Somerset County Council
Minerals Planning Options Paper Officer Response to Responses
March 2012
Page 1 of 193 Document Control Sheet
Reviewed and approved by Paul Browning: Planning Policy Manager (04/06/2014)
Minerals and Waste Policy Team Somerset County Council Environment Directorate PP C601C County Hall Taunton TA1 4DY
℡ 0845 345 9188 [email protected] www.somerset.gov.uk/mineralsandwaste
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Contents
Introduction ...... 4 1 Vision and Plan Objectives ...... 7 2 Aggregates ...... 23 3 Peat ...... 91 4 Building Stone ...... 117 5 Mineral Safeguarding Areas ...... 136 6 Development Management ...... 151 7 Additional Comments ...... 159
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Introduction This document contains details of the representations made on the Somerset County Council Minerals Options Paper during the consultation period 15 th December 2011 to 12 th February 2012.
The consultation documents were published on www.somersetconsults.org.uk and were accompanied by a questionnaire. The County Council's Minerals and Waste policy team encouraged respondents to reply via this website if possible and provided printed copies of the consultation document via Somerset’s libraries and Council Offices or on request.
The team promoted the consultation via email and letter mailings, as well as through the Somerset County Council website. Local media were involved, presentations were given at district and parish events, briefing notes were circulated at district and parish events, and meetings were arranged with consultees.
Postcards were sent out to approximately 3000 residents who live in, or in close proximity to existing minerals consultation areas – highlighting that the Minerals Options consultation was underway and how to get involved.
Prior to the consultation, all consultees (contactable by email) were emailed to determine how they wished to be notified of the Minerals Options consultation. This helped to shape the approach to consultation and engage in an optimal way.
National Policy
At the time of writing this document the final National Planning Policy Framework had not been published. Therefore the collation and consideration of all respondents’ representations and SCC responses in this document are made prior to the publication of the Framework. The Preferred Options document for Somerset minerals policy will be informed by consultation feedback in this document and the evolving national policy framework.
Page 4 of 193 Representation summary Representations were sought on a wide range of issues. 86 respondents replied, which can be divided into 1195 representations (individual comments).
The majority of respondents supported the proposals outlined, beginning with broad support for the proposed Vision and Objectives, with some constructive comments made to ensure that the final wording is as clear as possible; in particular, several representors highlighted the need for further clarity in reference to "limits set by the environment" in Objective A, and the need to ensure each Objective does not try to cover too many different ideas - in particular Objective C needs to be reviewed with this in mind.
Opinion was spread on the size of crushed rock landback, with some suggesting 10 years, some 15 years (in line with policy in the adopted Minerals Local Plan) and some 20 years or more.
Opinion was also mixed when additional reserves are needed for a demand that cannot be met from existing reserves (Issue A2), the approach to take on managing the shortfall in sand and gravel reserves (Issues A4) and the restoration of sites (Issue A5). On this last-named matter, broadly the same number of respondents supported restoration of sites in the East Mendips on a site-by-site basis as supported a more strategic landscape approach.
There was strong support for the supply of local building stone for local demand, whilst recognising markets outside of the County and the need to support the building stone industry to maintain its economic viability. Furthermore there was support for the mineral types listed for safeguarding.
There was general consensus that no further peat permissions should be granted. This aligns with the direction of national policy, in particular the emerging National Planning Policy Framework. And there was broad support for the coverage of Development Management topics proposed.
In addition, comments were welcomed on a range of other issues including, but not limited to:
• dormant and abandoned minerals sites in Somerset; • the importance for restoration of all minerals sites taking an holistic approach that where possible seeks to reflect changes in the industry, national planning policy, and new biodiversity targets and initiatives; • the importance of Somerset’s water resources, especially the Mendip Hills groundwater resource; and • ensuring that the County Council has a robust framework in place to consider the potential of oil and gas extraction in Somerset..
Page 5 of 193 Below is a summary of the number of representations received to the questions presented in the Minerals Options consultation
Question Number of representations number 1 71 2 65 3 32 4 62 5 29 6 60 7 26 8 30 9 32 10 49 11 68 12 34 13 66 14 27 15 25 16 59 17 20 18 48 19 51 20 19 21 85 22 26 23 30 24 31 25 36 26 28 27 29 28 57 Total 11 95
Please note : A full set of representations is presented below, together with a response from the Minerals Planning Authority as to how all comments have been considered. Some representations contain spelling or grammar errors. Representations have been reproduced faithfully so as not to inadvertently alter or nuance the intended meaning.
Since writing this document in accordance with the requirements of the National Planning Policy Framework and the Town and Country Planning (Local Planning) (England) Regulations 2012, the emerging Somerset Minerals Core Strategy has been renamed the Somerset Minerals Plan. However, this document has not been updated to reflect this change and still refers to the Minerals Core Strategy.
Page 6 of 193 1 Vision and Plan Objectives
The Minerals Options Paper included the following vision and plan objectives…
Vision for mineral extraction in Somerset :
To ensure sustainable supply and use of minerals to meet society’s needs without unacceptable impact upon Somerset’s environment or communities.
Objective A: To ensure that Somerset is able to provide an adequate and steady supply of minerals in accordance with government guidance in order to contribute to national, regional and local requirements within the limits set by the environment.
Objective B: To protect Somerset’s residents from impacts on human health associated with minerals extraction and transportation whilst recognising the benefits of the minerals industry, including provision of jobs.
Objective C: To protect the natural and historic environment of Somerset from impacts associated with minerals extraction and transportation recognising the potential for increased conflicts of interest due to climate change, particularly on the water environment, and opportunities for positive land use change in the long term.
Objective D: To promote the efficient production and use of primary minerals, together with the minimisation of waste, increased substitution of alternative materials, and appropriate timing of release of reserves thereby reducing the impact of mineral production on climate change and protecting finite resources.
Objective E: To reduce the impacts arising from minerals transportation on local communities and the climate by maximising opportunity for mineral movement by rail or water.
Objective F: To seek a positive contribution from the minerals industry whilst sites are operational in terms of improved carbon management and ongoing and final site restoration incorporating environmental and community enhancements such as, biodiversity,
geo -diversity, landscape, recreation and access.
Page 7 of 193 Objective G: To bring together the minerals industry and local communities to identify and implement suitable reclamation schemes at dormant or abandoned mineral workings that are problematic and unlikely to work again, for the benefit of local communities or the environment.
Objective H: To avoid the unnecessary sterilisation of valuable mineral resources by other types of development.
Question 1: Do you agree with the vision and objectives?
Summary of responses to question 1
6% (2 responses)
Agree Disagree
94% (31 responses)
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Detailed Responses
Rep Respondents’ comment s MPA Officer response s ID (in this section, the letters refer to the different Plan Objectives) R9.3 We are pleased with both the Vision and Objective C of the main Noted. document.
R12 We support the need for minerals development in Somerset to avoid The potential to enhance the quality of the natural environment and unacceptable impacts to the environment. It would also be helpful to quality of life for communities will be recognised in the Core Strategy - recognise the potential to enhance the quality of the natural environment high quality site restoration and after use will be planned for, and quality of life for communities through well designed and well funded recognising the wide range of possible land uses. site restoration and afteruse. Perhaps this could be highlighted in the accompanying text. Objective C - we welcome recognition of the need to C: The promotion of landscape scale conservation, where feasible, will protect the natural environment from impacts associated with minerals be addressed in the main body of the Core Strategy. The Vision and extraction and transportation. This objective should also highlight the Objectives are overarching. Detail on how the Vision and Objectives need to plan mineral exploitation strategically to help promote landscape will be delivered will be embedded in the policies and supportive text. scale conservation through the creation of corridors and core areas of wetland habitat, especially in relation to European and UK BAP priority D: Noted. habitats. Objective D - we strongly support the development and promotion of substitute materials, especially in relation to peat. We also strongly support the need to minimise carbon and other emissions from F: The Objectives are overarching - the detail will be included in the mineral development. Objective F - this objective should also recognise policies and supportive text. The role of minerals sites in climate the potential of restored mineral sites to aid climate change adaptation by change adaptation is noted. wildlife. Mineral sites supporting restored priority habitats can not only act as carbon sinks, but can enable priority European and UK BAP species G: Noted. to colonise new areas as they adapt to a changing climate. Objective G - we welcome and support this objective.
R13 Chapter 3 contains limited information to provide a reasonable context of Chapter 3 makes reference to the wealth and variety of environmental the environmental setting for minerals in Somerset, and consequently areas designated for nature and landscape conservation. Similar levels provides poor grounding for the proposed vision and objectives. The of detail were provided for other aspects of importance such as natural environment is one of Somerset's most important assets, transport, built heritage etc. The Core Strategy will contain more underpinning key county and regional economic activities such as detailed information providing a reasonable context of the tourism and agriculture. The value of the environment in ecological terms environmental setting of Somerset. is reflected in a suite of local, national and international designations, including 127 Sites of Special Scientific Interest, 13 National Nature Reserves, 3 Areas of Outstanding Natural Beauty, one National Park and
Page 9 of 193 7 Special Protection Areas and Special Areas for Conservation. A fairer summary of the importance of Somerset's natural environment ought to be provided within the Minerals Core Strategy as a means of providing appropriate context for the policies following. Objective A: Whilst the A: Review use of the phrase “within the limits set by the environment” aspiration to produce minerals "within the limits set by the environment" to ensure the final text is workable and practical to work towards. is positive, it is probably unworkable. There is, to our knowledge, no working model for establishing environmental carrying capacity, and therefore environmental limits. The concept definition and quantitative C: Consideration will be given to rewriting or clarifying this Objective methods remain debatable, and whilst the metric is a desirable one, and whether or not it contains too many different issues. Our climate uncertainties around indicators, measures, and evaluation tools have and water resources are considered particularly relevant (water rendered it theoretical rather than practical in a commercial setting for the especially to the Mendip Hills) and reference to them in the Objectives time being. Alternative wording could be around avoiding impacting on is still felt necessary. References to these issues have not been made ecosystem processes, services and goods, such as the ground water at the expense of other concerns; all relevant over-arching concerns aquifer, and contributing to ecological networks and biodiversity, for (including, but not limited to, biodiversity) will be addressed in the example. Objective B: No comment Objective C: As written, this Objectives as a whole. objective is unclear - it seems to be cramming a lot of issues into one sentence. A suggested alternative: "To protect the natural and historic environment of Somerset from impacts associated with the extraction G: Consider making this change, which will bring the Objective in line and transportation of minerals, and to maximise opportunities for positive with the multifunctional benefits that reclamation schemes can provide. land change in the long term." The details about climate and water are superfluous, as in any examination of issues around the natural environment these concerns rank highly anyway; drawing them out for specific mention risks over-emphasising these at the expense of other, equally pressing concerns such as biodiversity. Objective D: No comment Objective E: No comment Objective F: No comment Objective G: A small point, but perhaps where appropriate multifunctional benefit creation can be looked at within this objective, rather than the current wording which suggests "environment" and "community" benefits and mutually exclusive. Minerals after uses can frequently deliver environmental and community benefits simultaneously, for example in terms of recreation opportunities in beautifully rich nature reserves. Objective H: No comment
Page 10 of 193 R15.1 We agree with the sentiment of the overall vision statement, but as Whilst minerals are a finite resource the government’s objectives for minerals are a finite resource their supply cannot be regarded as minerals planning (Minerals Policy Statement 1) reflect the requirement sustainable. A clear distinction should be made between peat soils and to contribute to the achievement of sustainable development, as other "minerals" in any general statements made throughout the required by Section 39 of the Planning and Compulsory Purchase Act document. The future use of peat is likely to be limited if the policies to 2004. The supply and use of minerals can be managed to be as conserve our remaining peat soils put forward in the Natural Environment efficient and sustainable - so far as practicable. White Paper: "The Natural Choice: securing the value of nature" (June 2011) and the Draft National Planning Policy Framework (July 2011) are We anticipate that peat, aggregates and building stone will receive confirmed. Objective C should also recognise the impact of quarrying on individual attention in the Core Strategy, however, we do not anticipate groundwater as a significant potential conflict. There is a potential for singling out peat in the Vision and Objectives as these are overarching serious negative impacts on aquatic and riparian environments, and cave and apply to all minerals in Somerset. systems could be seriously damaged by de-watering. Objective E: Again a distinction should be made between quarries and peat sites. C: The potential impact of quarrying on groundwater will be specifically Restoration of historic transport links in the PPZ would have a damaging addressed in the Core Strategy. The wider water environment will be impact on biodiversity and heritage features during construction and referred to in the Objectives. operation. It is unlikely that the reinstatement of railways and canals would completely replace the use of roads for commerce. Provision of E: Noted. See the above comment in relation to peat. alternative transport links could improve the attractiveness of existing peat processing sites to different enterprises, which could be less G: Noted. compatible with the character of the area and have a negative impact on the environment. Objective G: We would like to see statutory and voluntary environmental stakeholders invited to participate in such discussions. R25 The AONB Unit supports the proposed Vision as it has a strong Noted. environmental protection element to it. The Unit also supports the objectives and considers that Objectives C, F and G are of particular relevance to the AONB
R28 The Town Council supports plan objectives F (regarding improved Noted. carbon management and restoration of the site incorporating environmental and community enhancements) and G (re suitable The different stages of consultation on the Core Strategy and reclamation schemes) in particular. It also feels that there should be associated discussions on restoration and reclamation have provided extensive consultation on dormant and abandoned sites to try and meet valuable information to help shape County Council policy and deliver objectives F and G. Objectives F and G. The Options paper included a section on dormant and abandoned sites. Further formal consultation will be undertaken as/when necessary and the County Council will continue to engage with all relevant stakeholders.
Page 11 of 193 R34 The vision should be to see the end if quarrying in Eastern Mendip. A vision to see the end of quarrying in Eastern Mendip is not in line with Objectives A - To change the national, regional and local requirement, Government policy and guidance, in particular policy stated in Minerals as they are exceeding the limits set by the Environment. B- To protect Policy Statement 1 and the Draft National Planning Policy Framework. Somerset residents from the effects of mineral extraction and transportation. Walking and cycling in Eastern Mendips are hazardous Forecasts on projected future requirements help the County Council to due to HGV's C - Agree D - Promote efficient use of alternative consider what is likely to be needed and how these needs could be met materials by reducing supply. I - To avoid disruption to residents live by without causing unacceptable damage to the environment and local quarrying. communities.
R35 Adequate and relevant. Noted. R36.2 We agree with these objectives but would wish to see a restriction of All sites outputs are controlled in relation to the type and size of the output to ensure that there remains a sensible safeguarding and respective site and its surrounding environment and infrastructure. monitoring of resources for future generations.
R41 In general the Objectives fairly state the requirements of the Minerals B: Consider making reference to the local economy and employment Core Strategy. We suggest that Objective B could confirm that the opportunities. benefits of the industry extend to the local economy as a whole and include the provision of direct and indirect employment opportunities. G: Chapter 5 of the Minerals Options Paper explains the current That reflects the far wider economic benefits than just the provision of situation and issues associated with dormant and abandoned minerals jobs. With regard to Objective G it is not clear if there is a problem in the sites. Consider if Objective G needs to be reworded – mindful of how first place and whether this objective is achievable. the Mineral Planning Authority could act within their means to improve the current position.
Page 12 of 193 R43 Objective A: "To ensure that Somerset is able to provide an adequate A: Consider removing the text “within the limits set by the environment” steady supply of minerals is accordance with government guidance in or consider changing the text “within the limits set by the environment” order to contribute to national, regional and local requirement within the to ensure that the text is workable and practical to work towards. limits set by the environment". It is suggested that the words within the limits set by the environment are deleted as Objective C related to the B: One of the Government’s objectives for minerals planning in protection of the natural and historic environment of Somerset. Objective Minerals Policy Statement 1 states: “to secure working practices which B: The reference to impacts on "human health" associated with minerals prevent or reduce as far as possible, impacts on extraction is considered alarmist and unnecessary. Minerals extraction the environment and human health arising from the extraction, and transportation is not a recognised problem to human health nor does processing, management or transportation of minerals”. Due to the the consultation document explain how this statement has been scale of minerals extraction in Somerset it is considered appropriate to determined. It gives an unrealistic negative image to the minerals include an objective on the protection of human health in local planning industry and should be deleted. Objective C: The reference to policy which is relevant to all minerals operations. "opportunities for positive land use change in the long term" is not considered appropriate in this objective. The objective seeks to protect C: It is not perceived to be inappropriate to have Objectives which seek whereas Objective F seeks to enhance. Objective D: It is suggested that to protect and enhance. Stakeholders would not wish to see any part the words 'where available' are added after '..increased substitution of of Somerset’s natural or built environment deteriorate, therefore alternative materials'. Alternatives to primary aggregates in some protection is needed. It is also felt appropriate to seek to enhance the applications are either secondary aggregates or recycled aggregates. natural and built environment after mineral activity, which is in line with There are no known sources of secondary aggregates in Somerset. Government guidance in Minerals Policy Statement 1 and programmes Recycled aggregates opportunities are maximised by the Quarrying such as Nature After Minerals which support high quality restoration Industry where available, for example the recycling of asphalt planings, and positive end land uses (e.g. recreation and biodiversity) for sites. recycling of concrete etc. Objective E: This objective is supported. Objective F: This objective is supported. Objective G: The general aim of D: Noted. this objective is supported however it is evident that a number of dormant quarries are held in private ownership. It is considered that this presents E: Noted. a significant barrier to the County Council, the Mineral industry and local communities in securing suitable reclamation schemes which could be F: Noted. implemented at identified dormant quarries in the future on a voluntary or financial basis. It is likely that private individuals would consider their G: While prohibition or revocation orders can be secured, this is a long dormant quarries to have a far greater financial value than say local process that is resource intensive and potentially sub-optimal. It is communities. In circumstances where the County Council and/or local better for all stakeholders to engage and resolve the permissions in a communities view dormant sites as problematic which could have beneficial way for all those involved. For this reason three mechanisms significant adverse impacts on local communities or local environments in were identified in the Minerals Options paper that could resolve the the event that quarrying resumes, then the County Council should use issues linked with problem dormant and abandoned sites. their statutory powers under the Town and Country Planning Acts to secure prohibition or revocation orders. Objective H: This objective is H: Noted. supported.
Page 13 of 193 R44 Objective A: "To ensure that Somerset is able to provide an adequate A: Consider removing the text “within the limits set by the steady supply of minerals is accordance with government guidance in environment” as this is covered in Objective C, or consider changing order to contribute to national, regional and local requirement within the the text “within the limits set by the environment” to ensure the text is limits set by the environment". It is suggested that the words within the workable and practical to work towards. limits set by the environment are deleted as Objective C related to the protection of the natural and historic environment of Somerset. Objective B: One of the Government’s objectives for minerals planning in B: The reference to impacts on "human health" associated with mineral Minerals Policy Statement 1 states: “to secure working practices which extraction is considered to be alarmist and unnecessary. Mineral prevent or reduce as far as possible, impacts on extraction and transportation is not a recognised problem to human the environment and human health arising from the extraction, health nor does the consultation document explain how this statement processing, management or transportation of minerals”. Due to the has been determined. It gives an unrealistic negative image to the scale of minerals extraction in Somerset it is considered appropriate to minerals industry and should be deleted. Objective c: The reference to include an objective on the protection of human health in local planning "opportunities for positive land use change in the long term" is not policy which is relevant to all minerals operations. considered appropriate in this objective. The objective seeks to protect whereas Objective F seeks to enhance. Objective D: It is suggested that C: It is not perceived to be inappropriate to have Objectives which seek the words 'where available' are added after '..increased substitution of to protect and enhance. Stakeholders would not wish to see any part alternative materials'. Alternatives to primary aggregates in some of Somerset’s natural or built environment deteriorate, therefore applications are either secondary aggregates or recycled aggregates. protection is needed. It is also felt appropriate to seek to enhance the There are no known sources of secondary aggregates in Somerset. natural and built environment after mineral activity, which is inline with Recycled aggregates opportunities are maximised by the Quarrying Government guidance in Minerals Policy Statement 1 and programmes Industry where available, for example the recycling of asphalt planings, such as Nature After Minerals which support high quality restoration recycling of concrete etc. Objective E: This objective is supported. and positive end land uses (e.g. recreation and biodiversity) for sites. Objective F: This objective is supported. Objective G: The general aim of this objective is supported however it is evident that a number of dormant D: Noted. quarries are held in private ownership. It is considered that this presents a significant barrier to the County Council, the Mineral industry and local E: Noted. communities in securing suitable reclamation schemes which could be implemented at identified dormant quarries in the future on a voluntary or F: Noted. financial basis. It is likely that private individuals would consider their dormant quarries to have a far greater financial value than say local G: Noted. While prohibition or revocation orders can be secured, this is communities. In circumstances where the County Council and/or local a long process that is resource intensive and potentially sub-optimal. It communities view dormant sites as problematic which could have is better for all stakeholders to engage and resolve the permissions in a significant adverse impacts on local communities or local environments in beneficial way for all those involved. For this reason three mechanisms the event that quarrying resumes, then the County Council should use were identified in the Minerals Options paper that could resolve the their statutory powers under the Town and Country Planning Acts to issues linked with problem dormant and abandoned sites. secure prohibition or revocation orders. Objective H: This objective is supported. H: Noted.
Page 14 of 193 R49 The vision and plan objectives need to recognise that the potential Objective A makes reference to national, regional and local impacts of mineral extraction in Somerset have implications that extend requirements for minerals, thereby helping to set the role of minerals beyond the County boundary. extraction in a wider context. Consider if more explicit references are required e.g. to cross boundary movements. R61 An aspect of Objective A is about a supply of stone for conservation of The Objectives, such as Objective A, are overarching – detail such as the built heritage and maintenance of local distinctiveness and character. the supply of stone for conservation of the built heritage and Should this be expressed here? maintenance of local distinctiveness and character will be included in the policies and supportive text in the main chapters of the Core Strategy. R71 I believe the Vision should include the reduction of peat extraction ahead To include a specific target for peat in the vision would be too specific of government targets. The Vision is not providing leadership in this area, and show prioritisation over other minerals worked in Somerset. The but is leaving that leadership to central government. I believe the County Vision and Objectives are overarching. The County Council’s peat Council should formulate its own peat extraction policy to preserve the policy will be contained in the main chapters of the Core Strategy. county's environment, and safeguard the water drainage systems. R74 Agree in general, but not on some specific points. Noted. R82 The Visions and Objectives look good on paper but in reality whilst the Quarries operate within the limits set in their planning conditions as part vision may be there the objectives are never reached. Quarries operate of their planning permissions. These conditions are enforced and without any respect for local communties and environment. Blasts are monitored by the Minerals Planning Authority, in Somerset this is hugh, load and cause vibration at levels well above current standards. Somerset County Council. Quarry traffic follow routes agreed as part Quarry traffic can not be enforeced and regulated - highways is a of their respective sites transport assessment between the Minerals govenment issue - and so trucks drive at speed with heavy loads through Planning Authority and the Operator. While traffic is one of the largest villages and lanes. Local councils are not consulted on planning re-occurring issues associated with quarrying, operators are doing what applications as it is a county matter. When close quarries they are just they can to improve this e.g. ensuring hauliers keep to the designated left on the day of closure and are never restored and landscaped and put routes and establishing new lorry schemes to reduce the impact of some other community or sensitive use. Safe guards never work, quarry vehicles. District and Parish Councils are consulted on planning planning conditions are poor and ignored and SSCC enforcement is applications. All currently active quarries have agreed restoration weak. conditions and plans. The Minerals Options Paper has consulted on problem dormant and abandoned sites in an attempt to resolve issues at the sites. R83 Objectives B & C appear to cover impacts outside the boarder of Noted. Somerset County including the Radstock area. Government policy advocates consideration of cross boarder matters in planning.
Page 15 of 193 R84 The Coal Authority supports Objective H which underpins the desire to Noted. prevent the unnecessary sterilisation of mineral resources which we consider complies with the advice in MPS1 and the BGS/Coal Authority document 'A Guide to Mineral Safeguarding in England' (2011).
R85 Place stress on Objective D minimising waste and substituting Noted. This is also supported in the County Council's Waste Core alternatives. Strategy.
R92 Particularly Objective E. Cheddar suffers from heavy traffic! Noted. R93 I agree but with the provision that Somerset County Council should The Minerals Options Paper has consulted on potential ways to ensure vigorously represent the interests of Somerset residents when they are that benefits are received within the County. asked to provide benefits to other parts of the UK which do not experience the costs The Aggregates Levy Sustainability Fund used to provide benefits to Somerset’s residents however the Aggregates Levy tax is now retained by Central Government. R100 I agree with the need for more small quarry sites to be found that can Noted. Quarry traffic follow routes agreed as part of their respective supply local building stone to local villages so that a continuity of heritage sites transport assessment between the Minerals Planning Authority can be maintained. I also feel very strongly that quarry lorries should be and the Operator. While traffic is one of the largest re-occurring issues prevented from driving through small villages and should only be allowed associated with quarrying, operators are doing what they can to on A roads at all times. improve this e.g. ensuring hauliers keep to the designated routes and establishing new lorry schemes to reduce the impact of quarry vehicles. R102 No objection to the Vision or any of the Objectives. Support for Objective Noted. A - to ensure that Somerset is able to provide an adequate and steady supply of minerals in accordance with government guidance in order to contribute to national, regional and local requirements within the limits set by the environment. Support Objective H - to avoid the unnecessary sterilisation of valuable mineral resources by other types of development.
Page 16 of 193 R103 The issues associated with noise and vibration impacts associated with The link is noted between noise and vibration considerations and mineral extraction are encapsulated within: Objective B: To protect proposed Objectives B, C, E and H. Somerset's residents from impacts on human health associated with minerals extraction and transportation whilst recognising the benefits of the minerals industry, including provision of jobs. Objective C: To protect the natural and historic environment of Somerset from impacts associated with minerals extraction and transportation recognising the potential for increased conflicts of interest due to climate change, particularly on the water environment, and opportunities for positive land use change in the long term. Objective E: To reduce the impacts from minerals transportation on local communities and the climate by maximising opportunity for mineral movement by rail or water. The protection of mineral sites from noise and vibration sensitive development would be encapsulated within: Objective H: To avoid the unnecessary sterilisation of valuable mineral resources by other types of development. R106 Objective A - it is not clear what is meant by the words "within the limits A: Consider explaining the definition of “within the limits set by the set by the environment". The words are too vague and open to environment” in the main text or in the glossary or rewording the text, to interpretation. The words should be deleted or explained. Objective B - ensure the text is workable and practical to work towards. the reference to impacts on "human health" is alarmist and unnecessary. Mineral extraction and transportation is not a recognised problem to B: One of the Government’s objectives for minerals planning in human health nor does the consultation document explain how this Minerals Policy Statement 1 states: “to secure working practices which statement has been determined. It gives an unrealistic negative image prevent or reduce as far as possible, impacts on and should be deleted. Objective C - the reference to "opportunities for the environment and human health arising from the extraction, positive land use change in the long term" is not appropriate in this processing, management or transportation of minerals”. Due to the objective. The objective seeks to protect whereas Objective F seeks to scale of minerals extraction in Somerset it is considered appropriate to enhance. However if the reference to long term positive land use change include an objective on the protection of human health in local planning refers to the Eco-systems approach to quarrying then this concept is not policy which is relevant to all minerals operations. supported as a generality. It is not considered to be viable or deliverable for all sites and is most appropriate for large sites and large landholdings. C: It is not perceived to be inappropriate to have Objectives which seek to protect and enhance. Stakeholders would not wish to see any part of Somerset’s natural or built environment deteriorate, therefore protection is needed. It is also felt appropriate to seek to enhance the natural and built environment after mineral activity, which is in line with Government guidance in Minerals Policy Statement 1 and programmes such as Nature After Minerals which support high quality restoration and positive end land uses (e.g. recreation and biodiversity) for sites. Furthermore, the reference to long term positive land use change does
Page 17 of 193 not only refer to an ecosystems approach but also positive end site uses, restoration etc. However, the ecosystems approach is supported national policy and guidance and emphasis has been placed on ecosystem services in the Natural Environment White Paper (Defra, 2011). An ecosystems approach is not only relevant to large sites and landholdings as an ecosystems approach attempts to adopt a holistic approach and ensure that the full value of the environment is considered in any decision making – including more participatory techniques and the inclusion of all stakeholders. Objective G - why are dormant/abandoned workings considered as being "problematic"? This is not explained. They certainly don't cause any G: While dormant/abandoned sites may not cause operational issues operational issues. If the Council feel they are unlikely to work again they for neighbouring sites, it is widely accepted that some have all the legislation they need to deal with them already. dormant/abandoned sites raise concerns for local communities. While prohibition or revocation orders can be secured by Somerset County Council; this is a long and complicated process. It is better for all stakeholders to engage and resolve the permissions in a beneficial way for all those involved. For this reason three mechanisms were identified in the Draft Options paper that could resolve the issues linked with problem dormant and abandoned sites. R108 Yes. We particularly support the emphasis on maintaining an adequate The Objectives are not listed in an order of priority but the ordering will and steady supply of minerals and contributing to national, regional and be considered in case there is a perceived impact or logic for a different local requirements (A). We recommend that Objective (H) is moved up ordering. the list (to follow A) to reflect the role that safeguarding will play in delivery of A. R113 Strongly support objective E in section four which seeks to reduce these It is expected that the Core Strategy will contain a table demonstrating impacts by maximising opportunities for moving minerals by rail or water. how each Objective is supported by the policies included in the Core They note, however, that the paper contains no discussion of how and Strategy. A list of indicators will also be included which will be used to when implementation of objective E will be achieved. They therefore monitor the Objectives etc of the Core Strategy. believe that the paper needs to be expanded to provide detail on the specific actions which Somerset CC intends to take, in conjunction with quarry operators and thers, to achieve Objective E over a measurable and auditable timescale.
Page 18 of 193 R115 I agree with, and support, the Vision and Objectives. They look very A: “ Within the limits set by the environment” is a phrase used in the comprehensive although achieving them all will be 'challenging'! One national objectives for minerals planning in Minerals Policy Statement point regarding clarity of Objective A - what is meant by the phrase 1. Essentially it means not subjecting the environment to detrimental "within the limits set by the environment"? Are there any advantages in impacts at the expense of securing an adequate and steady supply of including specific, quantifiable targets within the final Minerals Core minerals. However review the use of this phrase. Strategy which would be practically achievable, yet not unduly restrictive or prescriptive on future development, extraction or policy? For example; Quantitative and qualitative targets will be set in an Implementation and Objective E - to reduce the impacts from mineral transportation on local Monitoring chapter in the Core Strategy. These targets will be communities by cutting the number of road miles travelled within the monitored annually by using a serious of monitoring indicators used to County / vehicle movements by x%, or by increasing the amount of check the Core Strategy is delivering what it set out to deliver and to minerals transported by rail by y%. enable the policies in the Core Strategy to be monitored for effectiveness. R116 In C & D I do not believe 'impact of mineral production on climate change' There is research to demonstrate the carbon footprint of minerals is proven. extraction. Articles such as ‘Big Feet’ (Bloodworth and McEvoy, 2007) demonstrate how the extraction, processing and transport of minerals are responsible for ~7% of the total global energy consumption, thereby creating a significant carbon footprint. R117 We wish to see no mineral extraction - particularly peat or sand from the Noted. The importance of flood risk will be recognised in the Core Westonzoyland Airfield or any other land within the village within the Strategy. designated floodplane areas.
R119 Vision - Support Objective A - An aspect of Objective A is about a supply Vision: Support for the vision is noted. of stone for conservation of the built heritage and maintenance of local distinctiveness and character. Should this be expressed here? (Note: A: The Objectives, such as Objective A, are overarching – detail such This comment was made earlier in a separate response by Adron as the supply of stone for conservation of the built heritage and Duckwoth, Conservation Manager, SSDC) Objective B - Objective is maintenance of local distinctiveness and character will be included in unclear on what issue it is addressing? Reference is made to the Heath the policies and supportive text in the main chapters of the Core impact on Somerset residents and the benefits of quarries in supporting Strategy. jobs. Suggest that Objective is split to concentrate on a single issue; e.g. the impact of Minerals extration on Somerset residents through for B: Further explanation and or splitting this into more than one Objective example health, noise, dust, landscape ect...or the economic benefits of will be considered. minerals extration industry through provision of jobs, business ect.. Objective C - Support Objective D - Support Objective E - Support the C, D: Noted. principal of this objective but would suggest that an additional point is added in respect of lorrie movements which would form the greatest E: The impact of lorry movements will be addressed in specific policy in transportation impact for all quarries in South Somerset. Suggetsed the Core Strategy, particularly through the requirement to provide wording 'while managing the impact of lorry movements'. With the Traffic Assessments and relevant planning conditions associated with
Page 19 of 193 expectation that lorry movements can be controlled through limiting planning permissions. Consideration will be given to the inclusion in numbers of trips and the time they occur. Objective F - Support the Objective. Objective G - Support Objective H - Recognise the principal of this objective in preventing the unneccessary steralisation of land but would seek reassurance that this objective suitably recognises the Local F, G: Noted. Authority Development Plan and the growth strategy for the District. Would request that this objective is modified to make reference to H: The County Council will ensure that the Objectives are appropriately 'recognising and balancing the needs' of other types of development. balanced, taking into account District growth strategies alongside other considerations. R120 In general, I support the objectives, but I agree with other respondents Quarries operate within the limits set in their planning conditions as part who question whether the level of enforcement is adequate. For of their planning permissions. These conditions are enforced and example, I consider the quarry traffic should use A roads and the roads monitored by the Minerals Planning Authority, in Somerset this is that have been provided for them that are suitable for heavy traffic and Somerset County Council. Quarry traffic follow routes agreed as part should not take short cuts through the narrow roads and villages where of their respective sites transport assessment between the Minerals they create a risk to other legitimate road users, and cause damage to Planning Authority and the Operator. While traffic is one of the largest property and to the environment. In addition I think that not enough is re-occurring issues associated with quarrying, operators are doing what done to protect rivers and water sources. The contamination of the Mells they can to improve this e.g. ensuring hauliers keep to the designated stream and the risk to the water supply at Downhead are two examples. routes and establishing new lorry schemes to reduce the impact of Objective H should be reworded so that it recognises a need to achieve quarry vehicles. the necessary balance between other types of development and exploitation of mineral resources. We cannot protect all mineral Rivers and water sources and sites that have abstraction licences are resources from developments - they exist throughout the region. monitored by the Environment Agency. It is anticipated that a precautionary approach to protecting water resources and the close working relationship with the Environment Agency and Minerals Operators will be maintained in the Core Strategy.
H: Noted. A more balanced objective will be considered. R123 No – A. Noted.
Yes – B, C, D, E, F, G, H.
R124 A – Controlled supply. Noted. B – Human health – taken into account. Noise control, light control as well as dust management and effect of blasting.
Page 20 of 193 R125 Objective A. It is suggested that “within the limits set by the environment” A: Consider removing the text “within the limits set by the environment” is deleted as this is ambiguous and is covered by objective C. or consider revising the text “within the limits set by the environment” to ensure that the text is workable and practical to work towards. Objective B. There is no evidence of any meaningful detrimental impact on human health by mineral extraction. This should be removed. B: One of the Government’s objectives for minerals planning in Minerals Policy Statement 1 states: “to secure working practices which Objective C. It should be recognised that the water environment can be prevent or reduce as far as possible, impacts on improved by mineral extraction. The local water environment can be the environment and human health arising from the extraction, managed by mineral extractors in such a way as to improve water quality processing, management or transportation of minerals”. Due to the and flows. scale of minerals extraction in Somerset it is considered appropriate to include an objective on the protection of human health in local planning Reduced emissions of CO2 could result from local quarrying and reduced policy which is relevant to all minerals operations. transportation, rather than larger more central quarry activities and higher transport emissions. C: Noted.
Objective D. It should be recognised that there is very little opportunity of D: The current situation of secondary and recycled aggregates in substitution that is already not taking place in Somerset. The Somerset will be considered for the production of the Core Strategy. environmental effects of transporting substitutes should also be considered. Mineral reserves are defined by the British Geological Survey as being finite. Whilst minerals reserves in Somerset are extensive they can The mineral reserve in Somerset can’t be considered as finite. The only be worked where they occur, and once extracted or sterilised they reserve is tens of thousands of years. Common sense would suggest this are gone forever. to be infinite. G: While prohibition or revocation orders can be secured; this is a long Objective G. Many of these sites are not owned by members of the and complicated process. It is better for all stakeholders to engage and minerals industry. The Planning Authority has the appropriate powers to resolve the permissions in a beneficial way for all those involved. For act should it so wish to do. this reason three mechanisms were identified in the Minerals Options paper that could resolve the issues as problem dormant and Objective H. This is supported. abandoned sites.
H: Noted. R127 Add objective i: to ensure that once decided upon, all future applications Planning applications are considered with reference to the adhere to Somerset's Mineral Policy. Development Plan (including Somerset’s planning policy on minerals). In the event that a planning application is put forward for approval which does not meet a particular policy, the relevant planning officer will have justification for this which is ultimately up to Regulation Committee to consider.
Page 21 of 193 The County Council monitors mineral sites and takes appropriate enforcement when sites with planning permission do not comply with their planning conditions.
Page 22 of 193
2 Aggregates
Is sue A1: How big should the crushed rock landbank be?
Option a : Additional reserves should be identified now to ensure sufficient reserves remain at the end of the plan period to supply a further 15 years*.
Option b: Additional reserves should not be identified now. Policy will be included in the plan to allow further reserves to be secured, if necessary, towards the end of the plan period to ensure 15 years* supply is maintained.
* 15 years has been used as an example. You may consider 10 years or 20 years or more to be more appropriate.
Question 2: Which option do you support for Issue A1?
Summary of responses to question 2.
5% (responses)
41% Option a (15 responses) Option b Other
54%
(20 responses)
Page 23 of 193
Detailed Responses
Rep Respondents’ comments MPA Officer responses ID R13 From an environmental point of view, planning as far ahead, and at as Noted. However, there has to be a cap at some point in terms of large a scale as possible for minerals makes sense. Taking a long term, landbank as the provision of minerals should be in accordance with landscape-scale view of the landbank allows proactive assessment of the principles of sustainable development and avoid over-supply. systems impacts, and enables forward planning for the avoidance, minimisation, mitigation and compensation of identified impacts. Planning for ecological networks and ecosystem function becomes easier the clearer and more certain land use patterns are. SWT supports Option A for issue A1 because it allows communities and the minerals authority to work with the minerals industry to plan and act positively for nature. R15.1 On balance, we favour Option A as it should allow more sustainable use of Noted. the resource. There is already a massive landbank within Somerset but we do not accept that all of it should be worked. It would be logical to consider the allocation of new areas subject to a rationalization of the current landbank. This will not be easy as there will be a number of operators each vying for their own permissions. It is also critical to sustain the super- quarries, Tor and Whatley, provided they retain their rail connections. R18.2 Identification of any additional reserves should wait until an overall strategy The Minerals Core Strategy will play a central role in delivering this for sustainable operations, mitigation and restoration has been produced over-arching Strategy, following on from the currently adopted and agreed. Somerset Minerals Local Plan. The Minerals Local Plan supports the principles of sustainable development and includes policies that are appropriate to be used to guide the determination of minerals applications alongside other relevant policies in the Development Plan until the Minerals Core Strategy is adopted. R25 The AONB Unit does not have a strong preference between these options, The current crushed rock landbank held in Somerset's aggregate but considers that identifying sites up front would give more certainty in sites is substantial for both the expected Minerals Core Strategy Plan relation to sites proposed for future extraction. We consider any new sites Period (2013 – 2028) and a substantial period of time at the end of or extended extractions should be located outside the AONB boundary the plan period, it is therefore not anticipated that the Minerals Core unless an overriding national need for the materials can be proven and Strategy will identify any sites up front. acceptable mitigation demonstrated. Presumption against major minerals developments in AONBs is
Page 24 of 193 supported in Minerals Policy Statement 1. Also, the draft National Planning Policy Framework states that local planning authorities should as far as practical, ensure sufficient levels of permitted reserves are available outside AONBs.
It is expected that the Core Strategy will adhere to national policy. If any deviation is proposed, the County Council would need to give robust justification for doing so. R28 The Town Council would not wish to see a crushed rock landbank of Noted. Alongside consultation responses, the County Council will greater than 15 years - to avoid potential oversupply and a waste of finite need to consider national guidance, the importance and strategic resources, to encourage the development of more robust synthetic nature of Somerset’s crushed rock supply, the size of the current materials which could be used instead of finite source natural stone eg. crushed rock landbank, and the approach in the adopted Minerals slag/ash compounds and the need for flexibility in allowing for future Local Plan when formulating its new approach. provision of civic amenities such as transport, energy provision, AONB parks R34 The plan should be for 10 years supply. The need for primary aggregate Support for 10 years' supply is noted. Furthermore, it is noted that has been reducing for many years. This should continue by increasing the Minerals Policy Statement 1 advises that a minimum 10 year use of secondary aggregate. We should assume a supply rate 10 metric landbank should be retained for crushed rock. However, this issue tonnes/year or less - to encourage the reduction of waste in the use of must also be considered in the context of national guidance, the aggregates and the use of secondary aggregate. The land bank should be importance and strategic nature of Somerset’s crushed rock supply, reduced to ten years. The local communities do not want quarrying to the size of the current crushed rock landbank, and the approach in continue in their area for many years to come. Eastern Mendip has made the adopted Minerals Local Plan when formulating its new approach. its sacrifice. Now is the time to consider ways of alleviating their burden. Somerset apportionment has been greater than sales every year. The County Council will work to strengthen its knowledge of the Therefore it should be reduced to a more realistic figure. current situation regarding secondary aggregates in Somerset during the development of the Core Strategy and its supporting evidence base.
Due to the importance and strategic nature of Somerset’s aggregate supply; an adequate and steady supply will continue to be met in accordance with the principles of sustainable development. As the comparison of predicted demand and actual sales shows that on the whole Somerset’s annual sub-regional apportionment (given to Somerset by technical work undertaken by South West Councils) is greater than actual sales, Somerset will consider an alternative apportionment figure which is considered to be a realistic value. This approach is supported by National Government and is being adopted
Page 25 of 193 by other Mineral Planning Authorities.
R35 10 years Support for 10 years' supply is noted. Furthermore, it is noted that Minerals Policy Statement 1 advises that a minimum 10 year landbank should be retained for crushed rock. However, this issue must also be considered in the context of national guidance, the importance and strategic nature of Somerset’s crushed rock supply, the size of the current crushed rock landbank, and the approach in the adopted Minerals Local Plan when formulating its new approach
R36.2 There should be no need for further proposed areas since there is already Noted. a massively inflated landbank.
Page 26 of 193 R41 Paragraph 5.3.1 explains that a 15 year landbank would have, "the Comments in relation to paragraph 5.3.1 are noted. potential to result in very large reserves". Somerset is one of a very few counties where for many years there has been a large landbank and one Para 5.3.2: Phased restoration in large, deep, hard rock quarries is which has been more than adequate to meet the needs of industry and limited since the majority of the site is to be flooded (once working society without requiring regular replenishment. This has not, in our view, ceases), and in some cases areas are used for stockpiles etc. This led to any problems whatsoever. It has not led to increased production or prolongs the final restoration of respective quarries, even more so in more lorries but that is not surprising because it is commonly sites with large reserves. acknowledged that the industry responds to demand for its products but cannot create or manufacture a demand. The large landbank has not led to a proliferation in quarries and that has been borne out over the last half century during which numerous quarries have closed, some completely whilst others remain dormant, despite the fact that the County enjoys a large landbank. We agree with paragraph 5.3.1 that a large landbank results in a large reserve, which is of course a matter of fact, but we do not agree that it necessarily creates the problems envisaged in 5.3.2. Restoration need not be delayed because a quarry has not completed working because restoration can often be completed in phases. A large reserve need not influence planning outcomes because the stone can only be worked where it occurs and will only be worked if the market is available for it. The benefit of a large landbank is that it gives industry confidence to undertake long term investment not only in quarrying but in efficiency of plant and machinery, employment, safety, training, sustainable transport systems and restoration. A large landbank is not a problem. If identification of reserves were to result in a 15 or 20 year landbank at the end of the Plan period that is to be applauded because it reflects confidence in one of Somerset's most important industries. R43 Option b). but with reference to 20 years supply. The Somerset Strategic The preference of 20 years supply is noted. This will be considered in Sites Assessment (May 2011) identifies Moons Hill Quarry, Torr Works the context of the current size of Somerset’s landbank, the plan and Whatley Quarry as strategic mineral sites. It is suggested that issue period length, current and emerging national policy, the range of local A2 should deal solely with strategic sites and Issue A3 should be identified opinion on this issue and the approach taken in adopted local as relating to sites which serve a local market. Additions to the crushed minerals planning policy. rock landbank for strategic sites should be treated in a different manner than additions to the landbank at quarries serving the local market. Strategic Sites (Moons Hill Quarry, Torr Works and Whatley Quarry) and sites which serve local markers are addressed both by Issues A2 and A3. For example, Issue A2 could potentially be applied to Castle Hill Quarry as additional reserves could be needed there to supply a local market that could not be met from existing reserves elsewhere in Somerset, particularly on sustainability grounds. Also, to propose
Page 27 of 193 specific policies that address the sites separately could potentially be seen to prevent, distort or restrict competition. It is not perceived that the Core Strategy will only have policies for each Issue in the Options Paper; there could be more than one policy for each issue, or in some cases multiple issues could be addressed under one policy.
It is expected that Strategic Sites will be addressed through supporting text in the Core Strategy which will provide guidance on how to be treated in relation to the policies included in the Core Strategy. R44 Option b but with reference to 20 years supply. The Somerset Strategic The preference of 20 years supply is noted. This will be considered in Sites Assessment (May 2011) identifies Moons Hill Quarry, Torr Works the context of the current size of Somerset’s landbank, the plan and Whatley Quarry as strategic mineral sites. It is suggested that issue period length, current and emerging national policy, the range of local A2 should deal solely with strategic sites and Issue A3 should be identified opinion on this issue and the approach taken in adopted local as relating to sites which serve a local market. Additions to the crushed minerals planning policy. rock landbank for strategic sites should be treated in a different manner than additions to the landbank at quarries serving the local market. Issue Strategic Sites (Moons Hill Quarry, Torr Works and Whatley Quarry) A2: If additional reserves are needed form a demand that cannot be met and sites which serve local markers are addressed both by Issues A2 from existing reserves, how much more should be permitted? Option a. the and A3. For example, Issue A2 could potentially be applied Castle quantity of additional reserves is irrelevant as long as the environmental Hill Quarry as additional reserves could be needed there to supply a and local community impacts can be mitigated or are not significant. A local market that could not be met from existing reserves elsewhere proposal should be considered on its own merits and account should be in Somerset, particularly on sustainability grounds. Also, to propose taken of production capacity site and whether a significant investment is specific policies that address the sites separately could potentially be required at a particular site, for example replacement processing plant. seen to prevent, distort or restrict competition. It is not perceived that the Core Strategy will only have policies for each Issue in the Options Paper; there could be more than one policy for each issue, or in some cases multiple issues could be addressed under one policy.
Additional clarity on Strategic Sites will be provided through supporting text in the Core Strategy which will provide guidance on how to be treated in relation to the policies included in the Core Strategy.
Issue A2: Noted. R72 20 years would be more appropriate. The preference of 20 years supply is noted. This will be considered in the context of the current size of Somerset’s landbank, the plan
Page 28 of 193 period length, current and emerging national policy, the range of local opinion on this issue and the approach taken in adopted local minerals planning policy.
R74 15 years is a relatively short term. Much longer term planning is desirable, Minerals Policy Statement 1 advises that a minimum of a 10 year almost to the point of rationing supply. landbank should be maintained for crushed rock. The County Council will consider national guidance, the importance and strategic nature of Somerset’s crushed rock supply, the size of the current crushed rock landbank, and the approach in the adopted Minerals Local Plan when formulating its new approach. The County Council will consider this issue in the context the plan period length and the range of local opinion on this issue. R82 Who can forecast what the needs and enviornmental requirements and Crushed rock supply needs to be considered over a longer timescale restraints are going to be in 5, 10 or 15 years time? Why have a hugh pile than 5 years to ensure that a steady and adequate supply is of rock extracted with loss of local community amenity, lay unused and at a maintained and to provide the minerals industry with support for great cost to energy use and the enviroment? Need needs to be indentified necessary investment. evry 5 years. R85 A 15 year forward plan on a 15 year current plan would seem to be Noted. appropriate bearing in mind we are about half way though the existing planned period. The County Council will consider this issue in the context of the current size of Somerset’s landbank, the plan period length, current and emerging national policy, the range of local opinion on this issue and the approach taken in adopted local minerals planning policy. R91 Reserves for a further 30 years. Additional reserves identified now to 30 years is not considered to offer a sustainable approach, since it ensures sufficient reserves remain for a further 30 years at the end of the would not be in accordance with national policy and guidance and is plan period. unlikely to comply with the principles of sustainable development. R93 disadvantages of identifying preferred areas for future permissions: Noted. technology, issues & needs change & it is not good to be bound by permissions granted within a different (outdated) context
R98.2 Limited to 10 years supply. Support for 10 years' supply is noted. Furthermore, it is noted that Minerals Policy Statement 1 advises that a minimum 10 year landbank should be retained for crushed rock. However, this issue must also be considered in the context of national guidance, the importance and strategic nature of Somerset’s crushed rock supply, the size of the current crushed rock landbank, and the approach in
Page 29 of 193 the adopted Minerals Local Plan when formulating its new approach
R100 There is a large identified area of crushed rock already - I don't believe that The current crushed rock landbank held in Somerset's aggregate there is a necessity to identify any more reserves for at least the next 10 sites is substantial for both the expected Minerals Core Strategy Plan years Period (2013 – 2028) and a substantial period of time at the end of the plan period; it is therefore not anticipated that the Minerals Core Strategy will identify more reserves up front. R102 However, there would be no objection to Option B as long as regular Noted. Due to the current size of Somerset’s crushed rock landbank monitoring is undertaken to ensure that additional reserves are identified it is not expected that further reserves will need to be identified by the as needed taking into account actual sales. Option B states: "Additional County Council during the Core Strategy Plan Period (2013-2028). reserves should not be identified now. Policy will be included in the plan to However, this is not to say that future planning applications will not be allow further reserves to be secured, if necessary, towards the end of the considered as site situations and supply demands have to be plan period to ensure 15 years supply is maintained." It is questioned how assessed. Therefore policy to address this will be included in the the need to release additional reserves would be triggered? Core Strategy. Furthermore quantitative and qualitative targets, such a trigger for when there is need to release additional reserves will be set in an Implementation and Monitoring chapter in the Core Strategy. These targets will be monitored annually by using a series of monitoring indicators used to check the Core Strategy is delivering what it set out to deliver and to enable the policies in the Core Strategy to be monitored for effectiveness. R103 I think the 'if necessary' should be clarified and there would be a Noted. requirement to identify what policy changes or economic factors might trigger a move to protect or identify mineral resources. R106 Option b is supported with a minimum 20 year landbank at the end of the The preference of 20 years supply is noted. This will be considered in Plan period. It is not clear why this question has been asked at all? Now the context of the current size of Somerset’s landbank, the plan that the Torr deepening application has been approved there is well over period length, current and emerging national policy, the range of local 20 years of landbank already consented beyond the end of the Plan period opinion on this issue and the approach taken in adopted local in 2028 at the rate of 11.7 mtpa (average production) and almost 20 years minerals planning policy. at the rate of 13.41 mtpa (latest apportionment). Due to the size of Somerset’s landbank at the time of writing the Options Paper, which pre-dated the decision on Torr deepening, the question was worded as stated.
Page 30 of 193 R108 The policy of maintaining reserves sufficient for 15 years' supply at the end Comments in relation to 15 years supply are noted. of the plan period should be retained. This recognises the importance of maintaining a steady and adequate supply from Somerset for local, Tonnage to be provided : As the comparison of predicted demand regional and national needs, and the scale of investment in the quarries and actual sales shows that on the whole Somerset’s annual sub- contributing to that supply. It is also important to provide for long-term regional apportionment (given to Somerset by technical work security of supply and certainty, particularly in a context of changing undertaken by South West Councils) is greater than actual sales, planning policy including abolition of regional spatial strategies and their Somerset will consider an alternative apportionment which is policies setting out sub-regional apportionments. In terms of tonnage to be considered to be a realistic value, as supported by national guidance provided for, the sub-regional apportionment as agreed by the RAWP and other mineral planning authorities should be the starting point. However, we are aware that the new National Planning Policy Framework may advise that authorities may consider alternative figures, including a long term (10 year) average of past sales as the starting point for considering levels of provision. The MPA believes that if sub-regional apportionments are not used then this may be a pragmatic alternative, as long as it is applied consistently by authorities and is subject to discussion and agreement of the relevant AWPs, including consideration of cross-border (authorities and AWPs) implications. A number of authorities are proposing to use an average of past sales as the basis for future provision (eg Hampshire, Dorset and potentially Oxfordshire). In doing so they are also assuming that the level of imports will be maintained at a similar level (average of the past 10 years). This again highlights the importance of providing for long-term security of supply from net exporting authority areas. R115 Additional reserves should either be identified now (if sufficient data on Current data suggests that additional reserves do not need to be available resources and/or levels of likely future demand are known with identified now. If and when they do need to be identified, reasonable confidence) - or (if data is currently incomplete) then at the mechanisms to address this will be included in the Minerals Core very least as a specific action within the Minerals Core Strategy. Given the Strategy. national importance of Somerset as an aggregate producer, then ensuring 15 years supply is maintained seems logical. Given the sensitivities over Deepening of quarries is preferred to lateral extensions. This was quarry certain aggregates in certain areas, such as Carboniferous stated in the Options Paper and is expected to be incorporated into limestone within environmental sensitive areas such as the Mendip Hills, the Minerals Core Strategy. consideration should be given to the deepening of existing quarries rather than lateral extension where available reserves and geology warrant such a decision.
Page 31 of 193 R119 Given the complexity of providing a sufficient landbank that meets National Noted. Guidance and the economics of a viable Minerals extraction sector we would look to the development industry to provide a strong steer on this issue.
R122 Due to the number of factors at each quarry, the decision for additional Noted. reserves should not be made sooner than necessary and should ensure fair competition between the quarries. R124 Crushed rock landbank should be 15 years. Noted. This will be considered in the context of the current size of Somerset’s landbank, the plan period length, current and emerging national policy, the range of local opinion on this issue and the approach taken in adopted local minerals planning policy.
R125 Option b is preferred but at least a 20 year landbank should be maintained While long term in the industry may mean at least 20 years, current even at the end of the period. Financial investment is always on long term national minerals planning policy states that a minimum of a 10 year horizons within the quarrying industry. If sites are to be quarried in the landbank should be maintained for crushed rock. This issue will be most environmentally responsible manner and with due regard to local considered in the context of the current size of Somerset’s landbank, residents, then long term investment must be encouraged. Long term the plan period length, current and emerging national policy, the within the quarrying industry means at least 20 years. range of local opinion on this issue and the approach taken in adopted local minerals planning policy.
R127 Option B, 15 years is a good number. Noted.
Page 32 of 193 Question 3: What are the advantages and disadvantages of identifying preferred areas for future permissions in the Core Strategy?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 Identifying preferred sites now may blight future property prices, but it Noted. Since the Options Consultation began Somerset’s landbank would allow for suitable infrastructure to be planned in advance and not has increased. The current crushed rock landbank held in Somerset’s piecemeal as sites are identified. Also as quarry boundaries would be aggregate sites is now substantial for both the expected Minerals known in advance this would contribute to the development of Core Strategy Plan Period (2013 – 2028) and a substantial period of neighbourhood plans and development strategy overall. time at the end of the plan period, it is therefore questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy. R13 Linked to the previous question is the issue of identifying preferred areas The advantages and disadvantages of identifying preferred areas are for future permissions. There are immediate site-based benefits of understood and the examples included are noted. Since the Options assessing areas for future permissions ahead of their being brought Consultation began Somerset’s landbank has increased. The current forward by mineral extraction companies: the least environmentally crushed rock landbank held in Somerset’s aggregate sites is now damaging areas can be chosen and promoted, with clear policy substantial for both the expected Minerals Core Strategy Plan Period expectations for their subsequent restoration. Permissions in the most (2013 – 2028) and a substantial period of time at the end of the plan ecologically sensitive or functionally important areas can be more easily period; it is therefore questionable whether there is merit in identifying avoided if the forward plan is sufficiently explicit in designating those areas preferred areas for future permissions within the Minerals Core that are acceptable for future extraction. Identifying future permission Strategy. areas provides a prompt to develop policy and guidance on restoration too; being clear about your expectation for how these sites will contribute in the medium and long term to the local landscape, ecosystems and ecological network is in line with both the Government's Natural Environment White Paper, and the emerging National Planning Policy Framework, both of which highlight the requirements for local authorities to plan for ecological networks. As a side benefit, designating the usage of different areas of the landscape gives a degree of confidence for the future to local communities; present people with an inspiring vision for their landscape, one in which they can imagine a role and future for themselves, and they are far more likely to get engaged with that landscape - something I think we would all like to see.
Page 33 of 193 R15.1 If the landbank is adequate, then why would there be a need to grant Since the Options Consultation began Somerset’s landbank has additional permissions? If the particular mineral cannot be supplied from increased. The current crushed rock landbank held in Somerset’s the landbank then consideration needs to be given for further permissions aggregate sites is now substantial for both the expected Minerals to be granted. Core Strategy Plan Period (2013 – 2028) and a substantial period of time at the end of the plan period; it is therefore questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy. R18.2 The disadvantage of identification of future permissions now would be that Noted. this would not be informed or inform the overall strategy as described above. There is no need to rush into identifying new areas.
R25 As stated in question 2, this would give greater certainty that sites can be Noted. found to provide the county's required apportionment without needing to open new sites within the AONB.
R34 Eastern Mendips should not be identified for any future permission. Since the Options Consultation began Somerset’s landbank has increased. The current crushed rock landbank held in Somerset’s aggregate sites is now substantial for both the expected Minerals Core Strategy Plan Period (2013 – 2028) and a substantial period of time at the end of the plan period, it is therefore questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy.
However whether or not any future planning applications are permitted is subject to the argument for and against them that will be considered against the minerals policies adopted at that time – whether that is the currently adopted Minerals Local Plan or the emerging Minerals Core Strategy.
R35 Flexibility remains Noted.
Page 34 of 193 R41 It is advantageous for industry, communities and landowners to know Since the Options Consultation began Somerset’s landbank has which areas will be preferred for future working. However, planning policy increased. The current crushed rock landbank held in Somerset’s should always allow flexibility to prevent, in accordance with government aggregate sites is now substantial for both the expected Minerals guidance in MPS1, a large landbank being tied up in the hands of one or Core Strategy Plan Period (2013 – 2028) and a substantial period of two operators which would stifle competition. Therefore it is important that time at the end of the plan period, it is therefore questionable whether flexibility is retained. The smaller independent operator should be able to there is merit in identifying preferred areas for future permissions extend a quarry as may be necessary within the Plan period even though within the Minerals Core Strategy. the proposed extension area may not have been designated a preferred area at the start of the Plan period. This must be qualified that the Nonetheless, flexibility will be retained in the Core Strategy so that extension accords with the County's environmental policies. policies allow for smaller, local, independent operators to submit planning applications to extend quarries where necessary and where in accordance with the policies in the Development Plan. R43 It is considered that a long term strategy for quarrying on the Mendips to The strategy for quarrying in the whole of the County, including the identify potential aggregate resources based upon a land use and Mendips, will be completed via the production of the Minerals Core reclamation strategy should be developed through the Minerals Core Strategy. Since the Options Consultation began Somerset’s Strategy (MCS). landbank has increased. The current crushed rock landbank held in Somerset’s aggregate sites is now substantial for both the expected Minerals Core Strategy Plan Period (2013 – 2028) and a substantial period of time at the end of the plan period; it is therefore questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy. R44 It is considered that a long term strategy for quarrying on the Mendips to The strategy for quarrying in the whole of the County, including the identify potential aggregate resources based upon a land use and Mendips, will be completed via the production of the Minerals Core reclamation strategy should be developed through the Minerals Core Strategy. Since the Options Consultation began Somerset’s Strategy (MCS). landbank has increased. The current crushed rock landbank held in Somerset’s aggregate sites is now substantial for both the expected Minerals Core Strategy Plan Period (2013 – 2028) and a substantial period of time at the end of the plan period; it is therefore questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy. R74 Identifying preferred areas will help with all long term planning Noted. R75 Affect on further development could "sterilise" land. Keeps plan for the Noted. future
R81 Can extraction sites be used for other purposes after closure? If not why Yes they can – including biodiversity, recreation, tourism, industrial not? etc.
Page 35 of 193 R82 Advantages are that it gives quarry companies assests to increase the While planning permission would be granted in relation to current value of their bussiness. Planning permissions are granted now to current standards and regulations, when their respective review dates come standards and regulations and therefore do not have to meet future they would have to comply with any new regulations. Areas of land regulations and enviromnetal constraints. Areas of land become lanlocked potentially identified give certainty to local communities and for no other use or development and quarries get unfair advantages. No businesses on areas identified and allow stakeholders to be clear real advantages for communities or local businesses. about how these sites will contribute to the local landscape, ecosystems, alternative land uses and end uses. Preferred areas do not disadvantage alternative development (e.g. housing, commercial industries etc), as in Somerset’s Case, District Core Strategy’s identify and allocate areas of land for preference to this kind of development. R85 Continuity and avoidance of blocking potentially useful signals. Noted. R86 Dont know but is surely better to be prepared well in advance Noted. R91 Ensuring roads to and from working sites are suitable for the type of Noted. transport needed, widening narrow lanes or building new roads to sites, or limiting the size of vehicles working on the site.
R10 0 The disadvantage of identifying areas of crushed rock now is the possibility Noted. of over production.
R102 Preferred sites have the advantage of offering a level of certainly to both Noted. the minerals industry and communities on areas of future mineral development. We would not have a specific preference over the identification of preferred sites or determining applications in accordance with policy. However, we would support specific criteria based policies for determining applications as opposed to reliance on national policy as suggested. R103 The identification, combined with guidelines on requirements for Noted. consultation, should ensure there is sufficient opportunity to recognise any need to protect against inappropriate District Council controlled development that may constrict future mineral extraction by virtue of the inability to contain environmental impact to acceptable limits.
Page 36 of 193 R106 There is no need to identify any further areas for extraction as the Since the Options Consultation began Somerset’s landbank has landbank is sufficient. Identifying individual Preferred Areas would provide increased. The current crushed rock landbank held in Somerset’s a clear advantage to those sites which had a Preferred Area and a aggregate sites is now substantial for both the expected Minerals disadvantage to those that did not. The Consultation paper considers Core Strategy Plan Period (2013 – 2028) and a substantial period of policy to allow for minor permissions to be granted where there are no time at the end of the plan period; it is therefore questionable whether unacceptable impacts or where environmental/community gains are there is merit in identifying preferred areas for future permissions proposed or where there is no alternative supply available and this is more within the Minerals Core Strategy. equitable. R108 Advantages include providing greater certainty for investment and host Noted. communities, and also being consistent with current national policy (MPS1) which advises planning authorities to identify specific sites, preferred areas and/or areas of search in LDDs. Disadvantages may be reduced flexibility for development outside of these areas to be considered positively and on its merits, although this could be accommodated through policy wording. R115 Advantages of identifying preferred areas for future permissions include Noted. confidence in maintaining future supplies for local and national needs, and enabling maximum time (pre-development) for proper consideration of all potential environmental, infrastructure and community impacts. Disadvantages include potential land or property blight, impacts upon community infrastructure etc.
R116 Advantages are preferred areas can go into planning process Noted. R119 Advantages of identifying a preferred area for future permissions is greater Noted. However, since the Options Consultation began Somerset’s developer and public certanity in respect of the location of suitable sites landbank has increased. The current crushed rock landbank held in however this takes away the flexibility of new works. Given the detailed Somerset’s aggregate sites is now substantial for both the expected nature of geological records (Figure 1: Location of Somersts Minerals Minerals Core Strategy Plan Period (2013 – 2028) and a substantial activity) and certainty associated with the location of minerals we consider period of time at the end of the plan period; it is therefore the first option is preferable. questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy.
Page 37 of 193 R120 There is an advantage for planning and investment purposes. For Noted. example, if the answer could be known, it would be helpful for other regional planning concerning the infrastructure (roads etc), plans to protect the environment and alternative forms of landuse. It would also help decisions about investment by the quarries themselves. But this would appear to be outweighed by the risks. The need for crushed rock may recede due to excessive extraction. The environmental impact can only be judged based on experience, things may not turn out as expected. External factors may change for example the need for crushed rock could reduce due to use of alternative materials or due to reduced investment in building and expansion due to the economic recession. The list could go on. R123 Advantages – method of transport. Noted. Potential effects on residents in close proximity to preferred sites are the same as potential effects on residents in close proximity Disadvantages – lack of competition therefore increase of prices. Effect on to existing sites. These effects are monitored and mitigated where residents, noise, dust, blasting, threats to water supply. appropriate. R124 Advantages – concentration in isolated areas. Transport net ads. Less Noted. Potential effects on residents in close proximity to preferred damage to wider rural areas. sites are the same as potential effects on residents in close proximity to existing sites. These effects are monitored and mitigated where Disadvantages – impact on local residents. Impact on environment appropriate. (concentrated). Lack of competition therefore increase of prices. R125 No preferred areas for future permissions should be identified. There Since the Options Consultation began Somerset’s landbank has should be clear policy to allow permissions in areas other than strategic increased. The current crushed rock landbank held in Somerset’s sites where there are no unacceptable impacts or where environmental aggregate sites is now substantial for both the expected Minerals gains are available or where local demand needs to be met. Core Strategy Plan Period (2013 – 2028) and a substantial period of time at the end of the plan period, it is therefore questionable whether there is merit in identifying preferred areas for future permissions within the Minerals Core Strategy. Policies will be included in the Core Strategy that address both strategic sites and non-strategic sites. R127 Traffic Planning. Noted.
Page 38 of 193
Issue A2: If additional reserves are needed for a demand that cannot be met from existing reserves, how much more should be permitted?
Option a: The quantity of additional reserves is irrelevant as long as the environmental and local community impacts can be mitigated or are not significant. A proposal should be considered on its own merits.
Option b: When the landbank is already sufficient any addition under exceptional circumstances should be limited, for example to 25 years supply, to meet the identified need only.
Question 4: Which option do you support for Issue A2?
Summary of responses to question 4.
5%
(2 responses)
Option a Option b
Other
50%
45% (19 responses) (17 responses)
Page 39 of 193
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R12 We believe there should always be a limit on the amount of mineral The amount of extractable material in Somerset is guided by yearly material that is extracted during any plan period. Flexibility could be apportionment levels predicted by using forecasting models provided to allow further development under exceptional circumstances developed by national government and/or monitoring annual sales. provided these can be justified. This helps inform the size of the landbank required and therefore the amount of expected material to plan for during the plan period. To set a limit on what can be extracted during a plan period may potentially hinder national development. However, individually sites do have conditions which impose output limits taking into account the surrounding environment and infrastructure. R13 The stated aim of the government's draft National Planning Policy Policy in the Core Strategy will protect against unacceptable Framework for minerals is to "secure an adequate and steady supply of community and environmental impacts. indigenous minerals needed to support sustainable growth, whilst encouraging the recycling of suitable materials to minimise the requirement for new primary extraction". It seems that Option A2 best accords with this aim, by recognising the adequacy of the landbank. However, SWT would like to see additional safeguards inserted into the policy wording to ensure avoidance and minimisation of ecological impacts, and the delivery of environmental and community benefits arising from any additions.
R15.1 We support Option B, but it should be implemented only in the case of an It is also important to support regional and local supply, as the exceptional national requirement. Somerset aggregate industry also plays a key role on these levels.
R18.2 Somerset will probably be expected to find the resources according to the Noted. pace at which development/demand proceeds. The important thing is to ensure that sufficient resources are made available from producers to carry out adequate mitigation and restoration. Railheads at least ensure some sustainability
Page 40 of 193 R25 The AONB Unit considers it essential that environmental and community Policy in the Core Strategy will seek to protect against unacceptable safeguards are put in place to ensure that impacts are not significant and community and environmental impacts and mitigate them where can be mitigated. A presumption against additional large scale quarrying in necessary. the AONB should be established, unless there is an overriding national demand for a material that can only be supplied in that location and Presumption against major minerals developments in AONBs is adequate environmental, social and economic mitigation can be put in supported in Minerals Policy Statement 1. Also, Draft National place. Planning Policy Framework states that local planning authorities should as far as practical, ensure sufficient levels of permitted reserves are available outside AONBs. It is expected that the Core Strategy will adhere to national policy. If any deviation is proposed, the County Council would need to give robust justification for doing so. R34 No more should be permitted. Market forces should operate. Users may Market forces do operate. Large reserves do not mean a large wish to import materials. supply, as shown during the recession, as demand for aggregates has fallen and so have sales from the Mendips. Importing non- indigenous materials from a strategic perspective is not in accordance with national planning guidance and is not sustainable. R35 Option a is considered the most pragmatic approach. Noted. R36.2 Option b, as being the lesser of two evils. Noted. R41 Option a is supported for the economic reasons given in paragraph 5.40. Noted. R43 Option b) would be appropriate for strategic quarries - Moon's Hill, Torr The County Council will develop its Core Strategy to be a workable and Whatley Quarries. For smaller quarries which serve a more local plan that provides flexibility to all stakeholders, including operators. market then Option a) would be appropriate. Option a. the quantity of additional reserves is irrelevant as long as the environmental and local community impacts can be mitigated or are not significant. A proposal should be considered on its own merits and account should be taken of production capacity site and whether a significant investment is required at a particular site, for example replacement processing plant.
R44 Option b) would be appropriate for strategic quarries - Moon's Hill, Torr The County Council will develop its Core Strategy to be a workable and Whatley Quarries. For smaller quarries which serve a more local plan that provides flexibility to all stakeholders, including operators. market then Option a) would be appropriate.
R74 There are always alternatives and demand exceeding supply is not Noted. uncommon. It should be resisted otherwise any planning is wasted effort.
Page 41 of 193 R75 If over 20 years suppy Noted. R82 Same answer as 2. A 25 year supply is excessive in current and changing This issue will be considered in the context of the current size of needs. Technowledgy is likly to change. In 2 years there are likly to be Somerset’s landbank, the plan period length, current and emerging electric cars that are lighter and do not need such heavy road surfaces. national policy, the range of local opinion on this issue and the For instance, car use may reduce. Perhaps cars will not be needed at all approach taken in adopted local minerals planning policy. as we we all be living and working from home. 5 years should be sufficent.
R85 This clause appears to limit the risks of over-supply with wasteful use of Noted. resources.
R91 If materials are desperately needed it is important that supplies are met by Noted. using British materials, not imported from across the sea's.
R103 Option A is favourable however the use off planning restriction on output Daily output rates are more relevant to the impacts felt by might be used to prevent over supply adversely affecting existing communities, particularly traffic related, than the total amount of operations and creating unsustainabillity issues for existing operations. reserves.
R106 Issue A2 This issue really deals with strategic sites and therefore it should Strategic Sites (Moons Hill Quarry, Torr Works and Whatley Quarry) be clearly stated as a policy for such sites. Option a is preferable. This and sites which serve local markers are addressed both by Issues A2 issue is only relevant to the strategic sites (Whatley, Torr Works and and A3. For example, Issue A2 could potentially be applied to Castle Moons Hill) where there is a demand for large volumes of rock or for a Hill Quarry as additional reserves could be needed there to supply a specific type of mineral that cannot be met from anywhere else. local market that could not be met from existing reserves elsewhere Paragraph 5.13 and 5.14 The Somerset Strategic Sites Assessment in Somerset, particularly on sustainability grounds. Creating policy identifies that Torr Works, Whatley and Moons Hill quarries can be which provides flexibility to support the industry at local, regional and regarded as being of strategic importance since there are limited national level is important. Also, to propose specific policies that alternative supplies to those provided by these sites. Additions to the address the sites separately could potentially be seen to prevent, aggregate landbank at strategic sites should be treated in a different distort or restrict competition. It is not perceived that the Core manner than additions at quarries that serve a more local need. Therefore Strategy will only have policies for each Issue in the Options Paper, Issue A2 should be clearly identified as relating to Strategic Sites and there could be more than one policy for each issue, or in some cases Issue A3 should be identified as relating to sites serving a local need. multiple issues could be addressed under one policy
It is expected that further information on Strategic Sites will be included in supporting text in the Core Strategy which will provide guidance on how they would be treated in relation to the policies included in the Core Strategy.
Page 42 of 193 R108 The Minerals Options paper refers to constraining additional reserves Noted. (Option b) as being more sustainable. However, additional reserves will only be worked if there is a market for the material. As long as the potentially adverse impacts of working are managed satisfactorily, then permitting new reserves will not result in unsustainable effects. Permitting additional reserves may also help to maintain diversity of supply (materials, locations and markets) and avoid stifling of competition. We assume that Issue A2 refers to both strategic and non-strategic sites. this question/issue refers to the Strategic Sites identified in the Options Paper and Land Use Consultants' assessment, and therefore this should be made clear.
R115 A blend of these options seems ideal! Option b is preferable in terms of Noted. Policy in the Core Strategy will protect against unacceptable avoiding overly excessive landbank levels and potential wasting of community and environmental impacts. irreplaceable resources. However, any proposal should be judged on its merits with full attention paid and mitigation provided for any environmental and local community impacts.
R119 Consider that the 'type' of proposal is relevant to the approach taken. In Noted. The Core Strategy will need to be sufficiently flexible to the case of a large-scale application where a large 'reserve' is known to consider all types of minerals sites and related applications. exist a time bound approach as advocated as in 'option b' seems sensible. As this allows the Authority a review process. However in the case of small-scale deposits where quantity is limited and the mineral is rare /unique the first 'option a' should be taken e.g. the proposal is considered on its individual merits. As this allows the Council the flexibility to adapt to changing demands. R120 I agree that it must be limited to the identified need - see b. This is Noted. Policy in the Core Strategy will protect against unacceptable important because it may not be possible to correctly identify the community and environmental impacts. significance of impacts on the community and the environment and serious mistakes could occur if assumptions are made about this, based on limited evidence. Mitigation only goes part of the way to protect the environment or the community. There will always be some detrimental effect.
R124 Impact on water sources. Due to the importance of Somerset’s water resources, particularly in the Mendip Hills, water will be addressed through relevant policy in the Core Strategy as similarly covered through specific policy in the adopted Minerals Local Plan.
Page 43 of 193 R125 Option a is supported. As expressed earlier, the level of landbank is It is important to not create a situation where Somerset’s landbank is somewhat irrelevant. If environmental and local community impacts can in a situation of over supply, to ensure that national secondary and be mitigated or are not significant, a proposal should be considered recycled aggregate tonnages are not reduced due to the size of favourably. minerals planning authorities’ landbanks, and to follow the principles of sustainable development.
Question 5: How should an excessive landbank be defined?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R15.1 As a large area of the Mendip Hills could be considered a potential Noted. landbank, we believe that it should be limited to a figure that is close to the projected annual production figure for the period of the plan and a subsequent plan, subject to close scrutiny of the sustainability of any allocations. R25 The AONB Unit considers that a 10 year landbank for crushed rock across Noted. the AONB and East Mendips, as suggested in MPS1 and the draft NPPF, is reasonable. R34 An excessive land bank could be defined as one that distorts market Noted. forces. R35 An excessive landbank should be defined where there is a large impact on This would be hard to monitor and measure on a County basis. the community, infrastructure and the Mendips natural and beautiful environment.
R41 There is no such thing as an excessive landbank. Noted.
Page 44 of 193 R43 A landbank is a guide and not a cap. It should be used as an indicator of A landbank is used as an indication of when new reserves are likely when additional reserves are likely to be required, (a floor) to maintain an to be required to allow current apportionment/output rates to continue adequate supply of aggregates, rather than used to determine an upper to be met. While Minerals Planning Policy Statement 1 only states a level (ceiling) or to define an excess of reserves. There is no need to minimum landbank of 10 years should be maintained for crushed define an excessive landbank. Other issues need to be taken into account rock, in accordance with the principles of sustainable development it for example, production capacity and whether a site is of strategic is not appropriate to maintain an excessive landbank. The Core importance. A proposal should be considered on its own merits, taking into Strategy will seek to maintain an appropriately sized landbank, that is account prevailing circumstances at that time. flexible, in line with national planning policy and sustainable development, recognises the surrounding environment and communities, and takes into account operational requirements. In this way the County Council will consider proposals on their own merits. R44 A landbank is a guide and not a cap. It should be used as an indicator of A landbank is used as an indication of when new reserves are likely when additional reserves are likely to be required, (a floor) to maintain an to be required to allow current apportionment/output rates to continue adequate supply of aggregates, rather than used to determine an upper to be met. While Minerals Planning Policy Statement 1 only states a level (ceiling) or to define an excess of reserves. There is no need to minimum landbank of 10 years should be maintained for crushed define an excessive landbank. Other issues need to be taken into account rock, in accordance with the principles of sustainable development it for example, production capacity and whether a site is of strategic is not appropriate to maintain an excessive landbank. The Core importance. A proposal should be considered on its own merits, taking into Strategy will seek to maintain an appropriately sized landbank, that is account prevailing circumstances at that time. flexible, inline with national planning policy and sustainable development, recognises the surrounding environment and communities, and takes into account operational requirements. In this way the County Council will consider proposals on their own merits. R74 by careful consideration of the local environment and community impact. Noted. R82 Higher than 15 meters in an acre of land. Greater than 25% of current All planning permissions can vary in the time it takes for them to be orders identified and proved by quarry companies. It does not take long to considered. To maintain an adequate and steady supply of minerals blast some rock but 5 to 10 to 15 years to get planning permission for a and support local and national development priorities long term major highway, Rver Seven Barrier, power station, etc. planning is required.
R85 Provision beyond identified needs. Noted. R86 When more than can be immediately required in the medium term It is important to plan in the long term as well. R91 Who knows what needs we will have in the future. Always keep a well Noted; however, it is important to ensure that the principles of stocked cupboard to meet any emergency. sustainable development are followed and that an over supply situation is not created.
Page 45 of 193 R93 An excessive landbank could be defined as one the exploitation of which Policy in the Core Strategy will protect against unacceptable would lead to: significant damage to or alteration of the landscape or community and environmental impacts. biodiversity, significant deterioration of the air or water environment, significant loss of use of land for other economic purposes including agriculture, significant damage to property or human health.
R100 When there is mroe that enough crushed rock to supply for the next 10 Noted; however, due to Somerset’s strategic supply to the South East years and London, and local markets a crushed rock supply of more than 10 years may be appropriate. R106 There is no need to define "excessive" particularly as it may not be A landbank is used as an indication of when new reserves are likely included in the National Planning Policy Framework. A landbank is to be to be required to allow current apportionment/output rates to continue used as a guide and is more appropriate as a floor rather than a ceiling. to be met. While Minerals Planning Policy Statement 1 only states a The term "excessive landbank" is irrelevant in the context of strategic sites minimum landbank of 10 years should be maintained for crushed as clearly shown by the recent approval of the Torr deepening application rock, in accordance with the principles of sustainable development it even though the landbank was 350 million tonnes when the consent was is not appropriate to maintain an excessive landbank. The Core granted. If a policy was to be adopted which resisted further consents Strategy will seek to maintain an appropriately sized landbank, that is when there was an "excessive landbank" then strategic sites would not be in line with national planning policy and sustainable development, allowed further consents until the landbank had declined irrespective of the recognises the surrounding environment and communities, and takes merits of the proposal and even though they were regarded as being into account operational requirements. The Core Strategy will strategic. Similarly if a policy relating to "excessive landbank" only applied provide flexibility and a fair and balanced approach in its policies so to non-strategic sites that would be prejudicial and anti-competitive. It that strategic and non-strategic sites are both provided with fair and must be remembered that the Government is currently investigating the balanced opportunities. competitive nature of the minerals industry and the barriers to entry which exist including planning restrictions.
R108 There is no need to define 'excessive' nor use the term, particularly as this Noted. term and test may not feature in the NPPF. Landbank should be used an indicator of when additional reserves are likely to be required (a floor) to maintain supply, rather than used to determine an upper level (ceiling) or to define an excess of reserves.
R115 Utilisation of best available national and local data and trend analysis from Past sales data is already collected to produce Regional Aggregate previous 20-25 years, projected forward for an additional 20-25 year Working Party Reports. Mineral Planning Authorities are currently period. using averaged sales data from the past 10 years to inform the yearly production total to plan for. Nationally forecasting models are used to help produce apportionment figures, although these figures have always been higher than actual production figures.
Page 46 of 193 R116 Exceeds projected demand Noted. R117 By research of all options Noted. R119 Understand that this issue is a balancing act beteen quanity and rarity of Noted. different minerals, opposed to the size of the reserve. Given the compelxity of the issue Would look for a steer from the Minerals industry for exact definition.
R120 Don't know. No comment. R122 Greater than 25 years capacity at current output rate. Noted. R123 AI – permission to quarry to sea level – 30-40 years An excessive landbank could not be defined by the granting of 15 year permission already in place! permission of a planning application to extend or deepen any quarry. Disregard to the effect of water situation – naturals sources and the This would be prejudicial against that site. aquifer. Due to the importance of Somerset’s water resources, particularly in the Mendip Hills, water will be addressed through relevant policy in the Core Strategy (noting it was also given specific coverage in the adopted Minerals Local Plan). R124 AI – permission to quarry to sea level over 30-40 years with already a 15 An excessive landbank could not be defined by the granting of year permission of reserve. permission of a planning application to extend or deepen any quarry. This would be prejudicial against that site. R125 What is to be gained by defining an excessive landbank? A large Noted. While a cap is not supported in planning guidance, planning landbank does not mean an increase in quarrying activity. The level of authorities should ensure that an adequate and steady supply of quarrying is set by customer demand as there are no practical substitutes minerals is planned for that doesn’t risk over supply and is not in the area. The landbank should be seen as a floor and not a cap. The excessive and therefore doesn’t breach the principles of sustainable floor is to prevent society running out of an essential commodity. The cap development. serves no purpose except perhaps to restrict competition. R127 Excessive is anything over the 25year supply. Noted.
Page 47 of 193 Issue A3: Maintaining local supply
Option a: Proposals will only be permitted if they result in significant benefits to local communities or the environment and do not significantly increase the size of the landbank.
Option b: Proposals will only be permitted if they result in significant benefits to the local community or the environment and are proportionate to the output at the relevant site.
Option c: There is no need to make provision for additions to the landbank when the landbank is excessive.
Question 6: Which option do you support for Issue A3?
Summary of responses to question 6.
5% (2 responses) 24% (9 responses)
24% (9 responses) Option a
Option b
Option c Other
47%
(17 responses)
Page 48 of 193
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R12 However, where further development is consented it should result in Noted. Policy in the Core Strategy will seek to protect against significant benefits to local communities and the environment, preferably unacceptable community and environmental impacts and obtain both. benefits for both where relevant.
R13 Option B. Of all 3, this option appears to offer more certainty of both Noted. controlling negative environmental impacts and securing substantive ecological gain. Option C appears not to offer the flexibility of encouraging minerals producers the chance to relinquish existing permissions in exchange for a permission at a new site which could be less environmentally damaging - there may be cases in the future where environmental variables have shifted over the life of a permission, rendering a quarrying operation particularly detrimental to the natural environment, and placing the authority in the position of needing to negotiate an abandonment of that site. The inclusion of the need for "significant benefits" to the environment gives confidence that stringent requirements will be placed upon those seeking new permissions to minimise initial impacts and deliver genuine landscape-scale enhancements throughout the life of the project.
R15.1 We support Option B as it appears to support the need to maintain existing Noted. railhead quarries, which would be better for the environment.
R18.2 Option b is a more flexible approach in an industry which is demand led. Noted. This option puts emphasis on the potential benefits to the local communities and the environment. It would also respond better to the needs to both the large and smaller producers.
Page 49 of 193 R25 There may be future opportunities for small scale additions in the AONB to Policy in the Core Strategy will seek to protect against unacceptable maintain the local supply. There must, however be a clear policy to protect community and environmental impacts and obtain benefits for both and enhance the environment and provide benefits for local communities. where relevant. These additions should be linked to an existing site, such as Callow Rock or Battscombe, and the extensions should be proportionate to the output Presumption against major minerals developments in AONBs is from the site. Additions within the AONB should generally be small scale supported in Minerals Policy Statement 1. Also, Draft National and there needs to be a restoration plan in place to provide landscape, Planning Policy Framework states that local planning authorities biodiversity and recreation gains. should as far as practical, ensure sufficient levels of permitted reserves are available outside AONBs. It is expected that the Core Strategy will adhere to national policy; thereby any additions within the Mendips Hills AONB would be appropriate in size and like sites outside of the AONB would, where possible and feasible, provide landscape, biodiversity and recreation gains. R34 Market forces should be allowed to operate. Recycling would be Market forces already operate and inappropriate measures will not be encouraged. taken to restrict such activity.
R41 Option b is realistic and the only sensible option. Noted. R43 Option a) appears to be sensible - Proposals will only be permitted if they result in significant benefits to the local community or the environment and The wording cited by the representor appears to reflect Option b are proportionate to the output at the relevant site. It may not always be rather than a. possible to provide significant community or environmental benefits when seeking additional reserves at smaller sites and therefore to ensure local It will be important for the Core Strategy to define what is meant by supplies can be maintained, proposals for additional reserves at smaller benefits to the local community and environment. Once this is clear it sites should be favourably considered if identified environmental impacts should clarify what is deliverable. can be satisfactorily mitigated or avoided. An understanding of what is acceptable in terms of the increase in the landbank is also necessary. An increase comparable to the annual crushed rock sales within Somerset averaged over the last 5 or 10 years would seem reasonable, however any figure should be used as a guide only and not a ceiling as there may be material considerations which dictate otherwise.
Page 50 of 193 R44 Option a) appears to be sensible - Proposals will only be permitted if they result in significant benefits to the local community or the environment and are proportionate to the output at the relevant site. It may not always be The wording cited by the representor appears to reflect Option b possible to provide significant community or environmental benefits when rather than a. seeking additional reserves at smaller sites and therefore to ensure local supplies can be maintained, proposals for additional reserves at smaller It will be important for the Core Strategy to define what is meant by sites should be favourably considered if identified environmental impacts benefits to the local community and environment. Once this is clear it can be satisfactorily mitigated or avoided. An understanding of what is should clarify what is deliverable. acceptable in terms of the increase in the landbank is also necessary. An increase comparable to the annual crushed rock sales within Somerset averaged over the last 5 or 10 years would seem reasonable, however any figure should be used as a guide only and not a ceiling as there may be material considerations which dictate otherwise.
R74 Common sense needs to be applied and each case viewed on merit. For Cases will indeed be considered on their individual merits. Policy example a blanket percentage yeilds very different results if based on the included in the Core Strategy will provide flexibility to allow for this, size of a site. thereby not unfairly constraining/disadvantaging any sites.
R81 Define benefits, especially to the environment. The need to define benefits is noted R82 Why allow excessive landbanks when it is not needed? Noted. The size of Somerset’s landbank will be considered in the context of the current size of Somerset’s landbank, the plan period length, current and emerging national policy, the range of local opinion on this issue and the approach taken in adopted local minerals planning policy.
R85 It is appropriate to keep smaller sites operational for business felxibility and Noted. spreading the impacts over more communities.
R94 There is a need to have suitable supplies of aggregate in for instance the While having aggregate supplies in other areas of the County would Keinton Mandeville area for sustainability reasons. There is a danger that be beneficial in sustainability terms, to our current knowledge, this is the concentration of supply in the north of the County would result in extra not practical due to geological resource constraints. The majority of travel to certail locations thus increasing CO2 emissions. aggregate resources are located in the Mendip Hills and there is a well established level of operation there. It would be impractical and potentially unsustainable to move and/or create supplies in other locations in the County – especially at a time when Somerset has a sufficient landbank.
Page 51 of 193 R106 This Issue should only relate to non-strategic sites as strategic sites are Strategic and non-strategic sites are not necessarily considered addressed in Issue A2. The policy should be clear on this point. Option a separately. It is important to consider the wider role of strategic sites is preferred, however care must be exercised when determining what through the Strategy. As long as policy exists to enable efficient, "significant" benefits to the local community/environment are. It may not competitive quarries to continue, be they strategic or predominantly always be possible to provide for significant benefits when seeking local suppliers, there is no need to consider smaller sites in isolation. additional reserves at smaller sites and it should therefore be possible to secure more reserves if impacts are satisfactorily mitigated or avoided. An It will be important for the Core Strategy to define what is meant by understanding of what is acceptable in terms of the increase in landbank is benefits to the local community and environment. Once this is clear it also necessary. An increase comparable to the annual crushed rock sales should clarify what is deliverable. averaged over the last 5 or 10 years would seem to be reasonable, however any figure should be used as a guide only and not a ceiling as Option b is not considered to disadvantage smaller sites. It provides a there may be material considerations which dictate otherwise. Maintaining mechanism for all sites existing in Somerset to access sufficient local supply (page 8) The special treatment for the three strategic sites is reserves to operate their business. potentially prejudicial to the smaller sites that do supply the local market unless there is the ability in policy terms for smaller sites to seek additional A flexible landbank will be defined in the Core Strategy but will reserves. Paragraph 5.20 - Option b disadvantages smaller sites. This is potentially cover fair treatment and accessibility to reserves for all unnecessary as strategic sites already have a favourable position under operators. Issue A2. It is not clear how Option b would result in a smaller but "more flexible landbank". What is a "more flexible landbank"? R108 Option a will provide for continued supply from smaller sites and help Noted. maintain diversity of supply and competition.
R115 Provision for additions should be maintained, and either Option a or b Noted. seem appropriate.
R116 Extraction should be within longterm employment objectives Noted. R119 Option b seems the most appropriate approach as output should be Noted. proportionate to the scale of the reserve. A low yield of minerals extraction in a small scale quarry maybe sustainable but highly inappropriate in a large quarry such as the railhead quarries cited in the text (paragraph 5.17 summary document) that have a combined average yield in excess of all other quarries combined.
Page 52 of 193 R120 I am not sufficiently expert to give an alternative. The issue is very Issue A2 and A3 both apply to all aggregate sites in Somerset. They complex. I am concerned that b just appears to preserve the status quo were included to ensure comments could be collected on how to and misses the point of planning. However, I would not support a if it was develop policy for all sites. The Core Strategy will provide a robust, seriously and unneccessarily detrimental to the larger quarries, which are flexible approach in its policies so that all sites are provided with fair important not just locally, but nationally. I believe there needs to be a and balanced opportunities, and that local, regional and national planned solution which allows larger and smaller quarries to survive - as supplies can be maintained with any adverse effects on the long as they are needed and with recognition of the wider impact - broadly environment and local communities minimised and, where needed, as described by the objectives. mitigated appropriately.
R122 There should be no increase in limit if a 25 year landbank exists at current Noted. However each case has to be considered on its own merits output rate. against adopted policy, taking into account all circumstances e.g. peaks in demand, potential future major projects and operational circumstances. R125 Para 5.15 is strongly supported although the definition of “small additions” Comments on para 5.15 are noted. is crucial if the paragraph’s objectives are to be met. If the additions are too small then is may not be financially viable to invest to maintain/improve It will be important for the Core Strategy to define what is meant by environmental standards. benefits to the local community and environment. Once this is clear it should clarify what is deliverable. Option a is preferred with two caveats. Firstly proposals should be considered if impacts are mitigated as well as if environmental/local The Core Strategy will define/clarify all key statements so that they community benefits result. Secondly how is “do not significantly increase can be clearly interpreted. “Do not significantly increase the size of the size of the landbank” defined? An average of annual rock sales in landbank” will be considered to constitute an average of annual rock Somerset over a long period, say 5 years may be appropriate. However sales potentially in Somerset or for that site in question over a this should not be an absolute limit. Other important factors may need to relevant time period, which accounts for peaks and troughs in supply be considered such as sufficient additional reserves to allow financial such as 10 years. This will be flexible taking into account factors investment in different access arrangements or plant modifications for such as investment and site modifications/working. example. R125 Councillors are split between answers A & C. Noted.
Page 53 of 193 Question 7: Are there other sites that are unlikely to be worked again, or sites listed which should be considered as viable for future working?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R13 SWT does not want to comment on specific sites, but asks that the Along with all other planning considerations, the ecological context of ecological context of sites is properly assessed and weighted in the sites will need to be assessed. Minerals planning policy will seek to consideration of viability for future working. Ecological, ecosystem, and protect and enhance, where possible, the biodiversity and ecological wider environmental issues need to be considered in the decision making networks in the vicinity of minerals workings. process: impacts to biodiversity, the ecological network, and the water aquifer are just some of the things that can be affected positively and negatively by quarry dormancy or re-workings. Opportunities to maximise ecological and community benefits at dormant sites should be pursued. R15.1 We are not aware of any other sites in this category. We support the Noted. proposal for minerals operators to contribute to a fund to restore abandoned and dormant sites to achieve favourable environmental outcomes. R25 Chelmscombe is the only dormant site listed in the Mendip Hills AONB and Noted. the AONB Unit would wish it to remain dormant and be restored to enhance landscape, biodiversity and recreation.
R35 The old Quarry site in Binegar Parish should be classed as unlikely to be There are extant planning conditions to which the operator must worked again. adhere before operation could recommend at this site. The site is not classed as dormant. R36.2 5.52: According to the existing Local Minerals Plan (1997-2011) Both sites are dormant. They are considered active under the Cookswood is still active. 5.53: Westdown still has an active permission Environment Act 1995 but until a new scheme of modern working according to the existing Local Minerals Plan (1997-2011). conditions is provided they are unworkable. Currently a planning application for holiday chalets is being considered by Mendip District Council for Cookswood and therefore the revocation of the minerals permissions is being considered by the district planning authority. R43 It is known that a number of the dormant sites listed in the table at 5.52 of Noted / this is understood. the Minerals Option Paper are in private ownership.
Page 54 of 193 R44 It is known that a number of the dormant sites listed in the table at 5.52 of Noted / this is understood. the Minerals Option Paper are in private ownership. For those dormant sites in corporate ownership it is suggested that individual MQP members would be better placed to respond.
R75 Union Quarry. Quarry in Bridge Street (shooting range) Noted. R80 There are a number of old quarries in the Oakhill - Stoke St Michael - The quarries mentioned are abandoned sites with no form of planning Leigh upon Mendip belt in eastern Mendip. It seems unlikely that any of permission. It would be unlikely for them to re-open. these could re-open because it would be difficult to find an area large enough for economical exploitation. Waterlip quarry probably falls into the same category.
R81 Yes - some city centres could be mined. No quarrying is expected to take place in, or be identified to take place in town or city centres in Somerset during the plan period of the Core Strategy R82 No. Other use, benefit and relandscaping should be completed on unused Noted. Beneficial after uses for sites will be encouraged in the Core and dorment sites. Why leave great tracts of countryside abandoned and Strategy. dormant? Planning permissions should be considered when need for more quarries are identified.
R86 Dont know. Not in this area Noted. R91 Downhead = Tad Hill Quarry - Limestone. Stoke St Michael = Bector Lane Noted. Quarry - Limestone. Doulting = Farrington Lane - Sandstone.
R93 Shipham gorge quarries on east side of road should be unlikely to work Noted. again
R115 Questions 7 and 8 require further research and analysis. The evidence base supporting the Core Strategy will be further strengthened as the Core Strategy is prepared. R116 None Noted. R117 no Noted. R119 N/A No comment. R120 Don't know No comment. R122 BarnsClose (Leigh on Mendip), Waterlip. Noted.
Page 55 of 193 R123 No to both. – Downhead 2 Where feasible the Core Strategy will encourage dormant/abandoned All abandoned sites – revert to wildlife sites or SSSI. sites to be restored to a range of appropriate after uses. R124 No. All should be reverted to nature/wildlife sites. A giving back in Where feasible the Core Strategy will encourage dormant/abandoned exchange for taking. sites to be restored to a range of appropriate after uses.
Question 8: Which former quarry sites (dormant or abandoned) are particularly problematic and why?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 Chelmscombe quarry as its access is poor whatever use it is put to. Noted. R12 A number of dormant quarry sites support breeding peregrines. This is an Noted. Annex 1 species under the EU Birds Directive and is therefore afforded special protection. It is critical that the presence of breeding peregrines is taken into account when the MPA is considering whether to reopen an abandoned or dormant quarry. The MPA needs to ensure it has access to current information on the distribution of breeding peregrines within the Somerset quarry network when considering any new application.
Page 56 of 193 R13 SWT does not wish to comment on specific sites but will make the Comments noted. following point for consideration. Where dormant sites are left long enough without any restoration the situation can arise where ecological succession gives rise to a mosaic of habitats and associated species which may differ Depending on the date for the granting of permission some dormant markedly from the sometimes quite specific restoration conditions attached sites may be excluded from restoration conditions due to regulations to the planning permission. Depending on the habitats established it may that existed at that time. no longer be desirable to follow the original restoration conditions, and the process of altering these needs to be undertaken. This highlights the importance of ensuring restoration conditions are not limited to just the site The Core Strategy will promote restoration and benefits that extend boundary, but instead take into account the context of environmental beyond the site boundaries for both the environment and community. impacts of quarrying and make restitution in the local landscape. Long periods of time can elapse between commencement of quarrying activities, a period of dormancy, and eventual restoration. This gives an ecologically Current national and local minerals policy encourage site restoration significant lag time between habitat loss and habitat recreation, with during the working life of quarries, something which operators are concomitant issues for the local ecological network. Given that powers for pro-active in. closure and restoration of dormant quarries lie largely with the producers, and successful resolution involves time-costly negotiation on the part of The enhancement of the local outlying ecological network is already SCC, it seems a perfectly reasonable request that ecological restitution is taking place in schemes aggregate operators are involved in, such as delivered throughout the life of the quarrying in the local landscape as a Living Landscapes. Policy surrounding this will be considered in the means of compensating some of the operational environmental impacts Core Strategy. arising. SWT would like to see a policy mechanism for creating restoration strategies which ensure enhancement of the local outlying ecological network is delivered over the life of the quarry, as well as within the site bounds at the end of the process. R15.1 We believe Stoke Lane and Chelmscombe have the potential to affect Noted. seriously the nature conservation interest of adjacent sites. Cookswood and West Quantoxhead could present similar problems.
R18.2 Not known Noted. R25 The former Broadmead Quarry, near Westbury sub Mendip, in the AONB Broadmead Quarry aka Westbury Quarry is not included in the list in is not listed. Tthere would be significant issues of concern to the AONB the Options Paper as the Quarry has ceased operating and is used Unit in terms of landscape impacts if quarrying were proposed again in this for an alternative use. location.
R35 None Noted. R43 It is considered that this is a subjective matter. Noted.
Page 57 of 193 R44 It is suggested that individual MQP members would be better placed to Noted. respond on this issue.
R74 unknown Noted. R75 West Quantoxhead in SSSI, access, affect on AONB. Union Quarry - Noted. planning permission to build house, access. Bridge Street - access, effect on neighbours
R80 No comment. Noted. R81 this could be a structural geology question. For example, some rock has Noted. properties that meet roading (greater sand content) than other rock (greater mud content). There's jointing, fracture, faults and the nature of the ground below the quarry - drainage and ground water contamination
R82 Cookswood, Stoke St Michael. Abandoned without any landscape or Currently a planning application for holiday chalets is being enviromental reinstatement. No top soil and so nothing grows - unsightly considered by Mendip District Council for Cookswood and therefore and prevents wildlife returning. Ponds and lakes of polluted and stagnate the revocation of the minerals permission is being considered by the water killing wild life and people. Other use even when planning district planning authority. permission is granted can not be implemented as quarry rights prevent change of use. If the minerals permission and rights are given up or revoked then alternative permanent use can be granted. R85 Unknown. No comment R86 Dont know. No comment R91 Stoke St Michael - Bector Lane has become a venue for youngsters from Noted. miles away on hot summer days - diving, swimming, drinking.
R106 Question 8 refers to "problematic" sites but there is nothing in the Understood. Definitions will be made clearer in the Core Strategy. supporting text that defines what "problematic" is. If problematic refers to Problematic in this sense refers to problems created by the site for impacts that would occur if the site was to be reopened then keeping them local communities, the environment etc due to a former quarries dormant actually addresses this. These sites can't reopen anyway until current state. they have new planning conditions in place which, in theory, would control any operational impacts.
R115 Questions 7 and 8 require further research and analysis. The outcomes from the Options Paper consultation and further work on the evidence base will support future policy development.
Page 58 of 193 R116 All not siutable Noted. R117 none No comment R119 N/A No comment R120 Cookswood and Stoke Lane present a problem. Their future is uncertain Currently a planning application for holiday chalets is being and there is much concern that they will be developed for commercial or considered by Mendip District Council for Cookswood and therefore personal gain without regard to the needs of the local area - or, indeed, the revocation of the minerals permission is being considered by the the wider community. In my view, they should be used for sustainable, district planning authority. environmentally sound purposes. Any proposal should be accepted only if it is generally agreed that it satisfies these considerations - again, broadly, The Core Strategy will seek to promote a range of beneficial the Plan objectives. restoration and after-uses that are sound in environmental, planning and sustainability terms. R121 There is uncertainly regarding the future of Cookswood quarry. Currently a planning application for holiday chalets is being considered by Mendip District Council for Cookswood and therefore the revocation of the minerals permission is being considered by the district planning authority. R122 Cookswood (popular with summer recreation have been fatal accidents - Noted. Currently a planning application for holiday chalets is being dificult to prevent trespass) Delays with current redevelopment planning. considered by Mendip District Council for Cookswood and therefore the revocation of the minerals permission is being considered by the district planning authority. R123 None in Downhead exception of Asham Wood. SSSI – 4x4 activity and Noted. over past 20years motorcycles. Over use by shooting syndicate. Not policed effectively. R124 Those not policed by either wardens, security, police on a regular basis. Noted.
Possible fencing and notices – policed. R125 Generally the only problem with the dormant sites is the perception that This approach will be considered in the Core Strategy, which is they may re-open. The probability of any of these sites re-opening is similar to what is included in the adopted Minerals Local Plan. small. Perhaps it would be helpful to try to address the perception problems by clearly and explicitly stating that they are very unlikely to re- open and why this is the case i.e. the problems the sites would encounter meeting modern planning conditions.
Page 59 of 193 R127 Water filled quarry sites (safety reasons). Noted.
Question 9: For the sites that you are familiar with, what outcome would you like to see for each? E.g. Remove the risk of reopening, or restore for amenity or wildlife, or development such as housing?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 Chelmscombe quarry - restore for wildlife Noted. R12 Sites which support breeding peregrine should not be reopened unless it Noted. Any fund that is supported will target nature conservation and can be clearly demonstrated that this would not lead to loss of breeding other relevant community benefits. Current work by Oxfordshire birds. We strongly support use of the planning mechanism identified at County Council will be looked into. para 5.54 whereby mineral operators contribute to a site restoration fund. This should include the use of funds to target nature conservation restoration in key locations. We understand that Oxfordshire County Council are trialling such an approach in their MCS.
R13 Our vision for the Mendip Hills Living Landscape is to create a connected The current situation regarding nature, connection and the landscape where wildlife flourishes and rural communities enjoy a healthy, recommendations from ‘Making Space for Nature’, the Government’s productive natural environment. We are working with our members, the Natural Environment White Paper and the draft NPPF are public, and partners to explore innovative ways of achieving a sustainable, understood. Along with programmes such as Nature After Minerals nature-rich environment. The specific aims and targets of the initiative build these targets and aims will help shape the policies included in the upon the recommendations made by Professor Lawton in the cross-party Core Strategy. Policy to support biodiversity and conservation on all supported review 'Making Space for Nature' which defined a bare minimum scales will be encouraged and supported. Whether or not these of action needed to secure the resilience and function of the natural world. ecological benefits will be able to be measurable will have to be There is growing recognition within Government that strategic action for investigated and considered. nature is necessary now to prevent further weakening of important ecosystems, and to avoid the environmental, social and, crucially, economic problems associated with this. Restoration of quarry sites for nature is a critical element in delivering more, bigger, better and joined up sites for nature and people. "More, bigger, better, joined up" as an approach to environmental conservation and restoration was championed by Lawton in 'Making Space for Nature' has been adopted into policy via
Page 60 of 193 the Government's Natural Environment White Paper and in the draft NPPF, indicating that this is very much a desirable course for shared action. This is the principal on which Somerset's EcoNet is founded, albeit using the terminology favoured in the draft NPPF, rather than Lawton's phrase. As national and local policy is placing an expectation for local authorities and developers to move forward on ecological networks, we would expect to see this carried through across all quarry sites. We believe a comprehensive, strategic approach to planning future restoration of all quarries should be taken in association with those organisation and communities already actively engaged in landscape-scale conservation, to achieve bigger and better outcomes for biodiversity across the Mendips. All quarry sites should be expected to deliver measurable ecological benefits throughout the life of their operational activities in the surrounding area, seeking to create and connect new habitat patches, as well as delivering final site restoration. This would have the effect of lessening the long-term impact of biodiversity loss and interruption of the local ecological network, and could make a significant contribution to the national targets for achieving priority habitat restoration contained in the England Biodiversity Strategy 2020. R15.1 We would like to see Stoke Lane, Chelmscombe and West Quantoxhead Noted. restored to benefit biodiversity and allow appropriate amenity uses.
R18.2 Not known. What this series of questions illustrate is that there is There is substantial information from a variety of groups and projects insufficient landscape and countryside advice being given to the minerals such as Nature After Minerals and Living Landscapes that is planning function. SCC no longer has Landscape staff who are sufficiently accessible to minerals planning. The County Council is building a informed and involved in these issues to be able to give appropriate broad and detailed evidence base to support its policy development, advice. which benefits from liaison with other teams and officers within the County Council who have specific expertise in a range of matters including countryside management. The County Council is also keen to benefit from working with and hearing from other stakeholders through consultation and continuous engagement. R25 For sites, such as Chelmscombe, within the AONB the general Noted. Quarries, both active and dormant in the Mendip Hills AONB presumption should be for securing environmental enhancements to the will be treated in accordance with national planning policy. For landscape, biodiversity and recreation provision. Unless there is an example, a presumption against major minerals developments in overriding national need in the future, the dormant sites in the AONB AONBs is supported in Minerals Policy Statement 1. Also, Draft should be closed permanently. National Planning Policy Framework states that local planning authorities should as far as practical, ensure sufficient levels of
Page 61 of 193 permitted reserves are available outside AONBs.
R35 As stated in the example, 'Removes the risk of reopening and keeps as a Noted. community and wildlife amenity.
R36.2 5.56: We do not agree that industrial development is suitable. Noted. R43 No comment. No comment R44 It is suggested that individual MQP members would be better placed to Noted. respond on this issue.
R71 I would like to see a fund established to promote the restoration of Noted. This will be considered as a potential way forward in the Core abandoned sites for wildlife and recreation. Strategy.
R74 In general restoration for amenity or wildlife is usually preferred. Noted. R75 Remove risk of re-opening Noted. R80 For sites mentioned in the answer to Question 7, the risk of re-opening Noted. should be removed, if it exists.
R81 quarries can make good gardens Taking note from national planning policy and guidance this is not an after use that is felt most appropriate for a quarry due to the size, location and nature of them. Nonetheless, it may be possible and appropriate to pursue a wider landscape role. R82 Remove the risk of reopening and restore for amenity and wildlife. Any The Core Strategy will seek to promote a range of beneficial other development given due consideration. restoration and after-uses that are sound in environmental, planning and sustainability terms. R85 Unknown. No comment R86 N/A No comment R91 If there is no good stone left, I would like to see old quarry sites made into Noted. amenity, possibly providing work for local people.
Page 62 of 193 R92 Give priority to wildlife, it is so greatly under threat. Ultimately, the whole of Wildlife will be considered and supported with all other possible and England will be covered with houses and probably called "London". Hold relevant after uses. Quarries can successfully support biodiversity back this tide! and help achieve UK Biodiversity Action Plan targets; this will be supported in the Core Strategy. R93 Shipham gorge quarries on east side of road: Remove the risk of Noted. reopening, & restore for amenity &/or wildlife Site of former structural test centre, Cheddar: Remove the risk of reopening, & restore for amenity &/or wildlife
R106 If owners are reluctant to see planning permissions relinquished because While this is preferred, ideally before alternative uses can be of potential future financial implications then the sites should be considered permitted the minerals permission and rights need to be given up and for some alternative use or development that would allow for income or revoked which can be costly and time consuming. The Core generation. Strategy will seek to provide mechanisms/policy to address this.
R115 My personal preference would be for restoration for amenity of wildlife Noted. benefits and also geological benefits. Many former quarry sites in Somerset are completely inaccessible for education, study or research purposes. Where possible some geological faces or exposures should be maintained - such features can be beneficial for wildlife as well as educational purposes.
R116 REstore for amenity The Core Strategy will seek to promote a range of beneficial restoration and after-uses that are sound in environmental, planning and sustainability terms. R120 Acceptable uses might include nature reserve, study facilities, visitor The Core Strategy will seek to promote a range of beneficial centre. Possibly combined with a landscaped garden - there are restoration and after-uses that are sound in environmental, planning precedents for this. Recreational facilities resulting in very large numbers and sustainability terms. of visitors possibly with arrivals and departures concentrated at one time are unlikely to be suitable. A very complete assessment of the implications for water, drainage, traffic and so on should be completed and made publicly available so that there is transparency around both the assessment of the application and the rationale for any planning permission given. R122 Tadhill - Open a permissive footpath to see wildlife. Need to overcome the Noted. responsibility on the owner for safety if warnings and path guidance are provided.
Page 63 of 193 R123 Restore and managed as wildlife sites. The Core Strategy will seek to promote a range of beneficial By all quarry owners as a joint venture. restoration and after-uses that are sound in environmental, planning and sustainability terms – that, where feasible, is contributed to by all operators.
Given the Council's budget constraints it is not considered that buying sites would be a viable proposition. R124 Restore to wildlife sites – warden for all, paid for by all quarry owners as a The Core Strategy will seek to promote a range of beneficial joint venture. restoration and after-uses that are sound in environmental, planning and sustainability terms.
Given the Council's budget constraints it is not considered that buying sites would be a viable proposition. However, the Council will work with developers and other partners as appropriate.
R127 Remove the risk of re-opening. Restore for wildlife. Opening to the public Noted. would involve great cost to make safe.
Page 64 of 193
Issue A4: How should we manage the shortfall in sand and gravel reserves?
Option a: Retain the Areas of Search and Preferred Areas around Whiteball to help meet the apportionment in conjunction with Devon.
Option b: Review potential Areas of Search or Preferred Areas through a call for sites from the minerals industry.
Option c : Criteria based policy approach for new sand and gravel reserves.
Question 10: Which of the options do you support for Issue A4?
Summary of responses to question 10.
18% (5 responses) 29% (8 responses)
Option a Option b
Option c Other
35% (10 responses) 18% (5 responses)
Page 65 of 193
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R12 Seeks to retain sand and gravel development within a single strategic Noted. area, providing there is no significant ecological interest which cannot be voided within the Area of Search or Preferred Area. This is in keeping with the concept of a strategic restoration plan to promote landscape scale nature conservation.
R13 In combination options B and C have the potential to realise benefits for If minerals planning applications are likely to give rise to significant the natural environment. Reviewing areas of search has the positive environmental effects and/or meet criteria/thresholds in the UK EIA aspect of requiring a sustainability appraisal which will flag up broad Regulations; then the proposed site would be subject to an environmental issues - mainly in terms of impacts to be avoided rather Environmental Impact Assessment to demonstrate the baseline than potential opportunities though. However, because the state of the environment and any potentially significant environmental effects that environment is not static, during the life of the plan it may occur that sites may occur from the proposed development, and how they will be within the preferred areas become more ecologically sensitive or mitigated. important, and from this point of view are less desirable for extraction; in this circumstance a criteria based policy offers the chance to "trade-off" A flexible approach will need to be taken and this could entail a this site for a new, less impacting site outside the preferred area. Is it combination of options (potentially options a and c). This is because possible to see both policy options go forward together? It seems the best in combination with Devon County Council’s identified areas the way of ensuring compliance with national biodiversity policy, statutory areas of search and preferred areas around Whiteball will provide biodiversity responsibilities, and of achieving delivery of local targets for sand and gravel resource to contribute to the shared apportionment. the health and status of the natural environment. Also taking forward a criteria-based policy will allow the option for sites outside of designated areas to be considered, where relevant.
R15.1 On balance, we support Option A as there is significant resource in the Noted. The Whiteball site which contains the areas of search and area. The downside is that transport to remote locations in the County preferred areas is located close to the M5 motorway, which is clearly could be an issue. an important part of the Strategic Road Network (SRN). The impacts of minerals transport on the SRN and local roads will need to be addressed in the Core Strategy. R18.2 There should be a long term strategy for mitigation and restoration of sand The Core Strategy should embed this long-term approach, working in and gravel workings before any new areas are identified. parallel with Devon County Council’s minerals planning documents.
Page 66 of 193 R25 This is not really an issue within the Mendip Hills AONB. However, there Any landscape issues would be considered through policy included in may be sites that are visible from the Mendip Hills, and the impact on the Core Strategy. these views could be included within a criteria based policy.
R35 N/A to Binegar parish. No comment. R40 While Devon County Council's emerging Minerals Plan will identify further A flexible approach will need to be taken and this could entail a sand and gravel resources to supply Devon and adjoining counties, it is combination of options (potentially options a and c). This is because anticipated that reserves at Hanson's Whiteball operation (including the in combination with Devon County Council’s identified areas the Town Farm site in Devon) will run out in around ten years. Our Minerals areas of search and preferred areas around Whiteball will provide Plan is likely to make an assumption that subsequent supply to the sand and gravel resource to contribute to the shared apportionment. Whiteball plant will be delivered from resources within Somerset. The Also taking forward a criteria-based policy will allow the option for retention of the Preferred Area and Area of Search identified in Somerset's sites outside of designated areas to be considered, where relevant. Minerals Local Plan is therefore supported (Issue A4) as a means of maintaining supply for the Whiteball processing plant. Reliance solely on a criteria-based policy for sand and gravel supply, however, is not supported, but it would be prudent for Somerset County Council to undertake a call for sites to establish the availability of other sources. Paragraph 5.57 states that the existing plant at Whiteball is located in Devon, which is incorrect as the plant lies on the Somerset side of the county boundary.
R43 It is suggested that any shortfall could be managed by retaining the Areas Noted. of Search and Preferred Areas around Whiteball to help meet the appointment in conjunction with Devon would be a sensible option.
R74 Part of the demand can be managed by better use of recycled materials Noted. R80 No comment. No comment
Page 67 of 193
R81 Sand and gravel is a diminishing resource hence increasing from offshore. Prior to any extraction or granting of planning permission, sites Chances are the demand will increase, for example beach nourishment undergo a range of assessments, including geological assessments and continued re-nourishment. Work is being done on other material - for and if likely to give rise to significant environmental effects and/or example re-cycled glass, green glass mountain! One concern is the lack of meet criteria/thresholds in the UK EIA Regulations; then the in site investigations - axiom - is the past the key to the future, evidence for proposed site would be subject to an Environmental Impact past sea levels. If the evidence is destroyed, taken away in trucks - then ... Assessment to ensure that any potentially significant effects are addressed and mitigated appropriately.
R82 This question is not clear. Where is Whiteball? What is the shortfall? When Whiteball is a quarry that straddles the Somerset and Devon borders, is the shortfall? How can there be a shortfall at a time of non economic close to the M5 motorway. There is a shortfall identified for the next growth? The need and proof needs to be clearly identfied. plan periods for Somerset and Devon: according to expected annual tonnages and current reserves there is not enough to provide for expected demand. R85 I have no knowledge of these elements so would support research and Noted. investigations.
R93 Re-use of waste materials should be encouraged in preference to new Noted. primary sources.
R102 We consider it reasonable to bring forward those areas still without A flexible approach will need to be taken in the Core Strategy to permission from within the Somerset Local Plan into the Somerset Core ensure that the joint sand and gravel apportionment is met and to Strategy. However a review should be undertaken to consider why these allow proposals to be considered outside of designated areas, where sites have not been brought forward and if they remain deliverable options. relevant. In light of the current situation in Devon and responses to A review of sand and gravel sites in Somerset should be carried out, the Minerals Options consultation it is not felt that a call for sites is including a call for sites, to identify whether additional sites could assist in currently required. meeting Somerset's contribution to the apportionment.
R106 Option b gives the minerals industry an opportunity to suggest new sites. Noted. R108 All of the options have a role to play and so should all be used in A flexible approach will be needed in the Core Strategy to ensure that developing policy. A call for additional sites (b) could be used to the joint sand and gravel apportionment is met and to allow proposals supplement the existing Areas of Search and Preferred Areas (a) while a to be considered outside of designated areas, where relevant. criteria based policy would provide for flexibility should additional sites emerge through the plan period.
Page 68 of 193 R115 Option a is my personal preference. Devon has much more significantly Noted. 'sand geology' and larger sand reserves than Somerset, and the current situation of apportionment with Devon and Cornwall (and utilisation of the Whiteball sites) seems sensible.
R116 Minimise enviromental impact Environmental impacts will be managed and minimised in accordance with policies included in the Core Strategy. Similar to the adopted Minerals Local Plan. R117 Significant reserves allow this option Noted.
Page 69 of 193
Issue A5: Restoration and after-use in the East Mendips
Option a : Restoration and after-use of quarry sites should be determined on a site by site basis.
Option b : Restoration should be determined by meeting criteria defined in an agreed long term strategic landscape scale restoration strategy for the East Mendips.
Question 11: Which option do you support for Issue A5?
Summary of responses to question 11.
11% (4 responses) Option a
Option b Other
47%
(17 responses)
42% (15 responses)
Page 70 of 193
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R8.1 A is the only option that provides for a coordinated plan of restoration and Noted. after-use, that takes account of issues such as water resources and the landscape approach to nature conservation.
R12 This should apply not only to quarry sites in the East Mendips, but also to Restoration will be addressed for all minerals in the Core Strategy. both sand and gravel and peat sites.
R13 Unequivocally Option B. There is already a great deal of ecological This clear viewpoint is noted. restoration and enhancement work underway in the Mendips courtesy of local nature and landscape conservation groups. As stated previously, the Stakeholders will be met with and consulted at the pre-submission Mendip Hills Living Landscape initiative, led by Somerset Wildlife Trust, consultation stage to establish the most appropriate restoration aims to restore, recreate and reconnect wildlife habitat across the area, so programme. that people can work, live and play in a vibrant local environment. A programme of ecological survey, landowner liaison, community While the potential benefits to biodiversity from restoration are clear, engagement and direct land management is enabling Mendip Hills Living prioritisation for biodiversity-focused site restoration may be Landscape to achieve ambitious targets for priority and protected species unreasonable as minerals planning policy (Minerals Planning Policy and habitat conservation. Via a range of projects and with a number of 1, Minerals Planning Guidance 7) allows a broad range of potential partners, the initiative is engaging and enthusing local communities about after uses to be supported. Furthermore some sites in Somerset may new opportunities for nature on their doorstep, encouraging them to get find it more difficult to establish effective ecological networks than involved, to explore the natural world, and to play a part in its future. In others, thereby an appropriate balance will be pursued. order to create substantive benefits for biodiversity, minerals producers should be required to work collaboratively with organisations such as SWT The Core Strategy should seek to encourage restoration and to an agreed programme of strategic landscape-scale habitat restoration, improvements beyond site boundaries for all sites – adopting an creation and enhancement. By working with others to an established holistic approach to ensure that the full value of the environment is scheme of priority actions, restoration of sites will contribute to the considered in any decision making. attainment of a functioning ecological network, and may achieve side benefits such as community engagement. Take a case by case approach, as posited by Option A, runs the risk of rendering restored sites as isolated islands of habitat in the landscape, unconnected, with reduced ecological function and making less contribution to the local biodiversity resource.
Page 71 of 193 R15.1 We support Option B and welcome the proposal for a landscape-scale Noted. approach to achieve biodiversity gains.
R18.2 As with other forms of mineral extraction a long term strategy would enable Noted. a plan for public benefits to be drawn up and funded by conditions on developers. This should be in place before any new areas of deposits are identified as potential permissions.
R25 The AONB Unit supports the proposal for a long term strategic, landscape All existing management plans relevant to areas of mineral working in scale restoration strategy. This should be co-ordinated with the AONB Somerset will be considered and stakeholders will be met with and Management Plan to ensure that the landscape is managed and enhanced consulted at the pre-submission consultation stage to establish the across the whole of the Mendips. most appropriate restoration programme.
R35 Each site is different and and requires individual attention. Was not asked All sites are different and present different opportunities for to specifically comment but Binegar Parish Council is also concerned with restoration; all possibilities and potential impacts (including upon the the conclusions regarding 'Quarry Extensions' in item 5.60. The Parish community) will be considered and addressed in the Core Strategy. Council is concerned about Gurney Slade quarry and feels that community The conclusions in para 5.60 of the Options Paper are supported by impacts also need to be considered before a quarry is extended. minerals planning policy and were the generally consensus from responses to the Aggregate Issues Paper consultation (2010). R36.2 5.70: Is this the Mendip Hills AONB or the Cranbourne Chase AONB. The Para 5.70 of the Options Paper refers to the Mendip Hills AONB, latter should be more relevant. Options b: This would be our preferred however any landscape scale restoration strategy will consider all option with particular stress on Amenity and nature conservation. We note environmental and landscape designations. that there is not a suitable buffer zone around the Asham Wood Special Area of Conservation. R41 A site by site approach to restoration is preferable. Noted. R43 Option a) for smaller quarries and option b) for larger quarries. Option b A long term strategic landscape scale restoration strategy has the proposes that restoration should be determined by meeting criteria defined potential to benefit and be contributed to by both small and larger in an agreed long term strategic landscape scale restoration strategy for quarries. While it is understood that larger quarries have the the East Mendips. This is supported and fits in with 'An Ecosystems potential to link with and benefit a larger surrounding landscape and Approach to Long Term Mineral Planning in the Mendip Hills', the report of ecological network, smaller sites also have the potential to extend which was published in May 2010. benefits beyond site boun daries to the environment and communities. The Core Strategy will seek to develop a flexible and holistic approach to ensure that the full value of the environment is considered in any decision making.
While a strategic landscape scale restoration strategy is supported
Page 72 of 193 and fits in with previous reports, the Core Strategy will consider all worked examples, guidance, initiatives, potential opportunities and criteria to benefit the environment and surrounding communities.
R44 Option a) for smaller quarries and Option b) for larger quarries. Option b A long term strategic landscape scale restoration strategy has the proposes that restoration should be determined by meeting criteria defined potential to benefit and be contributed to by both small and larger in an agreed long term strategic landscape scale restoration strategy for quarries. While it is understood that larger quarries have the the East Mendips. This is for larger quarry sites and fits in with 'An potential to link with and benefit a larger surrounding landscape and Ecosystems Approach to Long Term Mineral Planning in the Mendip Hills', ecological network, smaller sites also have the potential to extend the report of which was published in May 2010. For smaller quarries it may benefits beyond site boundaries to the environment and communities. be more appropriate for restoration and after-use to be determined on a The Core Strategy will seek to develop a flexible and holistic site by sites basis to reflect the contraints and limited opportunities that approach to ensure that the full value of the environment is may exist. considered in any decision making.
While a strategic landscape scale restoration strategy is supported and fits in with previous reports, the Core Strategy will consider all worked examples, guidance, initiatives, potential opportunities and criteria to benefit the environment and surrounding communities. R74 The Mendips are an important landscape that should be The Core Strategy will recognise the importance of the Mendip Hills protected/maintained and include policy to protect and enhance it where relevant.
R75 n/a to Williton Noted. R80 Option a seems to be the more useful. Noted. R81 what's restoration? How can a hole in the ground be restored? Landfill? Restoration is the process of restoring a site to an after-use that fits in Perhaps new use - local water supply? with its surrounding landscape and which potentially benefits the environment, communities and potentially the economy. Quarries have the potential to be restored to many after-uses including biodiversity, conservation, amenity, geodiversity, industrial and other forms of development.
Page 73 of 193 R82 Conditions and money needs to be put aside from quarry sales to Operators are required via planning permission conditions to fund guarentee this will happen - it has not happened in the past. The money their approved restoration schemes The Minerals Options Paper has and benefits need to go directly to local communties most affected by consulted on potential ways to ensure that benefits from minerals quarries and not to SSCC and lost in cost cutting or spent spread county development are locally received. wide. The Aggregates Levy Sustainability Fund used to provide benefits to Somerset’s residents however this Aggregates Levy tax is now retained by Central Government. R91 Site access is always a problem. All potential constraints to restoration and site after-use will be addressed in the Core Strategy. R102 The strategic landscape scale restoration strategy approach is supported. Noted. R103 Option A is favourable as site by site consideration allows flexibility and Noted. A long term strategic landscape scale restoration strategy response to current needs that may not have been foreseen when any has the potential to achieve wider environmental and community overall long-term objective was proposed. benefits as all sites work towards shared objectives. There are benefits and weaknesses in both approaches. R106 It is too late to plan a 50-100 year working and restoration strategy for all Even though quarrying has been established in the Mendips for many quarry areas as sites and ownerships have already been developed. If the years it is not too late to plan a long term strategic landscape scale Mendips was an entirely greenfield area a landscape/restoration led restoration strategy. Such a strategy could be worked towards by development strategy may be more appropriate but it isn't appropriate current operators and help shape any future planning applications here. An Eco-systems is most appropriate for larger sites and larger existing sites may apply for. landowners and those sites not constrained by adjacent physical barriers. The Eco-systems approach was not endorsed by Tarmac. It is more An ecosystems approach is not only relevant to large sites and appropriate to have some imagination in the afteruse of sites rather than landholdings as an ecosystems approach attempts to adopt a holistic try to reinvent the entire basis of mineral development in the Mendips. approach and ensure that the full value of the environment is Question 11 - Option a is supported for smaller quarries or those remote considered in any decision making – including more participatory from the main quarrying area in the East Mendips. Option b is supported techniques and the inclusion of all stakeholders. for larger groups of quarries/quarry complexes. A long term strategic landscape scale restoration strategy has the potential to benefit and be contributed to by both small and larger quarries. While it is understood that larger quarries have the potential to link with and benefit a larger surrounding landscape and ecological network, smaller sites also have the potential to extend benefits beyond site boundaries to the environment and communities. The Core Strategy will seek to develop a flexible and holistic approach to ensure that the full value of the environment is considered in any decision making.
Page 74 of 193 R108 We support Option b in providing for a strategic approach to restoration A long term strategic landscape scale restoration strategy has the which should help deliver larger-scale and multiple benefits in a potential to benefit and be contributed to by both small and larger coordinated way, identifying and prioritising appropriate after-uses for quarries. While it is understood that larger quarries have the different situations and locations. However, this is most relevant for the potential to link with and benefit a larger surrounding landscape and restoration of large-scale workings and concentrations of ecological network, smaller sites also have the potential to extend sites/landholdings. Therefore Option a is also supported to provide benefits beyond site boundaries to the environment and communities. flexibility and should be applicable to smaller sites to reflect particular The Core Strategy will seek to develop a flexible and holistic opportunities and constraints. approach to ensure that the full value of the environment is considered in any decision making. R115 Option b is my personal preference, as this provides a more strategic The Core Strategy will seek to develop a flexible and holistic approach to restoration and helps maximise benefits. However, this will approach to ensure that the full value of the environment is only work if the strategic landscape scale strategy correctly identifies and considered in any decision making. balances all important restoration factors and benefits - including community / amenity use, wildlife and geological benefits, agricultural uses, flood alleviation. An ecological services approach could be helpful here and provide a framework for the strategy and assist prioritisation between possibly conflicting factors and after-use/restoration options.
R116 Each site has its own criteria Noted. R117 obvious Noted. R119 N/A to South Somerset District Council No comment R120 Each site is very different and any proposal needs to be looked at in detail Noted. All proposals are based on their own merits but policy to seek with the locality in mind. Every effort needs to be made to anticipate and a more landscape-scale approach will be considered in the Core mitigate possible detrimental effects. Strategy. All potential effects will be addressed appropriately through the use of policies and supportive text provided. R121 Option a: Restoration and after-use of quarry sites should be determined Noted. on a site by site basis.
R122 Need a correlated approach (whole is greater than the parts) Noted. R123 AONB not interested in E. Mendip – classified as a ‘sacrificial area for the No comment. quarry industry’. R124 AONB not interested in E. Mendip – classified as a sacrificial area to No comment. quarrying. Somerset wildlife trust unable to fund funds.
Page 75 of 193 R125 Option a is more suited to smaller, possibly more isolated operations. While the options may be more suited to specific sites, a landscape Option b is more suited for larger operations that have extensive scale is not only relevant to large sites and landholdings as this landholdings or control over land, outside their quarrying perimeters. approach attempts to adopt a holistic approach and ensure that the full value of the environment is considered in any decision making – including more participatory techniques and the inclusion of all stakeholders. This can be achieved at smaller sites too and is in line with Government guidance (Natural Environment White Paper) and national projects (Nature After Minerals).
Question 12: Which land uses do you think are particularly suitable for quarry after use?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R8.1 The suitability or otherwise of specific after-uses will be dependant on the Noted. location and characteristics of the quarry, particularly in terms of environmental constraints.
R12 We strongly support conservation and public access afteruse of these Noted. sites. Public access for quiet recreation is compatible providing it does not adversely impact a nature conservation objectives. Further, all potential end uses can incorporate some biodiversity enhancements, and we would strongly urge the MPA to seek significant biodiversity enhancements on all sites coming forward for planning consent.
R13 Given the not insubstantial environmental impacts quarrying has over a It is noted that quarrying not only impacts upon the environment but protracted period of time, a particularly suitable after use is restoration for also communities as well. While the potential benefits to biodiversity nature. The Mendip Hills have pockets of Local Wildlife Sites, SSSIs, and from restoration are clear, prioritisation for biodiversity focused site Natura 2000 sites, all of which are critical elements of a functioning restoration may be unreasonable as minerals planning policy ecological network. There are also patches of habitats and populations of (Minerals Planning Policy 1, Minerals Planning Guidance 7) allows a species of conservation priority lying outside these protected sites which broad range of potential after uses to be supported. Furthermore the minerals planning authority has a duty to consider and act upon (s40 some sites in Somerset may find it more difficult to establish effective and s41 of the Natural Environment and Rural Communities Act 2006). ecological networks then others; therefore the Core Strategy will seek Opportunities for creating habitat areas of sufficient size to be useful are to encourage restoration and improvements that consider all potential limited, so there is great potential for quarries to act as new "core areas" or after uses – adopting an holistic approach to ensure that the full value
Page 76 of 193 "stepping stones" within this currently disjointed collection of sites and of the environment is considered in any decision making. patches, given their size. Prioritising this after-use seems prudent, particularly given the new targets for priority habitat creation unveiled in the England Biodiversity Strategy 2020. Understandably, conflicts over the after-use of quarries will arise: however, given the scale and nature of environmental impacts caused by quarrying, a substantial contribution back to the natural environment at the end of their life ought to be prioritised. Prioritising nature after minerals does not necessarily preclude other activities. Creating open access nature reserves of high ecological value has a range of benefits beyond contributing to national biodiversity targets, as it provides opportunities for low-impact leisure and recreation to the local community. The unique and distinctive landscape of the Mendip Hills already has well established "honey pot" destinations; former quarry sites restored back to nature could act as new attractors in the landscape, offering opportunities to visitors and locals alike to experience, encounter and enjoy the natural environment. Encouraging more people to interact with, understand, and get more involved in their natural environment is a key aim of the Government's Natural Environment White Paper: in the short term, this is only going to happen if inspiring, diverse sites are created, maintained and made accessible. R15.1 We would place a strong emphasis on biodiversity and geological Impacts from any potential land uses for quarry after use would be conservation. Recreational use which is compatible with biodiversity could fully evaluated and considered against national policy and policy be considered. Other possibilities are water storage and flood included in the Core Strategy. management, renewable energy generation, carbon capture and storage and light industry. However proposals for renewable energy generation, carbon capture and storage and industrial development need to be evaluated carefully in relation to environmental impacts on site and in relation to associated infrastructure and transport links. R18.2 Nature reserves, especially where new wetlands can be created. Recycling Noted. There is also a link here with waste planning policy. of waste materials, particularly aggregates.
R25 Wherever possible, the AONB Unit would wish to see sites restored so as The Core Strategy will seek to develop a flexible and holistic to provide landscape-scale environmental enhancements. The priorities approach to ensure that the full value of the environment is should be to enhance landscape character and biodiversity. In some considered in any decision making. Consideration will be given to all locations there may be opportunities, subject to the above possible and appropriate after uses. landscape/biodiversity objectives to create new recreational facilities to benefit local communities and visitors to the area.
Page 77 of 193 R35 Housing or renewable energy (solar farms or thermal storage) or creation Noted. of a community recreation facility.
R36.2 Amenity and conservation. Noted. R43 Ecology, recreation, tourism, water storage, industrial uses at railheads Noted. amongst others. There may be opportunities for individual quarry sites to contribute towards the Mendip Hills Living Landscape Initiative which is being proposed by Somerset Wildlife Trust. Aggregate industries is currently in discussions with Somerset Wildlife Trust and Somerset County Council on this issue with regards to Torr Works.
R44 Ecology, recreation, tourism, water storage, industrial uses at railheads Noted. amongst others. There may be opportunities for individual quarry sites to contribute towards the Mendip Hills Living Landscape Initiative which is being proposed by Somerset Wildlife Trust.
R72 Use as tips. In general terms this would not be an appropriate after use as it does not seek to provide benefits to the environment and communities, is not in accordance with national planning policy and would not make the most of the potential offered by a site – or indeed by the waste material as a resource. However, there may be scope for some compatibility with waste uses (in particular of inert waste), which would need to be considered also in light of waste planning policy. R74 Flooded quarries can provide valuable wildlife habitats and public amenity Noted. areas.
R75 n/a to Williton No comment. R80 For small quarries nature reserves or recreational use (e.g. rock climbing) Noted. All options for restoration of all quarries will be considered in are suitable. For large ones such as Merehead or Whatley, it is difficult to the Core Strategy. see what could be done. Restoration would involve enormous quantities of fill. However this question will arise as quarries are eventually abandoned and needs to be studied.
R81 termal heat sinks for energy? Noted. R82 Re landscaping for wildlife, walking, cycling, etc. Local lesiure use. Noted. Renewable energy schemes
Page 78 of 193 R85 I have no direct knowledge of worked out sites in this area, but feel A landscape scale approach may generate more engagement as it instinctively that a site-by-site plan is more likely to achieve the will cover a wider geographical area and therefore a large spread of involvement and interest of local communities rather than a "big" scheme. the affected population, rather than small pockets of communities in the immediate vicinity of a particular quarry. However, the County Council will consider all consultation responses and its wider evidence base in reaching its proposed Strategy. R86 Forestry,Conservation, Leisure Noted. R91 Engineering works, lorry parks, fish farms, storage depots, out of town Noted. shopping area, garden centres, bowling allwys, adventure centre, skating rinks, leisure centres.
R93 Country parks with combined water storage/water recreation facilities, mix Noted. of woodland and grassland with trails for walking, cycling & educational uses, stabilisation of cliff faces to allow climbing and abseiling allocation of some areas as Nature reserves. Provision of car parking, toilets, launch site for water craft, picnic site, possible camp site.
R98.1 leisure/ wildlife havens. Could they not be used as limited sources of water There would be the potential for the sites to be limited sources of or would this create a drain elsewhere? water but in this instance the Environment Agency and local water agencies would have to be consulted. R98.2 After use should look at options for wildlife/nature reserves inc leisure Noted. activities eg walking, non-motorised sailing craft on the lake etc, low - density eco-lodges for holiday lets assuming traffic not hugely increased etc.
R103 With the ever increasing encroachment of noise into the countryside it may Noted. be beneficial to consider worked out quarries, with their original defences to minimise noise breakout, as then providing protected havens of tranquillity when restored to nature. In other respects the existing degree of noise screening makes quarry sites suitable for the enclosure of noisy industrial development.
R106 There are a host of afteruses suitable for quarries such as recreation, Noted. tourism, water storage and built development (warehousing, industrial uses, housing etc).
Page 79 of 193 R115 Restoration and after-use options should be innovative and fully consider Noted. options which provide benefits for other sectors in Somerset, for example opportunities for recreational fishing or sailing in flooded quarry pits and future tourist sites. Such 'passive' activities may have linked benefits eg. wildlife and biodiversity, flood storage, aesthetic landscape scenary.
R116 Supporting biodiversity Noted. R117 green Noted. R120 Depends on the location. Noted. R122 Nature conservation, recreational walks, mountain biking, horse riding. Noted. Activity sports (e.g. rock climbing, abseiling, diving).
R123 Wildlife site/nature reserves. Environmental. Archaeological interest. Noted.
R124 Wildlife sites – nature reserves. Archaeological and historical value need Noted. protecting.
R125 With a bit of imagination the options for afteruse of hard rock quarries are Noted. almost endless.
R127 Councillors agree agreed with 'make safe and return to wildlife'. However, Noted. would add that a nature reserve, forest, sustainable energy park or Centre - Parcs type of affair would be suitable as wildlife is considered with all plans.
Page 80 of 193
Issue A6: Renewable energy
Option a : Renewable energy schemes should be encouraged where in conjunction with minerals operations to support carbon reduction.
Option b : Renewable energy schemes should be considered separately from a mineral application.
Question 13: Which option do you support for Issue A6?
Summary of responses to question 13.
10% (4 responses)
Option a Option b Other 49% (19 responses)
41% (16 responses)
Page 81 of 193 Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R8.1 There are environmental consequences associated with all forms of The Core Strategy will address impacts for developments arising energy generation, including renewables. Accordingly, the overall impact of from minerals developments. The impacts of any energy generation any energy generation proposal will need to be fully assessed. proposal would be assessed against national and local policy.
R9.3 One of our first areas of concern is over the use of renewable energy in Any potential impact on the environment would be addressed by the conjunction with quarrying operations. This is because such schemes can Core Strategy and assessed against national and local policy. be powered by technology that in some instances may have a potentially damaging impact upon the environment such as solar panels or tall extractor chimneys or wind turbines. On this basis for Issue A6 we would advocate Option b where a separate consideration should be given to renewable energy schemes.
R12 Where this is compatible with the nature conservation interests of Noted. It is not appropriate for the Minerals Core Strategy to deliver a surrounding land. In particular, we would not wish to see the erection of spatial strategy for renewable energy development in Somerset; wind turbines close to existing areas of high value for wintering or passage however, the County Council will need to ensure its policy framework waterbirds, or whether a site is situated within a regular waterbird flyway. is suitable for considering the different types of minerals applications submitted. R13 Option A but with only the following understanding in place. Renewable energy schemes should be encouraged, but must be subject to proper If a renewable energy scheme was likely to give rise to significant ecological impact assessment through the planning process. It is important environmental effects and/or meet criteria/thresholds in the UK EIA that due consideration is given to avoiding impacts upon protected and Regulations; then the proposed scheme would be subject to an priority species and habitats that could arise through the siting of Environmental Impact Assessment to demonstrate the baseline renewable schemes. For instance, bats are particularly sensitive to wind environment and any potentially significant environmental effects that turbines, and therefore careful attention needs to be paid to the siting of may occur from the proposed development, and how they will be this technology. Species-specific mitigation further to that required for the mitigated. quarrying operations may be required to ameliorate potential impacts arising from the installation of renewables schemes, and this may have to sit separately from the site's mitigation and restoration scheme. One key benefit of encouraging renewables in conjunction with minerals applications is that it will be easier for in-combination and cumulative impacts - as well as the stand-alone impacts - to be considered. Stand- alone applications for renewables projects frequently fail to deliver the level of ecological data ecologists would like to see, and this is particularly the
Page 82 of 193 case for wind turbines; by combining minerals and renewable energy applications, a better picture of the wider local ecology, and concomitantly the range of potential impacts, will be presented to the mineral planning authority, giving greater confidence in decision making. R15.1 We support elements of both options for the following reasons: Option A: Support for a combined / more flexible approach is noted. we would welcome measures to reduce carbon output from an energy- intensive industry and agree, in principle, that renewable energy generation schemes will be appropriate for some minerals extraction sites, both during operation and post-use. Option B: we believe that planning decisions on renewable energy projects associated with minerals operations should be decoupled from regulation of extraction sites, because the environmental impacts which may be caused by different forms of renewable energy generation will be different from those caused by minerals extraction. (This should not have been presented as an either/or choice.) R18.2 While some worked out mineral operations may be suited to particular The Core Strategy will seek to achieve a flexible approach to after forms of renewable energy generation there is no inherent reason why use, potentially with nature conservation being the favoured option as they should be. A more flexible approach to after use should be adopted, suggested. perhaps with Nature conservation uses being most often favored.
R25 Schemes that involve mineral extraction and renewable energy facilities All landscape designations and landscape and biodiversity issues will should be developed in an integrated way. They also need to fully consider be addressed in the Core Strategy and given consideration in any landscape and biodiversity issues as part of an overall Masterplan for the relevant applications for renewable energy schemes. site. Particular care will be required if sites are within on adjacent to the AONB boundary.
R34 If it is difficult for M.P.A to take carbon footprints into account the M.P.A. The importance of carbon footprint is noted and has already been needs to start working on the problem. identified in Objective F for the Minerals Core Strategy.
R35 Different community impacts. Noted. R43 Renewable energy schemes should be encouraged in conjunction with Noted. mineral operations to support carbon reduction: However these should be considered separately from mineral planning applications and proposals should be dealt with on a site by site basis.
Page 83 of 193 R71 Keep planning for renewable energy and minerals operation separate, All applications are and will be appropriately evaluated ensuring any otherwise poor standards in one could be justified by 'buying' credit in the potential significant environmental impacts are appropriately other. addressed and mitigated.
R74 As an engineer I am acutely aware of the ability for "integrated" systems to Noted. provide the best efficiencies and savings.
R80 No comment. Noted. R82 Again the most benefit needs to go to those most affected - ie cheaper Noted. local electricity from wind turbines or solar farms.
R84 The Coal Authority would support Option b, namely that 'Renewable Any potential policy included in the Core Strategy for renewable energy schemes should be considered separately from a mineral energy would not be used to resist mineral proposals that are application'. Whilst mineral extraction can be an energy intensive use, acceptable in all other cases. Any such policy would most likely allow renewable energy provision raises different planning considerations that for and guide any relevant renewable energy scheme to be should rightly fall to be determined by the relevant District Planning appropriately considered in a proposed application. Authority in line with their relevant LDF policies. The Coal Authority is concerned that the provision of renewable energy to provide energy for All aspects of a proposed renewable energy scheme would be mineral extraction will not be feasible nor desirable in many cases and a considered – including its location and potential sterilisation of policy seeking the provision of renewable energy could potentially be mineral resources. utilised to resist mineral proposals that are perfectly acceptable in all other cases. The Coal Authority is also concerned that some forms of renewable energy, wind turbines in particular can actually lead to the effective sterilisation of mineral resources contrary to national planning policy objectives.
R85 Continue the site by site approach. Noted. R88 Renewable energy schemes should be encouraged however they should Noted. be considered on their own merits, separately from any mineral applications. It would be good for local communities if mineral companies installed renewable energy sources and then any surplus energy could be used by the local community.
R92 Surely carbon reduction is a sine qua non? Noted. The County Council will need to ensure its policy framework is suitable for considering the different types of minerals applications submitted.
Page 84 of 193 R103 The energy consumption of minerals extraction and processing are huge in Any prospective policy will recognise the processes involved with comparison to the potential energy that might be recouped from renewable minerals operations and renewable energy schemes. sources and policy should recognise this fact. In my view the direction of efforts to renewable sources is likely to misdirect efforts that would be Mineral operators already strive to make their quarrying operations better spent in identifying small improvements in methods and technology more energy efficient as this ultimately creates cost savings. associated with blasting, handling, processing and delivery. In my view requirements for energy auditing should be the driver identifying the There are potential benefits to having renewable energy schemes relative gains from any improvement and deciding on whether it is better to during and after the life of a quarry, neither should be prioritised over target a renewable or an improvement project. Renewable energy the other. initiatives become more realistic at the completion of a quarry and for there own merit rather than as a token offset to the vastly greater energy consumption of the active quarry.
R106 It is preferable to encourage conservation and efficiency in energy usage Noted. rather than the development of renewable energy in the Minerals Plan. Question 13 - Option b renewable energy should be treated separately from minerals matters. Some sites will have more potential than others and they should be treated on their merits.
R115 I strongly support Option a, and believe that any forms of renewable Noted. energy generation should be encouraged and supported where it is sensible and practical to do so.
R116 Much not understood Noted. R117 obvious Noted. R119 Both option a & b, renewable energy schemes should be encouraged in Noted. conjunction with minerals applications although this should not preclude separate applications.
R120 I am in favour, generally, on renewable energy, but it is necessary to If a renewable energy scheme was likely to give rise to significant consider local environmental impacts. environmental effects and/or meet criteria/thresholds in the UK EIA Regulations; then the proposed scheme would be subject to an Environmental Impact Assessment to demonstrate the baseline environment and any potentially significant environmental effects that may occur from the proposed development, and how they will be mitigated.
Page 85 of 193 R122 Only where there are real benefits and little or no adverse impact on the If a renewable energy scheme was likely to give rise to significant local community. environmental effects and/or meet criteria/thresholds in the UK EIA Regulations; then the proposed scheme would be subject to an Environmental Impact Assessment to demonstrate the baseline environment and any potentially significant environmental effects that may occur from the proposed development, and how they will be mitigated.
R125 Option B as each site can be so different. Noted.
Question 14: Are there any forms of renewable energy generation that you do not think should be supported?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 We do not wish to see wind turbines Noted. R13 From an ecological point of view, SWT takes the view that renewable All significant impacts from a proposed minerals development would technology should be matched to the site - it is about the right project in need to be considered by the County Council in determining an the right place, as with any development. New renewables schemes application. This basic approach will apply regardless of the type of should be taken on the premise that they avoid impacts to sensitive technology being deployed. ecological features, be that direct habitat loss, termination of connectivity, potential death or injury of wildlife, or impacts to the ecological network. It is not appropriate for the Minerals Core Strategy to deliver a spatial The level of potential impact needs to be taken in the balance of strategy for renewable energy development in Somerset; however, considered issues: if low-level short term ecological impacts may occur at the County Council will need to ensure its policy framework is a site that otherwise on balance would be suitable, these impacts must be suitable for considering the different types of minerals applications mitigated and then effectively mitigated; conversely, if designated or high submitted. quality sites, species or features were impacted significantly, with no potential for minimisation or mitigation of these impacts, SWT would expect to see a presumption against that scheme.
Page 86 of 193 R15.1 Natural England supports the development of renewable technologies in All significant impacts from a proposed minerals development would appropriate locations. We believe that while well sited and designed need to be considered by the County Council in determining an developments are unlikely to damage the natural environment, this does application. This basic approach will apply regardless of the type of not remove the obligation through environmental legislation to examine the technology being deployed. potential effects that they can cause, and in the event that potentially significant impacts are identified, that these are minimised or avoided It is not appropriate for the Minerals Core Strategy to deliver a spatial altogether, especially when it could affect rare and threatened species and strategy for renewable energy development in Somerset; however, designated sites and landscapes of national and international importance. the County Council will need to ensure its policy framework is There are areas where some renewable energy developments may not be suitable for considering the different types of minerals applications compatible with the need to safeguard environmental assets, e.g. wind submitted. energy developments on or close to Special Protection Areas, Ramsar Sites, Special Areas of Conservation and SSSIs.
R18.2 Any polluting forms of renewable energy Noted. R25 Within the AONB, it is unlikely that large scale wind turbines or solar farms Noted. could be adequately integrated into the landscape.
R34 Solar panels could be erected in quarry beds. They are moveable, and Noted. produce energy in daylight hours, when the quarries are working and using most energy.
R35 No Noted. R43 No on the basis each proposal should be considered on its own merits. Noted. R44 No on the basis each proposal should be considered on its own merits. Noted. R72 All forms should be considered. Noted. R74 No - Each option should be considered on merit determined by the site. Noted. "horses for courses"
R80 No comment. No comment R81 is nuclear renewable? Wood chip as a renewable is a miss classification Noted. as the resources required to chip wood and get it to combustion is not as low carbon as suggested. The wood growth rate in the UK is relatively slow, plus mon culture over sufficient land area precludes 'friendly'.
Page 87 of 193 R82 All Noted. R85 No knowledge. No comment R86 No. Noted. R88 No Noted. R93 No so long as the site is suitable Noted. R100 Wind farms Noted. R106 None Noted. R116 No Noted. R117 no Noted. R119 No, all feasible renewable energy schemes should be considered for a site Noted. R123 In this area wind turbines – wild fowl flight paths. Noted. Fracking is not a renewable technology and will be Hydro fracking. considered separately. The emerging evidence on fracking and the potential for applications to come forward will be considered in preparing the Core Strategy, and a decision made as to whether it merits specific reference. R124 Wind turbines – water expanses within the vicinity have encouraged Noted. Fracking is not a renewable technology and will be wildfowl activity – flight paths. considered separately. The emerging evidence on fracking and the Hydro fracking. potential for applications to come forward will be considered in preparing the Core Strategy, and a decision made as to whether it merits specific reference.
R125 None as each site can be so different that it is hard to come up with a form Noted. of renewables that is entirely unsuitable for any quarrying situation (tidal excepted). R127 Shale Fracking and Bore Holes, are not acceptable. Fracking is not a renewable technology and will be considered separately. The emerging evidence on fracking and the potential for applications to come forward will be considered in preparing the Core Strategy, and a decision made as to whether it merits specific reference.
Page 88 of 193 Question 15: Are there any forms of renewable energy generation that are particularly suited to minerals working areas that should be encouraged?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 No Noted. R13 No comment. No comment. R15.1 Ground source heat exchange or geothermal energy production may be Noted. appropriate developments for some quarries.
R18.2 No Noted. R25 Small scale solar schemes may be useful to generate energy within the Any proposal would be considered for its potential landscape and quarrying area and could be ground-mounted or utilise the roofs of any visual impact assessment. Policy will address this in the Core quarry buildings. The visual impact of these would need to be considered Strategy. as part of the Landscape and Visual Impact Assessment for the whole quarry. Ground or air source heat pumps could possibly be used to supply quarry buildings.
R35 Solar power, water turbines. Noted. R36.2 Support should be given to Solar Panels and Hydroelectric schemes Noted. (particularly when restoration is planned).
R43 Solar wind, energy from waste, heat exchange from water bodies are the Noted. obvious renewable energy forms which could be considered at quarry sites, depending on constraints that may exist.
R44 Solar wind, energy from waste, heat exchange from water bodies are the Noted. obvious renewable energy forms which could be considered at quarry sites, depending on constraints that may exist.
R74 as above Noted. R80 No comment. No comment
Page 89 of 193 R81 hydro and or heat sink hole in the ground covered over makes great hot Noted. house - vege growth.
R82 Wind turbines on hills generated by waste. Solar farms. Noted. R85 No knowledge. No comment R86 Dont know. No comment R91 Wind Farms, water mills, incineration. Noted. R93 Wind turbines may be appropriate in exposed locations above a cliff face Noted. R100 solar pannel farms Noted. R106 There are a number of forms of renewable energy generation that could be Noted. carried out in quarries including wind, solar, energy from waste, heat exchange from deep boreholes or water bodies etc.
R116 No Noted. R117 not as far as we are aware Noted. R119 Wind turbines and photovoltaics would be well suited where a suitable grid Noted. connection is available. They could be portable, temporary structures in mineral working areas.
R123 Solar energy on Quarry faces. Noted.
R124 Solar energy – setup on south facing quarry faces. Noted.
R125 Quarrying sites can be so different that most forms of renewable could well Noted. in one quarrying site or another (tidal excepted).
Page 90 of 193 3 Peat
Issue P1: Establishing a landbank for peat
Option a: A suitably sized landbank will be maintained to ensure adequate provision of peat whilst avoiding over supply.
Option b: No further peat permissions should be granted.
Question 16: Which option do you support for Issue P1?
Summary of responses to question 16.
6% (2 responses) 18% (6 responses)
Option a Option b
Other
76%
(25 responses)
Page 91 of 193 Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R9.3 Our main area of concern is over the extraction of Peat. This is a fragile Noted. and non-renewable archive that preserves archaeological structures and a wealth of evidence for past environment and climate. It is also a carbon If peat extraction were to be allowed, conditions to require store, a function that will be lost if commercial peat extraction is permitted. archaeological recordings of deposits will be considered. We therefore strongly support Option b - for no further permitted extraction to take palce. If peat extraction is allowed as a last resort on a limited bases we would urge you to require Conditions to be imposed requiring archaeological recording of the deposits and this should be reflected in policy guidance.
R12 We strongly support option P1b. We strongly oppose the proposal for a Noted. However, it should also be noted that there is the potential for more flexible landbanking policy in order to meet demand through the imports of peat to increase if peat extraction in Somerset drops, future expansion of the industry in Somerset: We do not think this can be thereby increasing the carbon footprint and exported environmental justified based on existing consented reserves.There is currently major impacts (for example, European habitats) elsewhere. over production of UK-sourced peat and a large number of extant but unworked permissions on the Levels; A flexible 'supply and demand' A sustainable approach that is in line with national policy and landbanking policy is contrary to current government Natural Environment informed by the consultation replies will be considered in the White Paper policy which seeks to reduce UK peat production by 2030 to production of the Core Strategy. zero; It does not encourage the industry to switch supply to non-peat alternatives. The UK peat industry has failed to meet the Government's 2010 peat replacement targets. This seriously undermines any case for further peat expansion in Somerset; Development of a strong non-peat alternatives industry in Somerset would help provide sustainable long-term employment for peat workers beyond 2030; Peat extraction releases large amounts of stored soil carbon and makes a significant contribution to greenhouse gas emissions. Further expansion takes no account of carbon or other climate change impacts arising from such a policy, and is in our view contrary to the principles of sustainability which should underpin the MCS. The Somerset peat industry imports large amounts of peat from Eire and the Baltic where peat extraction causes extensive damage to species- rich lowland mire, one of Europe's most important ecosystems.We believe it is unacceptable that the county's Minerals Core Strategy continues to support an industry which directly contributes to the loss of this critical
Page 92 of 193 European habitat. We strongly oppose the importation of peat from Eire and the Baltic states. We agree with the MPA that peat extraction in these countries is likely to have a significantly deleterious effect on priority European habitats and species. However, this cannot be used as a basis for arguing for the continuation of the Somerset peat industry, which must begin to demonstrate a commitment to the development of non-peat alternatives to replace the dwindling local peat supply. Like the MPA we remain very sceptical about the peat industry's commitment in this regard, and pressure through national policy and the Somerset MCS is required in order to force the necessary changes in this unsustainable and damaging industry.
R13 SWT strenuously opposes new peat extraction and therefore supports All comments are noted. Option B. Clearly, if the Government remains committed to the clear direction of travel demonstrated in both the Natural Environment White The Mineral Planning Authority is fully aware of potential problems Paper and draft National Planning Policy Framework, there will be no new caused by the extraction of peat and has recognised these in past peat permissions in Somerset. Whilst SWT consider it highly unlikely to consultations, including this Minerals Options consultation. happen, if there is a change to this commitment we would not support Option A. The extraction of peat is unsustainable and ecologically All impacts of peat extraction will be considered to help inform a destructive, generating impacts that cannot be offset. The argument sustainable approach to peat in the Core Strategy that is in line with posited by peat producers that worked-out peat sites can result in benefits national policy. to nature is disingenuous: peat communities are unique, scarce and a priority for conservation action; destroying this unique soil substrate and the flora and fauna it supports, or has the potential to support, and replacing it with a more easily created and more ubiquitous habitat is not justified in conservation terms. Peat is not a sustainable, renewable or reusable resource. Peat soils are laid down over millennia, and therefore to all intents and purposes are finite, exhaustible and irreplaceable. By association, so are the flora, fauna and ecological processes it supports. Peat and the ecosystems associated with it provide a range of well documented ecosystems goods and services - a range of "free" benefits to society, the economy and the environment, including carbon sequestration, water storage and purification, and biodiversity. The destruction of peat resources for the short term economic gain of a few individuals has profound socio-economic and environmental consequences; unfortunately, because there is disconnect between the immediate peat removal and the subsequent problems it causes, the true impacts of peat extraction for Somerset have rarely been formally
Page 93 of 193 recognised. Cause and effect, whilst not always immediately obvious, needs to be considered when dealing with natural systems: can we really afford the true costs associated with the loss of processes, services and goods generated by the Levels ecosystems? R14 Clearly the SPPA supports 'Option A' and believes that a suitably sized Noted. landbank should be maintained to ensure adequate provision of peat whilst avoiding over supply.
R15.1 We support Option B. Peat soils are of greatest value to society when All comments here will be taken into account and guide the peat remaining in situ and managed carefully to maintain the ecosystem policy contained in the Core Strategy. All impacts of peat extraction services they provide, including carbon storage, water storage and will be considered to help inform a sustainable approach to peat in purification, supporting biodiversity and preserving irreplaceable the Core Strategy that is in line with national policy. archaeological material and pollen and plant remains which represent an invaluable record of environmental change. The Natural Environment It needs to be borne in mind that Somerset County Council as the White Paper: "The Natural Choice: securing the value of nature" (June Minerals Planning Authority has no authority to prevent the 2011) calls for a reduction in peat use to zero by 2030 through voluntary importation of peat. adoption of other growing media by industry and consumers. This is reflected in the Draft National Planning Policy Framework (July 2011), which states: "In preparing minerals plans local planning authorities should: not identify sites or extensions to existing sites for peat extraction." "When determining planning applications, local planning authorities should: not grant planning permission for peat extraction from new or extended sites." Retention of these policies in the Final NPPF will rule out the creation of a peat landbank. In our response to the Somerset Peat Paper - Issues Consultation for the Minerals Core Strategy, Somerset County Council (September 2009) we stated: "The use of peat for growing media should be phased-out rapidly, with no new permissions being granted in Somerset and importation of peat ceased to prevent further damage to peatlands outside the UK. The review of minerals planning policy in Somerset provides an opportunity for the county to lead in reducing damage to irreplaceable peat deposits, and ultimately ending exploitation of a resource that provides essential ecosystem services to society which far outweigh the short-term needs of the horticultural industry." We believe that these statements should be guiding principles in reviewing the future of the peat extraction in Somerset.
Page 94 of 193 R16.1 Any additional granting of peat permissions would inevitably have a Noted. detrimental effect on the archaeological resource. This resource includes the rare and internationally important waterlogged prehistoric structures and also the peat itself which is a unique and irreplaceable archive of information on past climate and landscape change, both natural and anthropogenic. This option is the one that follows the very clear steer of the Draft National Planning Policy Framework and the Natural Environment White Paper and the recommendations of the SEA/SA.
R18.2 Peat deposits have a wide range of public benefits which are too important It is noted that this issue needs to be considered on a wider to sacrifice as a result of destruction of the resource for short term gain. geographical scale. There is the potential for imports of peat to Denying further planning consents would encourage more sustainable increase if peat extraction in Somerset drops, thereby increasing the options to come forward more quickly.This need joint action on an EU and carbon footprint and exported environmental impacts elsewhere. worldwide scale. R22.1 It will be important to monitor peat production and remaining reserves, It is likely that peat production and remaining reserves will be based on a clear methodology. It is appreciated that this will be dependent monitored through the use of monitoring indicators in the Core on the Government's position concerning the future of peat production in Strategy. This has been very hard to do in the past since the only England. Consideration should be given to environmental and wider available data comes from national reports or reports supplied by the sustainability implications of increased peat imports, should national policy Mineral Valuation Office; however, the County Council continues in materialise as currently drafted in the NPPF and the Natural Environment its efforts to strengthen its evidence base on peat reserves. White Paper. All potential impacts of peat extraction, direct and indirect, will be considered to help inform a sustainable approach to peat in the Core Strategy that is in line with national policy. R25 The AONB Unit has no comments to make on this question. No comment R34 We have no comments on peat other than to note that production is Noted. unsustainable and should be halted as soon as possible.
R35 N/A to Binegar Parish No comment R71 Peat is a 'luxury' item which is unnecessary for amateur or professional Noted. growers. The damage caused by CO2 emisions should be enough to justify ending this unnecessary industry.
R73 I believe that peat extraction should cease and we manage the landscape All relevant land uses will be considered in the Core Strategy. for bio diversity and natural wildlife
Page 95 of 193 R74 There are alternatives to using peat and the environmental impact of its Noted. extraction is significant. R76 6.29 - 'protect Somerset's remaining peat and local carbon store'. Noted. R78 Given the government's drive to eliminate peat usage, Somerset County A sustainable approach that is in line with national policy and Council should support them and oversee the phase out of peat excavation informed by consultation responses will be considered in the and havitat destruction over the desginated time span shown in the HM production of the Core Strategy. While educating the gardening Government White Paper - Natural Choice (June 2011). In addition, SCC public in the use of alternatives is perhaps warranted, the County should take every opportunity to educate the gardening public in the use of Council is not best placed or the most appropriate organisation to do alternatives. this. National bodies and initiatives are already taking action to promote awareness and understanding of the issues involved. R81 peat can reduce flood risk That home gardeners have a demand this is Noted. because they can not think, or know of, other material that could be better for their ends. Locals here throw out waste, and later buy it back as compost. This is incredible expensive. Don't compost. The trick to successful gardening is to grow a soil first - and to achieve this does not depand on the quantity of peat thrown onto it. This from one who lived out of the garden all year. R88 Peat bog is important in absorbing heavy rain thus reducing the risk of Noted. However, it should also be noted that there is the potential for flooding. Therefore as much peat bog as possible should be left intact. It is imports of peat to increase if peat extraction in Somerset drops, perfectly possible for growing media to become peat free, the National thereby increasing the carbon footprint and exporting environmental Trust and the Royal Horticultural Society grow all of their plants in peat free impacts elsewhere. media. If peat is not available then gardeners will be forced to buy alternatives. R93 Alternative materials are available and should be used. The uses to which Noted. peat is put are not vital so do not merit the damage caused by its extraction. R97 It is premature to ask this question as the government has yet to finalise a The County Council has taken note of emerging peat policy and any national proposal for peat extraction. changes to national policy for peat extraction (for example via the National Planning Policy Framework) will be taken into account in the Core Strategy. R111 The National trust has made considerable efforts over the last few years to Noted. become peat-free in its gardens. We are concerned about the continuation of peat extraction and we consider that no further planning permissions should be granted for peat extraction in Somerset.
Page 96 of 193 R114 The granting of new permissions, or the development of a land bank, Noted. should include a flood risk assessment and drainage plan for extraction and restoration for proposed areas. Again, this will assist the IDB in managing changes in water management.
R115 No further peat permissions should be granted. Future effort and policy A sustainable approach that is in line with national policy will be should be directed towards the increased promotion and use of considered in the production of the Core Strategy. sustainable and proven peat-free alternatives in line with developing Government policy. R116 Important employer Noted. R119 Option b, no further permissions, this is in line with the emerging NPPF. Noted. A sustainable approach that is in line with national policy will be considered in the production of the Core Strategy.
Question 17: If a landbank policy is developed what should we consider in calculating the size of the landbank?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R12 We strongly oppose option P1a. We do not believe there is a need to Noted. supply a landbank beyond the volume of available peat within existing planning permissions. It is clear that there is more than sufficient peat within existing permissions to meet demand within a declining turnover to 2020, notwithstanding uncertainties over the NPPF and the absence of data from Somerset peat producers to the contrary. We estimate from the figures provided in the options paper that there are a minimum of c.12-13 years of supply available through existing permissions. We believe this should be more than adequate given the comparison with sand and gravel reserves of approximately seven years. This concurs with the statement at 6.23, 6.28 and 6.37 which we welcome. We therefore do not agree with the need to provide further landbanking based on security of reserves as set out in para 6.27.
Page 97 of 193 R13 SWT is opposed to a landbank policy, however we recognise that SCC Proposing to maintain a landbank is also an attempt to steer away must take its local policy steer from national Government. Discouraging from a potential increase in imports from outside of the UK which peat production should be the fundamental factor in calculating the size of would increase the carbon footprint of peat used in the UK and export the landbank. Proposing to maintain a landbank for reasons of flexibility is environmental impacts elsewhere. predicated on peat use levels rising, and/or an inability of the market to supply sufficient alternatives. Firstly, maintaining a landbank is in itself It is not expected that maintaining a landbank will discourage likely to give rise to the latter scenario, as it creates a perverse incentive to producers switching to alternatives; however, it may help to ensure peat producers to avoid making the switch to sustainable alternatives, and that peat extraction can be managed sustainably and help indicate continue "business as usual". Secondly, there has been a year-on-year when further reserves may be required – thereby preventing an decline in the sale of horticultural peat; couple this with the Government increase in imports. setting up a task group and a statement that legislation against peat use is under consideration, a substantial decline rather than increase in peat usage and demand should be anticipated over the life of the Plan. Therefore, the smallest possible landbank should be sought, alongside an understanding that policy will be put in place to promote, encourage and support producers to switch to generation and supply of sustainable alternative growing media. R14 Calculations of the size of landbank should take account of the following: If a landbank policy is taken forward into the Core Strategy the points 1. Current and projected levels of peat use, including the possibility of made will b e considered in the calculation of the size of the landbank. replacing imported sphagnum peat with additional Somerset sedge peat by NB: point 5 is not seen as relevant to help calculate the size of a taking advantage of innovative peat free materials. 2. The volume of landbank, as whether or not applications come forward is not only consented reserves actually available to the Somerset industry (excluding due to appropriate land being available; also it is dependent on the land held by third parties that has not come forward to date and is unlikely industry bringing these forward and having appropriate supporting to do so). 3. The annual production capacity of the Somerset industry, assessments completed. which is constrained by the surface area open for extraction. 4. The reserves available to the individual members of the Somerset industry. 5. If there is insufficient peat available in the UK to continue to supply The rate at which new applications have come forward and the need for the market, data should be provided by the peat industry to support significant 'Areas of Search' to make assembling viable blocks of land at this position and make clear this requirement locally and nationally. reasonable cost a realistic prospect. 6. Progress towards DEFRA voluntary To date this has not occurred and Somerset County Council has tried peat reduction targets and the conclusions of the 'DEFRA Sustainable to obtain further information from the industry before without success. Growing Media Task Force', in particular with respect to the responsible The County Council has collected figures from the Office for National sourcing of growing media. Despite the significant commitment that the Statistics in the ‘Minerals Extracted in Great Britain, Business Monitor SPPA has made to working with Government, we intend to complete the PA 1007’ and sought data from the Minerals Valuation Office – both survey work relating to peat use over the last 10 years and the remaining of these sets of figures are broadly similar showing a decline in landbank. Clearly, however, this must be regarded as secondary to Somerset peat sales. Furthermore Somerset County Council has involvement with the process for future peat policy and peat use at a estimated reserves using geographical and geological data together national scale. It should also be noted that the SPPA disagrees with the with assumptions about the way sites are worked. Further work will view of Judith Stuart that there is sufficient UK peat to continue to supply be carried out to support the figures collected and produced so far.
Page 98 of 193 the market until the DEFRA voluntary phase out target is achieved without increasing imports. DEFRA has yet to supply any data to support this With reference to the National Planning Policy Framework, the assertion, which is at best a crude measure as it fails to account for which Council is obliged to adhere to national policy and guidance. If it companies have access to that peat. This is one issue that will be deviates from such policy and guidance, it must provide robust addressed and clarified by the Task Force and SCC must wait for the work justification for doing so otherwise its policies will be found unsound. to be completed to have a definitive view on this issue. The SPPA If it is more responsible to extract and source peat from archaic peat disagrees with the suggestion that the time taken to realise peat land under agriculture than from raised bogs then it is anticipated that permissions is less than for other minerals owing to the relatively low national government, via the National Planning Policy Framework, capital cost of working sites. This takes no account of the difficulty in Natural Environment White Paper and similar government policy and assembling viable blocks of land, which is difficult owing to the complex guidance, should show clear direction on this. ownership structure and relatively low value of peat compared to other minerals. As SCC well knows, the time taken to assemble blocks of land A sustainable approach that is in line with national policy will be and secure recent permissions has been well in excess of 1o years. With considered in the production of the Core Strategy. respect to point 4 above, consented reserves are not necessarily equally distributed in line with demand and it is not realistic to argue that supply will be determined by the market. Just because a company holds a significant reserve of peat in the ground does not mean that they have the customers to match their potential harvest or sufficient production capacity to increase their customer base. Individual companies are more likely to hold future reserves than sell to competitors, which will promote importation of peat to Somerset if a landbank is provided on an industry wide basis without accounting for the requirements of individual companies. It is also important to note that the DCLG Team Leader of Minerals & Planning Policy has confirmed that even if the final version of the NPPF reflects the draft document so far as peat policy is concerned, the NPPF will be guidance document only. This means that SCC will not be legally bound to comply with the final NPPF and could continue to grant new peat extraction planning permissions if it wished to do so. Therefore incorrect for the full options paper to state in paragraph 5.21 of the Options document that SCC would not be able to grant new permissions in the final NPPF is unchanged from the draft. The subsequent references to a ban on new permissions in also incorrect. Should SCC have any doubts, Mark Plummer of DCLG will be able to clarify this point. New peat extraction planning permissions in Somerset could be justified if the alternative were the import of sphagnum peat from raised bog sites elsewhere. This will be particularly relevant if the peat policy in the final version of the NPPF is unchanged form the draft, but the 'DEFRA Sustainable Growing Media Task Force' concludes that it is more responsible to source that peat which
Page 99 of 193 is required in future from archaic peatland under agriculture than from raised bogs.
R15.1 We are opposed to the concept of a peat landbank. Noted. R18.2 There should not be one. Noted. R25 The AONB Unit has no comments to make on this question. No comment. R35 N/A to Binegar Parish No comment R74 The primary consideration should always be the resulting impact locally. R76 The land bank policy is not supported. Noted. R85 The sentimentnationally is to phase out the use of peat. I recognise that Noted. this does have implications on employment in this area, but it is something that just have to be faced up to and accepted as policy.
R86 Real need and damage to loal?national environs. Noted. R93 I disagree with a landbank policy for peat for thereasons given above Noted. R97 See answer for Q16. Noted. R115 Although data has not been supplied by the industry (Summary paper, para. 6.9), data from the Office of National Statistics indicates a falling Any changes in national policy will be reflected in the policies trend in the amounts of peat extracted and sold from Somerset (accepting included in the Core Strategy. that this may be offset by a rise in use of imported peat and alternatives). In any case, "currently there is sufficient peat to meet anticipated demand and there will be no need to permit more." (Summary paper, para. 6.13). Any future Somerset peat landbank policy should fully reflect the current Government trend to reduce peat extraction, and encourage the continued, increased use of sustainable, peat-free alternatives. Future landbank policy should also take into full account the location of landbank areas; for example, preference could be given for landbanks to be sited in: a) Areas that are relatively 'biodiversity-poor' b) Areas that are relatively 'archaeologically-poor' c) Areas which minimise impacts on communities, such as volumes of traffic movements d) Areas which permit optimum opportunities for after-use restoration, including biodiversity after-use, local tourism opportunities (passive fishing, no mechanised boating, etc). If
Page 100 of 193 current national Government policy for mineral reserves remains 'as is', then a Somerset peat landbank policy should be revised (ie. reduce the size of the existing landbank) in accordance with the best available data specifically relating to Somerset peat demand and supply levels. If national Government policy for mineral reserves is revised and identifies a reduction in the requirement of peat reserves, then a Somerset landbank policy should, likewise be revised (ie' reduce the size of the existing landbank) in accordance with the best available data specifically relating to Somerset peat demand and supply levels. If national Government policy for mineral reserves is revised and identifies an increase in the requirement of peat reserves, then a Somerset landbank policy should adhere to the situation recognised within the Summary Paper, namely "currently there is sufficient peat to meet anticipated demand and there will be no need to permit more." (Summary Paper, para. 6.13).
R116 Development at a rate to support sustainable development Noted. R127 Provision should be made for greater demand than the Governments peat Noted. free targets suggest. We do not want to import peat when it is abundant in this country. Suggested figure: 1,000,000m 3.
Page 101 of 193
Issue P2: Sites with potenti al to impact on the Somerset Levels and Moors Special Protection Area.
Option a : Permissions that will have a detrimental effect on the Somerset Levels and Moors Special Protection Area can be voluntarily revoked and offset by grant of permission at an alternative less sensitive site. The replacement site will still have to be acceptable in planning terms.
Option b: Peat permissions that will have a detrimental effect on the Somerset Levels and Moors Special Protection Areas should be reviewed and permissions modified or revoked as appropriate. Loss of asset will have to be compensated from the public purse.
Question 18: Which option do you support for Issue P2?
Summary of responses to question 18.
19%
(5 responses) 26%
(7 responses)
Option a
Option b Other
55% (15 responses)
Page 102 of 193 Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R1 Peat working is not damaging to wildlife, on the contrary, peat working has Land owners have to work their peat land in accordance with national created the wildlife habitat, landowners with permission for peat harvesting and local planning policy. The Core Strategy will play an important should be allowed to use their land in the best way that only they know role in local-decision making during the Plan Period. how, no-one should be allowed to interfere with the original permission or make claims on other peoples property unless they are prepared to fully It is clear that habitats are impacted by peat working. Though new compensate them financially for their losses. habitats can emerge after the working has finished and restoration has been completed, ultimately extraction disturbs and changes the natural environment that was once there. R8.1 The Agency is of the view that consideration needs to be given to potential Consideration will be given to potential impacts on all environmental impacts on SSSI and Ramsar features and wetland archaeology, not just and landscape designations (as it happens already via the Minerals the SPA. If the Draft National Planning Policy Framework is adopted, Local Plan). The current review of sites with potential to impact on Option (a) would appear to be unacceptable as it effectively provides for the Somerset Levels and Moors is relevant to Special Protection the identification of alternative sites or extensions to existing sites for peat Areas which broadly cover the same areas as SSSI and Ramsar. extraction. Some restored peat workings have been an asset to SPA features but peat workings are likely to damage SSSI and Ramsar features If the Draft National Planning Policy Framework is adopted in its (and buried archaeology) especially if land is drained for long periods. current form, as stated in the Options Paper, then it is highly unlikely These designated sites are not isolated examples of important habitat but that Option a would be adopted. are surrounded by a landscape which includes many similar habitats and species. Any policy should have regard to the recommendations of the Any recommendations and policies included in the Core Strategy will Lawton report (Making Space for Nature: A review of England's Wildlife have regard to relevant national policy and guidance. Sites and Ecological Network) which emphasises the need to retain and strengthen networks of similar habitat.
R12 We appreciate the MPA's work to date in carrying out its Regulation 63 Noted. duties with regard to extant peat permissions within the Somerset Levels & Moors SPA and Ramsar site. We strongly support option b.
Page 103 of 193 R13 The wording of these options needs to be revised: under Reg 63 of the Any wording will be checked prior to writing the Core Strategy to Habitats Regulations 2010 the requirement is for plans, projects and ensure appropriate terminology is used, not least to implement the activities not directly connected with the management objectives of the Habitat Regulations. Natura 2000 site to be assessed for alone and in-combination for "significant impacts", not as stated in the Options Paper for "detrimental The importance of policy delivery is noted and will need to be effect". As stated in answer to Question 16, SWT views peat extraction in carefully considered on this and other aspects of the Core Strategy. the Levels and Moors as an unsustainable and environmentally damaging land-use, and therefore would not support a policy that encouraged new peat digging as a result of permission revocation. We support Option B, and feel Appropriate Assessment under Reg 63 should be prioritised for those sites likely to be the most damaging to the conservation objectives and function of the Natura 2000 sites, with a view towards modifying or revoking permissions where necessary. However, our support for Option B is predicated on an understanding that sufficient resources for site assessment, negotiation and compensation for modification and revocation are actually put in place. There is little point in having a policy in place to comply with legal requirements if no resources are made available to enact that policy. This certainly appears from the outside to have been an issue over previous years, as although SCC has had a legal obligation to undertake this review since the enacting of the original Habitats Regulations in 1994, no permissions have ever been modified or revoked. R14 The SPPA supports a combination of both approaches as adoption of If the Draft National Planning Policy Framework is adopted in its either option alone is too restrictive and formulaic, failing to take account of current form, as stated in the Options Paper, then it is highly unlikely individual site circumstances. It is important to remember that in some that Option a would be adopted. cases, sites have been designated as SPAs specifically because of peat extraction, followed by high quality restoration. The first Godwins reedbed While some designations have been created as a result of on Pols Heath, Westhay is the best example of this. The site was initially successfully management by a range of stakeholders post extraction, restored to low level agriculture but, following a voluntary agreement this would be an insufficient reason to continue to extract peat. The between Godwins and the then Nature Conservancy Council, was restored continuation of peat extraction will only be permitted if it is in line with to a reedbed. It has subsequently designated a SSSI and then an SPA. All national policy and meet the principles of sustainable development. peat extraction planning permissions within the SPA will have to be reviewed, but the outcome will depend on site specific circumstances. In some cases it will be possible to agree changes to the working method or restoration outcomes that mitigate any harm to, or enhance, the SPA. In cases where it is not possible to do so SCC will have to consider revocation and payment of compensation. In some cases it may be possible to agree voluntary revocation, offset by a new planning permission but that will not always be viable or desirable. In the final
Page 104 of 193 analysis revocation and payment of compensation may be the only option. SCC cannot have a policy that allows only offsetting or only revocation, all options must be available.
R15.1 We support Option B. Damaging impacts on the designated features of Noted. the Somerset Levels and Moors Special Protection Area should be addressed as soon as possible. Extraction of peat from locations outside statutory designated sites still represents a cost to the environment and society. When climate change impacts and the archaeological and environmental record stored in peat soils are considered, then no sites outside land covered by statutory designations can be considered less sensitive. In reality, peat soils are not a sustainable resource and must be protected to safeguard the critical ecosystem services that society depends on, which are principally, carbon storage, water storage and purification, biodiversity and preservation of heritage features.
R16.1 If option A is chosen it should be borne in mind that archaeological If Option a is chosen a full environmental impact assessment, evaluation will be required on any new areas and also archaeological including archaeological evaluation, will be completed. If the Draft mitigation. The archaeological evaluation may rule out peat extraction in National Planning Policy Framework is adopted in its current form, as some areas. Such archaeological evaluation has a cost that should not be stated in the Options Paper, then it is highly unlikely that Option a taken by SCC. would be adopted.
R18.2 Both of the options described above should be employed as appropriate to Noted. However, if the Draft National Planning Policy Framework is the circumstances. adopted in its current form, as stated in the Options Paper, then it is highly unlikely that Option a would be adopted.
R25 The AONB Unit has no comments to make on this question. No comment R71 I prefer Option A with the addition that any alternative should provide no Noted. more peat extraction than the revoked site.
R74 As above - extraction is undesirable for a number of reasons Noted. R85 We just have to wind down our use of peat overall. Moving extraction Noted. eleswhere should not be contemplated.
Page 105 of 193 R97 Whilst option a is preferable it is potentially flawed as any replacement site Noted. should lie within the Peat Production Zones and it may not be possible for any particular operator to secure control over a replacement site. If it is not possible to develop a replacement site then compensation will need to be paid. R103 The term 'detrimental effect' needs to be better qualified in terms of extent The term ‘detrimental effect’ should be fully explained in the Core and outcome. The impact of noise at a protected area may be detrimental Strategy. in the sort term but not in the long term and modified conditions may accommodate both objectives when considered over a longer period. The Compensation will be dealt with appropriately and assessed in terms Noise Policy Statement for England considers detrimental effects in terms of necessary modifications to existing planning conditions. of principles of sustainability and states 'It requires that all reasonable steps should be taken to mitigate and minimise adverse effects on health and quality of life while also taking into account the guiding principles of sustainable development (paragraph 1.8). This does not mean that such adverse effects cannot occur'. Option b is favoured against creation of new sites but issues of compensation may be complex when modifications are deemed necessary to working practice to avoid 'detrimental effect'. R115 Option b is preferable as voluntary revocations (Option a) are neither Noted. unlikely to be readily forthcoming from the local peat industry, nor will they necessarily be located at the optimum sites to benefit wildlife or archaeological interests, or provide community or after-use benefits. Compensation from the public purse will realistically be required, but this should be focussed on sensible market value linked to demonstrable need and value of the contained peat resource (and fully recognise that existing trends support reduction in demand for Somerset peat products). In terms of demonstrating value from the public-purse, land valuation may be based on a system of agricultural price rather than inflatory 'potential unrealised or un-needed peat value'. Detrimental effects on the Somerset Levels and Moors SPA should be gauged both as direct 'on-site' effects and also 'off- site knock-on' effects - for example, changes in hydrological regimes caused by peat extraction that demonstrably and detrimentally effect water levels in biodiverse wetlands, reedbeds, unworked peatlands etc. R116 Suport financially job loss Noted. R117 obvious Noted.
Page 106 of 193 Issue P3: Reclamation Framework
Option a: The framework for reclamation included in the Minerals Local Plan is still relevant and should continue to guide the type of restoration and after-use of sites
Option b: A framework for reclamation allows the industry and community to work towards a positive landscape and range of after-uses in the area, but the Framework in the Local Plan needs to be revised to reflect changes in the industry and opportunities such as biodiversity ambitions of the Natural Environment White Paper
Option c: Restoration options should not be prescriptive and should allow for a variety of beneficial land uses. It should be the responsibility of the developer to demonstrate the benefits of the restoration and after-use scheme.
Question 19: Which option do you support for Issue P3?
Summary of responses to question 19.
17% 21% (5 responses) (6 responses)
Option a Option b 14% Option c (4 responses) Other
48% (14 responses)
Page 107 of 193 Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R8.1 it emphasises the need for community involvement and reflects changes Noted. that have taken place since the last Minerals Plan, particularly in respect of biodiversity ambitions.
R12 We recognise the need for zoning of afteruse to provide facilities for other The County Council will aim to put in place a framework that reflects end uses. It is critical that these are assessed against the value of creating changes in the industry, national planning policy, new biodiversity sites of potentially international conservation importance, as illustrated at targets and initiatives, that provides flexibility and a range of RSPB Ham Wall which is now a National Nature Reserve supporting a beneficial after uses. range of rare and specialist wildlife, and which contributes significantly to the local rural economy as an important visitor attraction. Such opportunities are highly restricted, and need to be taken where they can, especially in the Brue Valley.
R13 Unequivocally and very strongly Option B for the same reasons as outlined A framework that reflects changes in the industry, national planning in response to similar issues relating to minerals (see responses to policy, new biodiversity targets and initiatives, that provides flexibility questions 11 and 12). A reclamation framework must respond to the aims and a range of beneficial after uses will be developed for the Core and objectives of the Natural Environment White Paper and associated Strategy. England Biodiversity Strategy 2020. Given the absolute and irreversible impacts of peat extraction upon the natural environment, reclamation for While it will be important for reclamation for nature to be prioritised nature must be prioritised. A strategic overview of the local ecological and to be in keeping with the surrounding environment, other relevant network should be taken and individual site reclamation plans must be after uses, where appropriate, will be considered. developed within this context. It is imperative that site restoration is enforced on private sites, and that the requirements to comply with The Core Strategy will look to achieve successful site restoration that restoration conditions are clearly mandated through local policy. It is is enforced through appropriate conditions. unacceptable for NGOs and organisations such as Natural England to be expected to pick up the tab for restoring sites back to nature after the peat producers have gained financially from peat extraction, which has happened too frequently in the past. In a recent case, Natural England partially funded proper completion of planning conditions prior to sale to an NGO, essentially rectifying non-compliance issues which rightly should have been undertaken by the peat producer. Whilst SWT can understand SCC having some concerns about the potentially unfavourable public perception of compensating peat producers for revoking permissions
Page 108 of 193 where damage is occurring to the Natura 2000 network, we would suggest the public is likely to be incensed at hearing tax payers money is being spent on works that were required of a company to fulfil their planning conditions. This policy option also needs to address achieving restoration The County Council will, with the input of stakeholders, seek to define when a site has not been fully worked out and is just sitting dormant. It the term cessation so that this issue can be addressed through seems too easy at present for producers to stop extracting before hitting minerals policy. their planning permission limit, claiming a pause rather than a cessation of digging in order to avoid incurring the cost of restoring the site, even if in reality they have no intention of recommencing extraction. SWT is currently part way through a £100,000 restoration project of a site that is now part of our Catcott Nature Reserve, with around £45,000 of this cost relating to completion of non-nature conservation planning conditions which should have been undertaken by the producer. This portion of the project was funded through an appeal to our membership, most of whom are Council Tax paying Somerset residents. In this particular case it would have been impossible for SCC to enforce the imposed planning conditions for restoration because the site was never fully worked out, and all sides wanted to see the site move forward. This is an all too easily exploited hole in the planning system which needs to be addressed through policy in the Minerals Core Strategy. R14 The Framework for Reclamation in the Minerals Local Plan has been A framework that reflects changes in the industry, national planning useful, but is now out of date and the issue of restoration zoning must be policy, new biodiversity targets and initiatives, that provides flexibility re-visited. When it was prepared no one could have envisaged the number and a range of beneficial after uses will be developed for the Core of visitors that would be drawn to the area by the Natural England, RSPB Strategy. and SWT reserves, or the issues and opportunities that would arise as a result. The SPPA supports Option c, but this is not mutually exclusive with achieving the objectives of Option b. An updated Framework for Reclamation could be useful if it is not over-prescriptive. If that route is adopted it should reflect the changes in the industry, new biodiversity targets and opportunities for leisure and tourism that have the potential to enhance the economy of the area. Where justified on a site by site basis by the developer, a variety of beneficial land uses should be permitted.
Page 109 of 193 R15.1 A framework for reclamation is necessary to reinforce requirements to Noted. Responses to this consultation question will inform the manage voids in peat soils created through completion of extant proposed reclamation framework put forward in the Core Strategy. permissions to maximise future benefits for biodiversity and sustainable rural industries.
R18.2 As with other mineral plans an overall framework for restoration is Noted. desirable, taking into account a full range of interests including biodiversity, landscape, recreation and tourism.
R25 The AONB Unit has no comments to make on this question. Noted. R35 N/A to Binegar Parish No comment R74 Some flexabilty for changing circumstances is desirable Noted. R76 Future reclamation of sites to be carried out in harmony with the Natural Noted. Environment White Paper.
R79 I live on the Somerset Levels close to some peat workings ,and at the Using worked sites for landfill would not adhere to national minerals moment once the working are finished they are left to nature or dug out or waste policy. Nationally waste management is moving away from deeper and filled with water for fishing lakes, I feel that some areas would landfilling waste and moving up the waste hierarchy. Similarly benefit if they where landfilled with controlled builders/demolition waste to mineral’s planning has moved towards beneficial restoration and after save going to other landfill sites of the council and at the same time put it uses that benefit both the environment and community. back to agricultural land ,which work alongside other areas ,which have just been left to nature, creating a mixed environment for wild life.
R80 No comment. No comment R91 The developer may have more imagination than Local Planners. Operators will have the opportunity to comment on the proposed reclamation framework in the Core Strategy and have the opportunity to suggest and input into any future reclamation ideas for sites. R92 A combination of Option a and Option b to include the biodiversity Noted. ambitions expressed in the Natural Environment White Paper.
R93 See answer to 20 below Noted. R97 Option c provides most flexibility. The developer will need to demonstrate Noted. that any proposed restoration would be viable, deliverable and most importantly compatible with surrounding land uses.
Page 110 of 193 R103 Option a is favoured as the three framework options for reclamation Noted, however the reclamation framework will need to give included in the Mineral Local Plan are still relevant and give some flexibility consideration to new national policy and guidance, such as the in approach based on the site concerned. Natural Environment White Paper.
R114 Planning conditions for restoring peat sites should be reviewed and a new framework developed. The IDB would like to contribute to this and to Noted. Contribution from the IDB is welcomed and will help to inform advise on flood risk and water management issues. Master plans should the emerging approach to restoration. be prepared and agreed for the restoration for multiply sites and a timetable for restoration agreed. This will assist the management of the surrounding drainage network by the IDB and help realise benefits of working at large scales. The granting of new permissions should be dependent on the completion and restoration of sites in other areas. A new restoration framework should encourage the retention more peat with voids and restoration using minimum intervention. The need to remove peat to the clay to provide material for clay bunds should be reviewed and more sympathetic and naturalistic restorations encouraged. The restoration of multiple sites could reduce bunding needed to isolate restored sites from active sites and enable more connected and natural systems to develop. Restoration plans must consider habitat and drainage connectivity and seek opportunities to incorporate flood storage and include features that help maintain water quality in restored areas as well as the surrounding ditch system.
Page 111 of 193 R115 Issue P3: Questions 19 and 20. None of the options provided is A framework that reflects changes in the industry, national planning necessarily 'mutually exclusive'. The basic framework of three potential policy, new biodiversity targets and initiatives, that provides flexibility options for reclamation in the current Minerals Local Plan (Summary and a range of beneficial after uses will be developed for the Core Paper, para. 6.24) are essentially still valid (although forestry in a Strategy. predominantly wetland system seems anomalous and 'out-of-place'). However, these former options now need revision, greater refinement and expansion in light of the recognition of modern ideas including: carbon sinks and sequestration/links with climate change, water level and flood management, ecosystem services and Government policy (such as the Natural Environment White Paper). The basic principle of enabling the Somerset wetlands to operate as a natural wetland system fits well with a modern ecosystem services approach and has obvious benefits in terms of: flood management and storage, a carbon sink, and opportunities for biodiversity, archaeological conservation, passive recreation (fishing, non mechanised boating), sustainable 'local-brand' agriculture and tourism. After-use and restoration priorities based on the adoption of a 'zoned approach' for the area could have considerable future potential for a broad range of uses and users. R116 All bodies should be involved in these decisions All stakeholders have been consulted on this through the Minerals Options consultation and previous Peat Issues Paper, and will again be consulted on the Draft Core Strategy. Furthermore all relevant stakeholders are consulted on relevant planning applications.
Question 20: Which after uses should be included within a restoration framework and why?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses
Page 112 of 193 R13 There are clear overriding arguments for nature conservation to be the A framework that reflects changes in the industry, national planning primary focus of after use reclamation, both within the boundary of the policy, new biodiversity targets and initiatives, that provides flexibility SPA and outside of it. Government is sending a clear signal through the and a range of beneficial after uses will be developed for the Core NEWP and draft NPPF that peat extraction is not acceptable owing to the Strategy. destruction of internationally important habitat. This should ring particularly true within the Somerset Levels and Moors, whose nature conservation While it will be important for reclamation for nature to be prioritised importance is demonstrated by a suite of local, national, European and and to be in keeping with the surrounding environment, other relevant international designations. The ongoing and historic damage caused to after uses, where appropriate, will be considered. biodiversity by peat extraction makes a strong argument for all after use reclamation to prioritise nature, to make steps to compensate for the An holistic approach that looks beyond site boundaries to contribute ecological deficit accrued through extraction. This rationale should apply to to ecological networks and ecosystem functioning, of high restoration the reclamation of all workings, not just those within the designated areas. value, will be endorsed in the Core Strategy. As recognised by the Birds and Habitats Directives - transposed into English Law by the Wildlife and Countryside Act 1981 (as amended) and the Habitats Regulations 2010 - the protected area does not exist in isolation, but rather is dependant upon connected, outlying sites, and functions as part of a wider network of ecologically important sites. Building on this, the NEWP calls for the creation of ecological networks, to reverse the increasing fragmentation and isolation of habitats which is affecting ecosystem functioning. It is not sufficient to simply "maintain" the extent of protected or "core" areas and to expect these to continue to survive as isolated island refuges for wildlife. There must be sufficient habitat in the surrounds to support viable populations, and to link with other "core" areas across the landscape. A strategic approach to peat site reclamation is as crucial on the Levels as it is to quarry restoration on the Mendips. Recognition needs to be given in any reclamation framework policy to that fact that reclamation of workings for nature will not replace the biodiversity Possible linkages with other projects and initiatives will be examined. that was once there - it is simply not possible to recreate the flora and fauna communities associated with peat soil, and the processes and systems it supported. Once the peat is dug, that's it. What gets created in the peat voids is a different habitat, suitable for different species, and this should not be seen as equal value compensation. Therefore, a high standard of reclamation for nature should be sought, with specifications for Quantitative and qualitative targets will be considered for inclusion in schemes developed via dialogue with the nature conservation partnerships an Implementation and Monitoring chapter in the Core Strategy. Any operating on the Levels. Linking reclamation plans with Somerset's targets will be monitored annually by using a serious of monitoring EcoNet, and the ongoing work for nature undertaken through the Brue indicators used to check the Core Strategy is delivering what it set Valley Living Landscape initiative, for instance, will help to maximise the out to deliver and to enable the policies in the Core Strategy to be benefits to nature by enabling a strategic approach to habitat creation a monitored for effectiveness.
Page 113 of 193 former peat workings. SWT does not view nature conservation as incompatible with other uses; rather, we believe a nature-rich environment can bring multiple benefits. Conservation needs to be economically viable in the longer term, and therefore combining a strong primary drive for biodiversity opportunities with economic activities such as reed production, food production, or tourism where appropriate makes perfect sense, and should be looked on favourably. However, it is important that where opportunities for multi-functionality are sought within a nature conservation driven scheme, these are monitored to ensure there is no conflict between land-uses contrary to the primary aim of reclaiming a site for nature.
R14 The SPPA believes that if there is to be a new Framework for Reclamation A framework that reflects changes in the industry, national planning core conservation areas should be identified, but outside of that wetland policy, new biodiversity targets and initiatives, that provides flexibility appropriate land uses should be considered on a site by site basis. It is and a range of beneficial after uses will be developed for the Core important to be clear that conservation and agricultural and leisure uses Strategy. are not necessarily mutually exclusive. The previous approach of zoning the eastern end of the Avalon Marshes for leisure use is out of date owing If a zoned approach is adopted as in the adopted Minerals Local to the pattern of leisure permissions granted and the acquisition of land by Plan, the zones will be consulted on and allocated in a sustainable the conservation organisations. Instead the SPPA supports a 'honey pot' manner that seeks to provide a range of beneficial after uses and to approach, with clusters of leisure uses within a wider restored wetland minimise any potential impacts on the surrounding environment and landscape. This allows visitors to be better absorbed within the area and communities. the benefits of tourism to be distributed amongst local communities. It is vital for local people that the Avalon Marshes does not become a unique habitat that is an economic wasteland. Conservation, agriculture and leisure uses need to be balanced to provide economic benefit and jobs for local and landowners.
Page 114 of 193 R15.1 Within the Somerset Levels and Moors SPA and Ramsar Site, we want to A framework that reflects changes in the industry, national planning see peat extraction sites restored to a nature conservation after-use which policy, new biodiversity targets and initiatives, that provides flexibility will support the features for which the Natura 2000 site and the underlying and a range of beneficial after uses will be developed for the Core Site of Special Scientific Interest are designated. Outside designated sites, Strategy. we would like to see a mixture of restoration schemes that will benefit biodiversity and support sustainable rural industries, such as reed production, which will add to the biodiversity value of sites and provide valued ecosystem services to benefit society. It must be recognised that that this is not restoration of lowland peatland, but transformation of the aftermath of extraction to create new wetland habitats. The creation of new While some designations have been created as a result of wetland habitats after peat deposits have been worked-out must not successfully management by a range of stakeholders post extraction, become a rationale to grant new permissions, irrespective of possible this does not give reason to continue to extract peat. The changes in government policy on peat extraction. The revised framework continuation of peat extraction will only be permitted if it is in line with must restate the importance of not exhausting peat deposits, but retaining national policy and meet the principles of sustainable development. peat bases in voids and leaving more natural edges to benefit biodiversity.
R18.2 Biodiversity, landscape, recreation, tourism and other ecosystem services. Noted. R25 The AONB Unit has no comments to make on this question. Noted. R35 N/A to Binegar Parish No comment R74 This will depend on the location. The use must be a positive benefit. Noted. R76 (i) Activities which promote nature conservation and wildlife protection - as Noted. these have direct benefit to public and communities. (ii) Restoration to farmland or woodland establishment providing this does not conflict with (i) - as this has local economy benefits. (iii) Areas of water-based activity, such as sailing or fishing lakes, which do not conflict with (i) - as they can benefit local economy directly.
R80 No comment. No comment R85 Opportunities for after-use are bound to vary from site to site so all Noted. possible options should be kept available for consideration, including adjustments to existing plans should new ideas come to light.
R86 Forestry, Wildlife,Conservation Noted.
Page 115 of 193 R91 Something that encourages industry or any nature, to make employment Noted. for local people, long term.
R93 Uses which match the surrounding areas including those listed in the Local Noted. Plan: Activities that promote nature conservation and enhance wildlife Conservation, Agriculture or forestry use that does not conflict with the maintenance and promotion of the wildlife interest & areas for land and water based activities which do not conflict with the wildlife interest - so could include canoeing, fishing, sailing but not noisy water sports/power boats; educational use. Allow flexibility for local people to develop new uses and contribute to the decision making process.
R97 The uses included in the existing framework provide a guide but should not Noted. preclude other types of use which have clear benefits.
R116 All options included to maximise a good outcome Noted. R117 leisure Noted. R119 Agree as suggested. Activities that promote nature conservation and Noted. enhance wildlife conservation. Agriculture or forestry use that does not conflict with the maintenance and promotion of the wildlife interest. Areas for land and water based activities which do not conflict with the wildlife interest and quiet nature of the area.
R123 A concentration on rehabilitation of the natural environment and its Noted, however other relevant after uses will be considered as well. aftercare. It would be unfair to disregard other beneficial uses.
Landscape management aftercare insufficient.
R124 Examples in this area presented a fund in Asham Wood – are of the few Noted. most ancients limestone woodland in the county.
The aftercare and upkeep is lacking in previous landscaping carried out and is essential.
Page 116 of 193 4 Building Stone
Issue BS1: Local stone for local demand Option a : Affirm the importance of building stone for maintaining local character and develop policy in support of new building stone quarries where a need for the stone can be demonstrated.
Option b: Consider activities and new products that could be developed at building stone quarries to enhance economic viability.
Question 21: Which of the options do you support for Issue BS1?
Summary of responses to question 21.
6% (3 responses)
31% Option a (16 responses) Option b
Other
63% (33 responses)
Page 117 of 193 Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R9.3 We suppot Option a and b. We woulc recommed that you raise the issue of Noted. The demand for and shortages of natural stone will be stone shortages with the Conservation Officers in Somerset who are discussed as part of the consultation process. dealing with these issues on a daily basis.
R13 No comment No comment R15.1 We support Option A which potentially has much to offer for geodiversity Noted. conservation.
R18.2 Somerset has a wonderful variety of building stone which gives each part The Core Strategy will aim to maintain the current availability of of the County its own identity and sense of place. It is crucial that this building stones and support new building stone operations where a variety of stone continues to be available and where it is not that new need for the stone can be demonstrated. supplies are found and developed.
R25 Whilst the Core Strategy does not propose the quarrying of building stone As stated by Minerals Policy Statement 1 there is a presumption within the AONB, there are likely to be situations where building stone against major minerals developments in AONBs. Also, the Draft could be required to retain the character of local buildings and other stone National Planning Policy Framework states that local planning structures in the AONB. These needs need to be planned for and authorities should as far as practical, ensure sufficient levels of incorporated into the Core Strategy. permitted reserves are available outside AONBs. The Core Strategy will look to support this; however it will also need to consider being flexible to circumstances that may warrant small scale building stone operations to support the local character of the AONB – environmental and community impacts permitting. R34 The overburden in aggregate quarries is often of building stone. This has It is not standard or indeed good practice to discard or waste traditionally been discarded. This should no longer be tolerated. overburden material and this would not be encouraged by the Core Strategy. The overburden is used in the processes of screening and restoring areas of respective quarries. More often then not overburden in aggregate quarries is not suitable as use for building stone due to the methods of extraction. R35 N/A to Binegar Parish No comment
Page 118 of 193 R36.2 We welcome the stress on local stone for local (matching) building Building stones are used on existing buildings for restoration, projects, although the transportation of there materials to satisfy conservation and extensions as well as for new building work. As interior/kitchen demand is neither sustainable nor necessary. The identified by the British Geological Survey there are two needs for question of costs bourn by applicants should be addressed and made stone now and in the future: 1) Traditional stone is used in the repair more manageable since small sites for local projects will become of historic buildings and new traditional build. It forms the structure unsustainable if the sums demanded for applications outweigh the and construction of buildings; 2) Modern construction industry uses ecnomic return to the applicant. stone for decorative purposes (as a veneer) not for structural or constructional purposes. To maintain the economic viability of building stone operations the Core Strategy will consider the maintenance of both markets.
R40 The pursuit of a positive policy for the supply of building stone is supported The County Council will continue work on its evidence base, drawing and will complement the similar approach being taken by Devon County from information received in response to the Options consultation and Council. Both options for Issue BS1 are supported, and it is suggested that relevant research to identify the stones that are currently unavailable future iterations of the Minerals Core Strategy should clearly identify the to help identify potential opportunities for supply, thereby informing stones that are currently unavailable to highlight opportunities for their the production of the Core Strategy. supply.
R57 Paragraph 7.22 refers to new building stone quarries. It should also explain The Core Strategy will recognise the pro’s and con’s of extensions to that existing quarries need to be extended when the original quarry existing and former sites as well as permitting new workings. In all becomes exhausted. County policies should support extensions of existing circumstances applications will have to meet environmental policies quarries provided that they meet the Council's environmental policies. The contained in the Core Strategy. Minerals Policy Statement 1 states a advantages in supporting an extension of a quarry are that the quarry preference towards extensions to existing quarries. infrastructure already exists. The quarry will usually have been operating for many years and local people will be used to the activity. The operator can work seamlessly into the extension without having to build roads, buildings, structures in a new environment which may be not only While need is difficult to determine, stakeholders (e.g. conservation disruptive to a community but expensive for the operator and customer. In officers, local builders, architects, district planners, geologists) can answer to Question 21, Option a should be supported. It should be noted provide a good indication of stone types that may be required in the that need is often difficult to determine where a type of stone has not been future. Projects such as the English Heritage Strategic Stone Study quarried in recent years and there is no record of previous output. It takes and responses to the Options consultation can help inform possible a number of years following the opening of a quarry and offering stone on need. the market before conservation officers, architects and builders accept that the availability of a local stone will in future be consistent, reliable and offered on a dependable commercial basis. Option a should state, "....and The wording of option a will be considered. develop policy in support of new building stone quarries where a current or future need for the stone can be demonstrated". With regard to Option b, it
Page 119 of 193 is essential, in operating a stone production business, to be able to offer As identified by the British Geological Survey there are two needs for the potential customer a wide range of stone and stone products. If, at our stone now and in the future: 1) Traditional stone is used in the repair Tout Quarry in Somerton, we were only permitted to sell the blue Lias of historic buildings and new traditional build. It forms the structure which is quarried there, it is unlikely that the quarry would survive and that and construction of buildings; 2) Modern construction industry uses skilled work and economic activity in this rural area would be lost. Unless a stone for decorative purposes (as a veneer) not for structural or customer can be offered different stones, including some from different constructional purposes. To maintain the economic viability of counties and some from different parts of the world, at the quarry they will building stone operations the Core Strategy will consider the go to the retail providers who specialise in imported stone products from maintenance of both markets. The Core Strategy will aim to ensure China, India, Brazil and other producing countries. A one product quarry this is delievered with due regard to the principles of sustainability could not compete in the market against such competition. It is essential to and while the importation of stone to help maintain the economic maintain flexibility in the importation and retail sale of imported stone viability and range of stone products at building stone sites is together with indigenous stone at quarry outlets. Any restriction on the understood, it will be particularly important to support local supply for building stone trade applied to quarry outlets would impede Somerset's local demand. currently prospering natural stone quarry industry which works our rich and diverse range of stones and the industry, in Somerset, would probably not survive. Also, activities and new products that could be developed at building stone quarries to enhance economic viability should include the The development of stone waste for products will be considered; development of stone waste for specialist products. The use of stone for however, the importation of waste to restore the land will need to be agricultural purposes (tracks, roads, animal bedding etc) is usually not weighed up against all potential impacts and be in accordance with possible from Somerset's abrasive carboniferous limestone aggregate national policy – mechanisms to address this will be considered, also quarries and planning policy should not automatically prevent the potential mindful of the Waste Core Strategy. to allow waste stone to be sold. The restoration of building stone quarry sites should also be considered using imported waste to return the land to its original levels. R61 In Q21, the options a and b are not mutually exclusive. I support the Noted. The options were not intended to be mutually exclusive. statement in option a but in some cases additional activities may be appropriate at quarrys to help sustain them economically. R65 Both options a and b are relevant and SF would support both. Noted. R74 Local character is one of our important assets in this country and the Current policy in the adopted Minerals Local Plan already recognises architectural the importance of maintaining the local character of Somerset and areas of supply outside of the County. Future policy in the Core Strategy will continue to recognise this issue.
Page 120 of 193 R81 Why not use other materials for building? The general material options Use of local building stone plays an important role in maintaining the available are currently restricted. For example, wood is ideal, if in the character of Somerset. Using other materials which may not fit in with future a building relocation is required in the coastal environment. This in the surrounding area could lead to a loss in character and damage turn is restricted by the present coastal strategy - which centres on life as conservation areas and local towns, villages and historical buildings. normal. The Flood risk strategy is likewise flawed. Simplistic assumptions. Furthermore, this is more sustainable then not using local stone, Other methods of building - rammed earth ? The current building methods which would lead to the importation of building stones, increasing the are NOT sustainable (as claimed by SCC and developers - got to think carbon footprint of the development and exporting quarrying about these people's life experience - very limited). elsewhere. It is also important, in conservation and restoration terms, to use stone with the same structural properties otherwise buildings may not be aesthetically pleasing and could be subjected to structural problems and stone decay. R82 If stone is in short supply then other forms of sustainable construction Noted. Such considerations do form part of the picture – and will be should be encrouaged. considered via District and Borough planning policy too. However, it is important to recognise the role played by local stone in maintaining the character of Somerset. Using materials which do not fit in with the surrounding area could lead to a loss in character and damage conservation areas and local towns, villages and historical buildings. It is also important, in conservation and restoration terms, to use stone with the same structural properties otherwise buildings may not be aesthetically pleasing and could be subjected to structural problems and stone decay. R83 Building stone - the availability of white lias is particularly important to Noted. Radstock.
R85 Keep all options open both for existing and potential new sites. Noted. R91 With more housing needed more local stone will be needed. Noted. R92 Maintenance of local character in Somerset villages is of paramount While local stone for local demand will be an important priority in the importance. Local stone should be primarily reserved for local purposes. Core Strategy, it will also be important for Somerset to cooperate with our neighbouring authorities, supplying markets outside of the county which require stones worked in Somerset. R93 but limit scale of development to reduce adverse impact on surroundings All development will need to be considered against policies in the Core Strategy and wider Development Plan. Taken together, these will set the limits to the scale of development that is acceptable.
Page 121 of 193 R97 Option a and b are really separate issues. Whilst additional activities at a Noted. quarry may improve viability it does not necessarily translate into supporting the use of local building stone. Option a and b should both be supported. R100 To maintain the character of many local villages more small building stone Noted. quarries need to be found that can match the locally needed stone
R103 Option a and Option b are not mutually exclusive and both options should Noted. The options were not intended to be mutually exclusive. be desirable in the context of sourcing stone and creating viable opportunities to maintain existing quarries.
R108 Both Options should be developed and are not mutually exclusive. Noted. The options were not intended to be mutually exclusive. R109 Paragraph 7.22 refers to new building stone quarries. It should also explain The Core Strategy will recognise the pro’s and con’s of extensions to that existing quarries need to be extended from time to time and policy existing and former sites as well as permitting new workings. In all should support extensions of existing quarries provided that they meet the circumstances application will have to meet environmental policies Council's environmental policies. It should be noted that need is often contained in the Core Strategy. Minerals Policy Statement 1 states a difficult to determine where a type of stone has not been quarried in recent preference towards extensions to existing quarries. years and there is no record of previous output. It takes a number of years following the opening of a quarry and offering stone on the market before While need is difficult to determine, stakeholders such as conservation officers, architects and builders accept that the availability of conservation officers, local builders, architects, district planners and a local stone will in future be consistent, reliable and offered on a geologists can provide a good indication of stone types that may be dependable commercial basis. Option a should state, "....and develop required in the future. Projects such as the English Heritage policy in support of new building stone quarries where a current or future Strategic Stone Study and responses to the Options consultation can need for the stone can be demonstrated". Also, activities and new help inform possible need. products that could be developed at building stone quarries to enhance economic viability should include the development of stone waste for The wording of option a will be considered. specialist products. The use of stone for agricultural purposes (tracks, roads, animal bedding etc) is usually not possible from Somerset's The development of stone waste for products will be considered, abrasive carboniferous limestone aggregate quarries and planning policy however the importation of waste to restore the land will need to be should not automatically prevent the potential to allow waste stone to be weighed up against all potential impacts and be in accordance with sold. The restoration of building stone quarry sites should also be national policy – mechanisms to address this will be considered. considered using imported waste to return the land to its original levels.
Page 122 of 193 R110 Option a should be supported to affirm the importance of building stone for As identified by the British Geological Survey there are two needs for maintaining local character. We would also support new building stone stone now and in the future: 1) Traditional stone is used in the repair quarries where a current or future need for the stone can be demonstrated. of historic buildings and new traditional build. It forms the structure With regard to Question 21 Option b it is essential, in operating a stone and construction of buildings; 2) Modern construction industry uses production business, to be able to offer the potential customer a wide stone for decorative purposes (as a veneer) not for structural or range of stone and stone products. If, at our West Cranmore Quarry in constructional purposes. To maintain the economic viability of Shepton Mallet, we were only permitted to sell the stone which is quarried building stone operations the Core Strategy will consider the on site, our business would not survive. We would simply not be able to maintenance of both markets. The Core Strategy will aim to ensure operate and our skilled workforce and the economic activity which our this is delievered with due regard to the principles of sustainability business generates in this rural area would be lost. Unless a customer and while the importation of stone to help maintain the economic can be offered different stones, including those from different counties and viability and range of stone products at building stone sites is some from different parts of the world, at a recognised outlet such as West understood, priority and overall support will be given in the Core Cranmore Quarry the customer will go to the national retail providers who Strategy to local supply for local demand. specialise in imported stone products from China, India, Brazil and other producing countries. A one product quarry cannot compete in the market against such competition. It is essential in helping local business that the County Council supports not only the quarrying of local stone but the The Core Strategy will aim to maintain flexibility so that economically development of the stone production businesses which go with it. Flexibility viable operations can continue but there will be a strong emphasis on in the importation and retail sale of imported stone together with local stone for local demand and sustainable operations. Support will indigenous stone at quarry outlets is essential. Our business, unlike any be considered for masonry aspects of building stone quarrying and other business, is typically restricted by planning permission to operate the additional activities that are important to operational viability. from temporary quarry bases. This limits the length of time that we can operate. In turn this restricts investment, reduces work and career opportunities, constrains the development of related businesses and The development of stone waste for products will be considered, service industries and overall, it impedes the development of a strong however the importation of waste to restore the land will need to be traditional industry. Somerset's policies of supporting the quarry industry weighed up against all potential impacts and be in accordance with are to be applauded but support must also be extended to the masonry national policy – mechanisms to address this will be considered. and product development businesses by supporting the infrastructure relating to the quarry industry and permitting permanent sites for the production of natural stone products. Without political support for stone The use of building stone for is primary purpose and ancillary quarry producing companies, Somerset's natural stone quarry industry, which activities, such as site restoration, will be prioritised over any crushing works our rich and diverse range of natural stones, would probably not of stone – in line with national policy. The use of overburden, survive. Furthermore, in answer to Question 21 Option b, activities and interburden and offcuts etc will be looked into during the development new products that could be developed at building stone quarries to of the Core Strategy. enhance economic viability should include the development of stone waste for specialist products. The use of stone for agricultural purposes (such as tracks, roads, animal bedding etc) is usually not possible from Somerset's abrasive carboniferous limestone aggregate quarries and there is a market
Page 123 of 193 for the softer stone, which does not damage the feet of farm animals, which could be developed if planning policy were to be relaxed. A further use of stone waste is to crush it to produce a dust which is suitable for use in mortars. It is important to use a mortar which is compatible in colour, shade and texture with the stone which is being laid. Currently planning policy automatically prohibits the potential to allow waste stone to be utilised. This results in huge costs to the operator who must keep moving potentially thousands of tonnes of waste in the quarry to access the stone faces. That needlessly serves to make the operation less profitable and less viable. The waste overburden and interburden material and offcuts lying in the quarry should be developed for the valuable resource which it is. If the waste material is not used, the customer will seek this from other sources which could result in the far less sustainable option of hauling the material much longer distances from quarries where waste is permitted to be utilised. The restoration of building stone quarry sites should also be considered using imported waste to return the land to its original levels. R111 We support the Minerals Options Paper's comments in relation to Noted. safeguarding supplies of building stone and the importance of small, long establised and even dormant quarries. These are important for sources of building stone with which to repair historic buildings and construct new buildings in appropriate locations. We would support small-scale working of specialist building stone subject to environmental constraints and safeguards.
R115 I support both Options a and b. Some building stones are highly specialist Noted. and likely only to represent a 'niche' market. These are only likely to need a small-scale quarry source. (See Question 22 below)
R116 Town & Countryside character need to be maintained such as in the Noted. Hamstone villages of South Somerset
R117 obvious Noted.
Page 124 of 193 R118 We think it is best to always use the appropriate coloured stone for the It is important to use stone that has the same structural and aesthetic locality that a building project is taking place. We are a very small quarry properties. with a considerable amount of capitol invested to produce a quality building stone, and if you were to allow other quarries to open with the same Consideration will be given to the number of building stone quarries coloured stone then you could find that they all became unviable and end supplying the same type of stone. The need for that type of stone up with no local stone. We feel that this could be a problem with any type and products supplied will be taken into account. of stone where only small quantities are extracted. R119 The options a & b are not mutually exclusive. I support the statement in The options were not intended to be mutually exclusive. Any option a, but in some cases additional activities may be appropriate at potential additional activities will be appropriately considered and quarries to help sustain them economically. (Note: This comment was addressed in the Core Strategy. made earlier in a separate response by Adron Duckwoth Conservation Manager, SSDC)
R126 Both options are strongly supported. Small building stone quarries need to Noted. be able to provide many products and services to customers in order to survive. Customers in this market want choice of stone and a variety of different processing options. R127 Option B whilst supporting quarries on a small family run scale. Noted.
Question 22: Which building stone types are in short supply or unavailable in Somerset? Please provide specific examples, if known, of inappropriate stone use in sensitive locations.
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 None that we know of Noted. R13 No comment No comment R15.1 With the exception of Ham, Doulting, and the Lias Quarries plus limited Noted. extraction of Capton Sandstone and Forest Marble, there is little available except possibly the Inferior Oolite as a byproduct of limestone quarrying. Two shortfalls are Otter Sandstone (Milverton) and the Dolomitic Conglomerate.
Page 125 of 193 R18.2 Details not known but all should be made available. Noted. Only stones for which a need and market exist will be supported to be worked. It would not be sustainable or in line with national policy to make every type of building stone available. R35 N/A to Binegar Parish No comment. R47 Marlstone, Calcareous Grit, White Lias. (I am not sure if Bowdens will ever Noted. be useful (faulting and dips and overburden). There maybe something in the wind at Camel Hill.
R57 There are numerous types of stone which may be used for building Noted. purposes in Somerset. It is not possible to list all which may be considered for planning permission but quarrying any type of stone should be considered where it has been used for construction in the recent or historic past. Each application should be considered on its merits.
R60 There are many examples of Blue Lias stone being used for repair, The Core Strategy will support the correct use of stone and supply of extensions or new-build, in areas where traditionally White Lias was used, local stone for local demand for which an identified need exists. and this has changed the character of many buildings and villages in Somerset and is therefore inappropriate. Hamstone is widely used for repair, extensions and new-build in many villages in South Somerset, such as Barrington, South Petherton and Dowlish Wake for example, as an alternative stone to those used historically (such as Petherton and Moolham stones) but which are no longer available. Hamstone lacks the intensity of colour of the local stones and is changing the character of these villages. (photos available if required). In research carried out concerning a safeguarding proposal involving establishing a hierarchical approach (for EH/Derbyshire CC by the National Stone Centre) the same Support will be given to stone markets outside of the County which methods were briefly applied as a test, to Ham Hill stone. This depend on Somerset sources of stone. demonstrated that the stone had greater than local significance but could not claim national status - it had demonstrable &;regional? significance.
R61 Building stones that feature in South Somerset that are not available are Noted. Calcerous Grit, Chert, Marlstone, Upper Lias Limestone (Junction Bed or Yeovil stone), Inferior Oolite, Cornbrash Limestone and Shaftesbury Sandstone.
Page 126 of 193 R65 The survey by English Heritage provides the answers by highlighting the Further work will be completed on the viability of identified historical quarries no longer in operation. As to compatible alternatives for stones no sources of building stone, thereby informing the Core Strategy. longer available, this would require the services of a geologist and a test regime to find and evaluate other stones. (This may be worth consideration). R75 Red sandstone (ironstone) for Minehead and surrounding area Noted. R80 No comment. No comment. R81 Some developers use Lias which exfoliates. The only advantage is Buildings have character due to the type of stone and masonry skills exfoliation prevents moss growth. Some stone has good environmental and techniques used, therefore providing a local identity which often characteristics, for example natural heat sink, or air conditioning. But I am results in areas being designated as conservation areas, and reluctant to say. The only reason why many buildings have a characteristic resulting in buildings being designated as historical monuments. is they are 'local'. Easy accessible. That's the only reason. However as time has changed building ideas in some planet regions, not so here.
R82 Doulting stone. Bath stone. Noted. R85 I have no knowledge of this. No comment R86 Dont know No comment. R97 This is too technical a question for most respondents. Noted. R100 Wedmore Stone Noted. R109 There are numerous types of stone which may be used for building Noted. purposes in Somerset. It is not possible to list all which may be considered for planning permission. Each application should be considered on its merits.
R110 There are numerous types of stone which may be used for building Noted. purposes in Somerset. It is not possible to list all which may be considered for planning permission but quarrying any type of stone should be considered where it has been used for construction in the recent or historic past. Each application should be considered on its merits.
Page 127 of 193 R115 Issue BS1: Question 22. Two very general categories of building stone Noted. may be recognised in Somerset: A) Building stones required for both new build and ongoing conservation and restoration at fairly 'large scale' amounts. Several of these stone types, such as Blue Lias, Doulting Stone and Ham Stone have existing quary sources with sufficient reserves; B) Building stones required mainly for ongoing conservation and restoration work, or for building on a relatively small scale. This category includes 'niche-market' stones such as Draycott Marble, Wedmore Stone, Devonian limestone but typically the former source quarries have been long abandoned, become overgrown or lost. Further selected examples of each of these types is provided in the Table attached to this representation. This list is not exhaustive.
R116 Ham Stone Ham Stone is currently worked in two sites in Somerset and to date no identification has been made that it is in short supply. R117 not known No comment. R119 Building stones that feature in South Somerset that are not available are Noted. Calcerous Grit, Chert, Marlstone, Upper Lias Limestone (Junction Bed or Yeovil stone), Inferior Oolite, Cornbrash Limestone and Shaftesbury Sandstone (Note: This comment was made earlier in a separate response by Adron Duckwoth, Conservation Manager, SSDC)
R124 Doulting stone? Noted. R125 Both Blue Lias and White Lias are in short supply. In the case of Blue Noted. Lias, there are several small Blue Lias quarries operating on a very small scale which struggle to meet demand. Blue Lias comes in several forms. The bed heights vary between quarries and the colour is very distinctive, varying, from yellow-blue to grey-blue. Grey-blue matches the older type buildings and is used for conservation work in many local buildings such as many local churches:- Somerton Church, Glastonbury Abbey, Langport Church, Pilton Tythe Barn.
When buildings of grey Blue Lias require restoration, often other stone is used due to that lack if supply of grey Blue Lias. The attached picture shows a listed Dovecote at Curry Rival. Here yellow-grey Blue Lias has been used in restoration of the gable end to the detriment of the aesthetic integrity of the building. To be blunt, the wall looks dreadful.
Page 128 of 193
Question 23: What additional activity do you think could provide additional revenue and could be compatible with a building stone quarry?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 We would like to see more recycling Noted. This will also be supported via waste planning policy. R13 No comment No comment. R15.1 Possible developments include renewable energy generation and light Noted. industry, subject to consideration of environmental impacts.
R18.2 Recycling of building materials. Recycled aggregates. Nature Noted. Recycling will also be supported via waste planning policy. conservation. R25 The AONB Unit has no comments to make on this question. No comment. R35 N/A to Binegar Parish No comment. R36.2 7.26: Waste materials should not be exported as aggregate but retained Noted. Waste materials will only be supported to be exported for (by planned, phased working) for the restoration of the site. Should such other uses if it is considered appropriate to do so and if all other on material be exported as aggregate it should be subject to aggregate tax. site uses of the waste material have been considered.
R47 Additional activity ?? Additional activity means any activity in addition to the main quarry operations. R57 Activities which could provide additional revenue includes processing the Noted. The development of stone waste for products will be stone into high value architectural products which can be sold nationally; considered, however the importation of waste to restore the land will disposing of stone waste as aggregate or for specialist, perhaps need to be weighed up against all potential impacts and be in agricultural uses. The restoration of building stone quarry sites using accordance with national policy – mechanisms to address this will be imported waste should also be considered. considered.
R60 Whilst a certain amount of hardcore is likely to be produced, the emphasis Noted. Additional activities will be prioritised for the most appropriate should be on additional products that encourage careful extraction of the end uses, thereby not wasting the stone. stone (such as worktops and fireplaces) so as to reduce the attractiveness of crushing good building stone for aggregate.
Page 129 of 193 R65 In the website MOC, suggestions are put forward as to additional activities, Noted. provided they do not impact on the wining of building stone from the quarry it is not possible to give definitive answer to these questions.
R72 Recycling of demolition materials. It would only be appropriate to recycle reclaimed building stone. Recycling will also be supported via waste planning policy. R74 Manufacture of steel mountings and frameworks for cladding Additional activities relating to building stone will be prioritised over anything else. R75 Education facilities Noted. R80 No comment. No comment. R81 Ah, so now we have it - it's money - eh? If the material used in building is This question has been posed to collect representations from limited, then any further use - recycling - is limited. If greater use of other stakeholders as to what activities could potentially be viable and materials is allowable, this could increase re-cycling. In fact I don't see appropriate to help maintain the economic viability of building stone much recycling of building material. Plenty of hard core (for engineers) - sites, which can struggle in comparison to other minerals. This but very little for the home owner. A cultural problem - everything has to be question not only considered the recycling of building stone but any new? activity related to building stone operations. Recycling will also be supported via waste planning policy.
R82 Rock climbing. Noted. R85 No relevant knowledge. No comment. R86 Prduction of reconstituted stone for building Noted. R91 Types of man made stone blocks. Types of gravel for pathways. Types of Noted. fencing for gardners. Types of garden ornaments.
R93 supply of surplus waste materials for agricultural tracks, storage and Noted. Additional activities will be prioritised for the most appropriate reworking of salvaged natural stone, and high value, small volume end uses, thereby not wasting the stone. products developed for sale (to order) beyond the local market, such as kitchen worktops or fireplaces (not production of aggregate or reconstituted stone)
Page 130 of 193 R97 This depends on the quarry and its location. There should be general When considering additional activities all aspects of the respective support for additional activities and any proposals should be considered on site will have to be considered. Additional activities will be supported their merits however unless the planning system will allow some flexibility where in accordance with national policy and policies included in the additional activities are likely to be refused. Examples of additional Core Strategy. activities include: improved cutting/dressing facilities, importation of other building stones for cutting/dressing and for sale, open storage.
R109 Activities which could provide additional revenue includes processing the The development of stone waste for products will be considered; stone into high value architectural products which can be sold nationally; however, the importation of waste to restore the land will need to be disposing of stone waste as aggregate or for specialist uses such as weighed up against all potential impacts and be in accordance with agricultural tracks. The restoration of building stone quarry sites using national policy – mechanisms to address this will be considered. imported waste should also be considered.
R110 Activities which could provide additional revenue is answered above and The development of stone waste for products will be considered; includes processing the stone into high value architectural products, however, the importation of waste to restore the land will need to be processing imported stone, offering a wide range of stone products which weighed up against all potential impacts and be in accordance with can be sold nationally; disposing of stone waste for specialist uses and national policy – mechanisms to address this will be considered. restoring building stone quarry sites using imported waste.
R115 Some local building stones have potential use as ornamental stone and Noted. take a good polish, in addition to their 'basic use' primarily as a stone for restoration or conservation purposes. For example, Draycott Marble, or some harder facies of Forest Marble and Marlstone. These may only be applicable for interior work or decoration, but with appropriate promotion and marketing, these stones could provide additional revenue. The cutting and polishing facilities required for ornamental work are highly compatible with 'normal' building stone quarry operations. The extraction of many building stones is likely to be on a small-scale, perhaps a few thousands of tonnes annually and at times the quarry is likely to be non operational, or relatively quiet. This may enable the use of some site for recreational purposes, especially in limestone rock types which may be suitable for activities such as rock-climbing, pot-holing, caving etc.
R116 Artificial Stone Noted. R117 not apparent Noted.
Page 131 of 193 R119 SSDC support the suggested list of alternative activities that could be Noted. considered include; small scale aggregate production for ornamental use, supply of surplus waste materials for agricultural tracks, reconstituted stone products, storage and reworking of salvaged natural stone, and products developed for sale beyond the local market, such as kitchen worktops or fireplaces.
R123 On site stone carving, stone masonry schools/apprenticeships. i.e. Noted. Doulting Stone Quarries.
R124 Apprenticeships/stone carving schools on site e.g. Doulting Quarry. Noted.
R126 Masonry, carving, polishing, cutting, sawing, dressing are all processes Noted, that add value to the stone and add appropriate choices for the customer. Some importation of inert building rubble could ensure that appropriate site levels are left at the end of the quarry’s life. R127 College or training centre. Noted.
Question 24: What factors should be considered by the Minerals Planning Authority when determining whether additional activities are appropriate?
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 They must consider the local environment Noted. R13 In line with national policy and guidance, full appraisal of ecological Noted. impacts, their scale and significance should be considered, along with opportunities to avoid or mitigate harm, and generate biodiversity enhancement should all be considered.
Page 132 of 193 R15.1 All environmental and societal impacts must be considered. Noted. R18.2 Nature of the minerals present. Transport infrastructure and other Noted. sustainability issues. Proximity of the site to residential areas. The prominence of the site and the its ability to be screened by landscaping. The proximity of the site to where the materials are likely to be used.
R25 The AONB Unit has no comments to make on this question. No comment. R35 N/A to Binegar Parish No comment. R47 Appropriate, demand and cost of extraction. Noted. R57 Each application should be considered on its merits. Noted. R60 The local authority should consider the likely scale of demand for particular These comments will be borne in mind when completing further buildings stones, by reference to the numbers of listed buildings and research into the likely demand of particular building stones and conservation areas in which the stone is used, but should be careful not to identifying potential areas of supply. equate level of demand with the importance of the stone for conservation. In most cases, alternatives to a particular stone that was used historically are unlikely to be acceptable for aesthetic or technical reasons. Where a proposal is for a stone type that was only used in a limited area historically, demand for that stone from conservation and new build is likely to be low, so additional activities may be needed in order to make extraction viable and to ensure a supply for repair and new build in sensitive areas. The local authority should also bear in mind that some of the stones for which there is the most pressing need might be stones that, by today’s standards, are not considered very durable or good quality, since buildings made of such stone may have greater conservation needs than those made of more durable stone. As such, more uncertainty is likely to be attached to extraction and meticulous selection may be necessary. Such stones may therefore be less attractive and have a limited market for new build, so in order to ensure a supply for conservation, additional activities are likely to be needed. R65 In the website MOC, suggestions are put forward as to additional activities, Noted. provided they do not impact on the wining of building stone from the quarry it is not possible to give definitive answer to these questions.
R74 Economic Community (emploment etc) Skills Environmental impact Noted.
Page 133 of 193 R75 Amount of new development proposed. Amount of building likely to need Noted. stone repairs
R80 No comment. No comment. R82 Loss of local amenity. Local consultation. Traffic. Benefit to local Noted. communities and businesses.
R85 Can a viable use be identified. Can work be carried out without serious Noted. and detrimental impact locally.
R86 Size of quarry required.Noise and local disturbance Noted. R91 Easy site access. Noted. R92 Environmental above all. Noted. R93 Scale, benefit to local area/community in income, jobs etc, minimising Noted. impact on local area and carbon footprint
R97 Whether the additional activities are related to the production and sale of Noted. building stone. If the additional activities are not related then if they make use of parts of the site that are not required operationally and do not cause unacceptable impacts on the environment/local amenity.
R103 The resulting environmental impact should form part of any consideration. Noted. R109 Each application should be considered on its merits. Noted. R110 Each application should be considered on its merits. Noted. R115 Factors which could influence the location of local building stone quarries Noted. include: - detail of stone type available, possible resource levels, accessibility of site, transport, proximity of local community, environmental considerations and wildlife designations. R116 Employment & the enviroment Noted. R117 locality and impact on local community Noted. R119 Agree with statement that additional output must not result in poor quality Noted. restoration or unacceptable impact on the local community or environment.
Page 134 of 193 R123 Water issues. Dust issues. Noise issues. Light pollution. Effect of blasting. Noted. Air/ground vibrations = damage.
R124 Always – noise issues, dust issues, light pollution. Noted. N.B. water issues/sources and aquifer. Blasting – monitoring air/ground vibration. R126 Given the difficult economic nature of small building stone quarries, the Additional activities would only be prevented if they were not need for their products and the rural employment that they provide; it is acceptable in environmental and sustainable terms, and did not hoped that very strong reasons would have to be found to prevent any adhere to national or local policy. additional activities in a proposal. R127 Traditional skills maintained, Environmental impact, Size, Assess, Noted. Longevity of site.
Page 135 of 193 5 Mineral Safeguarding Areas
Which minerals are to be safeguarded? It is proposed that for the purposes of safeguarding all minerals currently worked should be safeguarded for the future:
• Carboniferous limestone (consider separately aggregate and industrial-grade resources); • Silurian andesite;
• Blue Lias;
• White Lias; • Budleigh Salterton Pebble Beds
• Inferior Oolite • Forest Marble • Cornbrash
• Ham Hill Stone • Sand and gravel (recent and Permo-Triassic)
• Peat.
In addition minerals that have not been worked for a while, but that may become economic again are: • Brick clay: proximity of source to use from the perspective of both sustainability and transport cost. Shallow working – could be suitable for prior extraction where a sufficiently large construction area is planned. • Shallow coal: national energy minerals increasingly given consideration given our dependence on energy minerals from other parts of the world, including politically unstable areas. Could be suitable for prior extraction where sufficiently large construction area is planned.
• Building stones identified in historic buildings but not currently being worked will be required for maintenance at some point in the future. • Devonian Sandstone with high polished stone value – comparable with the Silurian andesite with regards to end use as roadstone. Entirely located within the Quantocks AONB and recently worked sites are sited on small country roads which are not suitable for quarry working. There are no proposals to reopen historic sites. However, these materials are important for maintaining safe road surfaces and may become important in the long term as more environmentally acceptable sites are worked out.
Page 136 of 193 Question 25: Do you agree with the mineral types listed for safeguarding? Are there any others you would include?
Summary of responses to question 25.
12% (2 responses)
Agree Disagree
88% (15 responses)
Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R9.3 We are happy to endorse the mineral types listed for safeguarding. Noted. R13 No comment. No comment. R15.1 We agree with the list, apart from the inclusion of peat, but suggest that If the current approach of the Draft National Planning Policy Draycott Stone could be added. Framework is adopted then the entire peat resource on the Somerset Levels and Moors would most likely not require safeguarding.
Page 137 of 193 However, current permissions and therefore the Peat Production Zones and Areas of Search would need to be safeguarded to ensure that they are not affected by other development as peat use and extraction is phased out in line with Government targets. R18.2 Exclude peat and safegaurd it being left where it is. Devonian sandstone - If the current approach of the Draft National Planning Policy as above. Framework is adopted then the entire peat resource on the Somerset Levels and Moors would most likely not require safeguarding. However, current permissions and therefore the Peat Production Zones and Areas of Search would need to be safeguarded to ensure that they are not affected by other development as peat use and extraction is phased out in line with Government targets. R22.1 It is welcomed that aggregate recycling facilities are to be considered for Noted. safeguarding. Cooperation with the district councils and the Waste Policy Team should help in identifying relevant sites.
R25 The AONB Unit has no comments to make on this question. No comment. R34 There should be no need to safeguard peat or carboniferous limestone If the current approach of the Draft National Planning Policy (except if it is used for building, rather than as aggregate). Framework is adopted then the entire peat resource on the Somerset Levels and Moors would most likely not require safeguarding. However current permissions and therefore the Peat Production Zone and Areas of Search would need to be safeguarded to ensure that they are not affected by other development.
The carboniferous limestone in Somerset will be safeguarded due to its national, regional and local importance. However, due to the geographical extent of the resource, it is most likely that the entire resource will not be safeguarded – all stakeholders will be given the opportunity to input into the determination of safeguarding areas. R35 No others Noted. R40 Assuming that the reference to Permo-Triassic in relation to sand and Both the Permo-Triassic sand and gravel deposits and Budleigh gravel includes the Budleigh Salterton Pebble Beds, the list in paragraphs Salterton Pebble Beds are listed for safeguarding in para 9.7. 9.7 and 9.8 is supported. Devon County Council will be safeguarding the Pebble Beds resource on the Devon side of the county boundary to ensure a 'joined-up' approach.
Page 138 of 193 R41 We are pleased to see that the andesite is listed as a mineral to be Noted. safeguarded. We completely support the point raised in paragraph 9.23 that "the Silurian andesite is limited in extent and is a strategic source of road surfacing material and therefore should be safeguarded in its entirety". R43 Yes. Noted. R44 Yes Noted. R47 Calcareous Grit Marlstone. Noted. This will potentially be safeguarded along with all other building stones that are currently being worked and identified as being in short/no supply. R60 We agree with the list suggested, subject to the reference to building Noted. stones being expanded to take account of the comment above.
R75 Yes Noted. R80 Agree. Noted. R81 Soil, is soil a mineral resource? Soil is not a mineral resource. R84 The Coal Authority supports the recognition that the surface coal resource Noted. The Core Strategy will take into account these comments. should be safeguarded. The Coal Authority would wish to see the entire National and local policy, and local circumstances will be considered surface coal resource present within Somerset safeguarded within a MSA. in determining any decisions taken on prior extraction. The wording indicated in relation to prior extraction is welcomed as a general concept. The Coal Authority supports the prior extraction of surface coal resource where non-mineral surface development is proposed. The Core Strategy does however give the wrong impression that prior extraction can only be undertaken 'where sufficiently large construction area is planned'. This is in fact not the case, prior extraction can take place easily within densely urban and rural areas on sites of all scales, the smallest recorded site was only 0.04Ha with numerous schemes taking place from 0.2Ha upwards. The prior extraction of surface coal resources can therefore take place cost effectively on small sites and the Core Strategy should reflect this in policy when this is developed.
R85 No relevant knowledge. No comment.
Page 139 of 193 R86 Yes and NO Noted. R87 agree Noted. R91 Yes. Doulting Sandstone. Noted. Doulting stone is a form of limestone. R93 Draycott marble Good quality soil/agricultural land Good quality soil/agricultural land is not a form of mineral and is protected under the agricultural land classification. R100 Wedmore stone Noted. R102 We agree with the list of minerals set out in paragraph 9.7 that will be Noted. safeguarded. There is a strong case for safeguarding the minerals in paragraph 9.8, but further assessment may be needed to establish whether a reduced area would be more suitable for safeguarding.
R105 We support the idea of a safeguarding area for Ham Hill Stone. The stone Noted. is actively quarried at 2 sites, old faces are used by climbers, act as key bat roosts and are key teaching resources for school visits. The stone is vital to the country park and it has defined the history of the site through pre history to current land use. The stone should be protected and all Any application to extend a quarry will be considered in respect to its applications for extensions to quarries should carefully consider the impact surrounding landscape and environmental designations and uses. on the country parks' users, the historic land surface (Scheduled Ancient Monument) and also the wildlife of the site (Higher Level Stewardship Scheme). The large Ham Hill South quarry operates on private land and recent archaeological excavations have provided extensive opportunities for learning, by all ages, and academic study of the Scheduled Ancient Monument. As part of the geological SSSI notification the operator here is being asked to aim to retain a full length face exposure illustrating all the sedimentary layers of Ham Hill Stone when quarrying ceases in the currnt area. Ham Hill north is a smaller operation, in the busiest and publically accessible area of the Country Park and creates a range of different problems for management by the on site countryside ranger team. The stone resource in the existing Ham Hill North area must be soon be If the stone resource at Ham Hill becomes exhausted and any coming to an end and we would support a decision to prevent any further subsequent planning application is submitted to continue or extend exploitation of this area predominantly from a public safety and landscape working is received, it will be considered against the need for the point of view. Ham Hill Country Park is famous for it internal lumps and stone and the potential impacts of the development. bumps and certainly the old Victorian and some Medieval quarry waste heaps hold significant heritage value and we believe that those remaining should be left in situ.
Page 140 of 193 R106 It is not practical to safeguard the entire geological deposit of all minerals Noted. Safeguarding areas will be appropriate in their size and that are currently being worked or may become economic again when the locations, taking into account the demand and level of supply for extent of the deposits is so widespread. If the extent of the deposit was each mineral. For example, the carboniferous limestone in Somerset small and isolated such as for sand and gravel, or of a particular type of will be safeguarded due to its national, regional and local importance. stone such as the igneous basalt material worked at Moons Hill then the However, due to the geographical extent of the resource, it is most entire deposit could realistically be safeguarded. The deposit of likely that the entire resource will not be safeguarded. All carboniferous limestone is extensive in Somerset, as are a number of stakeholders will be given the opportunity to input into the building stones deposits. There is probably sufficient carboniferous determination of safeguarding areas. limestone to quarry for many, many generations. It does not all need to be safeguarded. The problem with safeguarding almost everything and therefore reviewing all contrary planning applications is that all applications will be allowed unless they are close to existing quarries or Preferred Areas. How can an application for, say a new house in a Greenfield location, sitting on limestone, but miles from the nearest quarry, ever be refused? How can extraction in advance of a competing development ever be required for limestone deposits? The result is that no one will ever pay any real attention to the safeguarding policies, they will be diluted and ineffective. Only when an application is close to a quarry/Preferred Area or limited geological outcrop will Safeguarding ever be likely to be enforced. Consequently safeguarding should be restricted to a zone around existing The Core Strategy will identify clear and understandable quarries and limited geological deposits such as basalt or sand and gravel safeguarding areas. Whether or not this is on a site by site basis, or (and Preferred Areas if there ever are any). Such zones around quarries on a more general scale is under sided. However, all stakeholders are already identified in the existing Minerals Local Plan. A finite, clear will be given the opportunity to input into the determination of and understandable zone is much more likely to be applied and be safeguarding areas. effective. R107 Yes. First, CoalPro wishes to suggest an amendment to para 8.1. The The UK Renewable Energy Roadmap written by DECC in July 2011 presumption against in the draft NPPF is a retention of the presumption shows a clear direction to increasing the amount of renewable and against set out in MPG3 which was issued in 1999. There were various cleaner energy generation by 2020. The Report quotes that reasons for this but there was not then, and there is not now, any “Securing renewable sources of energy is a key pillar of the UK indication that it in anyway relates to a government preference to see Government’s strategy for a diverse, low carbon energy system energy supplied by cleaner alternatives. Para 8.1 should be amended alongside nuclear, cleaner coal and gas, and energy efficiency”. accordingly. With respect to para 9.5, CoalPro does not feel that there is any need to go beyond the designation of the Mineral Safeguarding Area Comments in relation to para 9.5 are noted; there is no proposal, at for shallow coal, i.e. it is not necessary to identify an Area of Search, this time, to go beyond the designation of the Mineral Safeguarding Preferred Area or Specific Site. CoalPro is pleased to note that in para Area for shallow coal. 9.8, the potential for prior extraction of shallow coal is recognised. The minerals plan should make provision for the potential to process old tips to Due to the need to move towards renewable energy alternatives and recover coal. cleaner energy production, it is not expected that the Core Strategy
Page 141 of 193 will make provision for the potential to process old tips to recover coal, unless national policy states otherwise – more research needs to be completed in this area.
R108 Yes - agree Noted. R111 We support the Minerals Options Paper's comments in relation to Noted. safeguarding supplies of building stone.
R116 I believe the importance of our groundwater resouces is wrongly Water resources are not ignored or excluded. They are not a mineral completely excluded. The importance of natural year round springs is and therefore will not be safeguarded under a mineral safeguarding ignored. area. The County Council understands and recognises the importance of Somerset’s water resources, especially the groundwater in the Mendip Hills. Water resources will be addressed in the Core Strategy, similarly to the adopted Minerals Local Plan. And the County Council will continue to work with other organisations such as the Environment Agency in the protection of our natural resources. R117 not known No comment. R119 Support list of proposed minerals types and in particular Ham Hill Stone Noted. that is relevant to the village vernacular in South Somerset.
R123 Yes. Greenstone. Newly discovered and Mendip (E) fossils, minerals and Technically 'Greenstone' refers to a basic, coarse-grained, igneous rocks – regular surveys of the rack face should be carried out for rock. These rocks don't strictly occur in Somerset. This has been geological purposes and palaeontology research. checked and the County Council are believe that the respondent is referring to part of the Silurian outcrop of volcanic rocks and lavas (technically called 'tuffs' and 'andesites'; within the Coalbrookdale Formation on the BGS map sheet) that occur near Stoke St Michael (east of Shepton Mallet), and by Old Wells Road. These igneous rocks are used very locally and on a very minor scale as building stone (an occasional walling stone etc); they are mainly crushed and used as aggregate. The existing quarry at Moons Hill works this strata and stone, so it is believed that we have plenty of the resource available.
Rock faces are surveyed by mineral operators throughout the
Page 142 of 193 operational period of sites.
R124 Yes. Greenstone newly discovered – south of Old Wells Road. Technically 'Greenstone' refers to a basic, coarse-grained, igneous Fossils – minerals and rock – geological interest. rock. These rocks don't strictly occur in Somerset. This has been Regular survey of newly blasted rock face on an academic basis. checked and the County Council are believe that the respondent is referring to part of the Silurian outcrop of volcanic rocks and lavas (technically called 'tuffs' and 'andesites'; within the Coalbrookdale Formation on the BGS map sheet) that occur near Stoke St Michael (east of Shepton Mallet), and by Old Wells Road. These igneous rocks are used very locally and on a very minor scale as building stone (an occasional walling stone etc); they are mainly crushed and used as aggregate. The existing quarry at Moons Hill works this strata and stone, so it is believed that we have plenty of the resource available.
The minerals planning authority are not aware at the time of Greenstone and will look into this. Rock faces are surveyed by mineral operators throughout the operational period of sites. R125 The mineral types listed for safeguarding is agreed with. The safeguarding Noted. Safeguarding areas will be appropriate in their size and areas should be fairly discrete and practical in that they are indeed location, taking into account the demand and level of supply for each safeguarding mineral that is likely to be useful in the foreseeable future. If mineral. For example, the carboniferous limestone in Somerset will safeguarding areas are too big, they are simply ignored. be safeguarded due to its national, regional and local importance. However, due to the geographical extent of the resource, it is most likely that the entire resource will not be safeguarded. All stakeholders will be given the opportunity to input into the determination of safeguarding areas.
Page 143 of 193
Buffers It maybe necessary to add a buffer to a Minerals Safeguarding Area to protect both mineral resources from sterilisation and future residents from unwanted impacts. The buffer will depend on the mineral type and therefore extraction method, eg. hard rock requiring blasting will need a larger buffer than say machine-dug sand and gravel resources. Current policy in the Minerals Local Plan has allowed a minimum buffer around existing minerals workings as shown in Table 1 below.
Mineral Working Minimum Buffer Peat sites and building stone quarries 100m
Low-output aggregate quarries 200m (<250,000 tonnes/year)
Higher-output aggregate quarries 400m Table 1: Buffer zone for minerals extraction sites
Question 26: Are the buffers listed appropriate? If no, please propose alternative buffer distances with justification?
Summary of responses to question 26.
40% (6 responses) Yes
No 60%
(9 responses)
Page 144 of 193 Detailed Responses
Rep ID Respondents’ comments MPA Officer responses R2 We believe these distances are inadequate Noted. R13 No comment. No comment. R15.1 We do not disagree with the extent of the buffers for building stone and Noted. aggregate quarries, but please note our concerns (Question 27) in relation to peat sites.
R18.2 Building stone - 200 mts rather than 100 mts due to noise issues. Low These comments will be taken into account. However, it is noted that level aggregate with little machinery - 200 mts may be ok with safeguards. 1000m for higher-output aggregate sites would be a significant High level aggregate production - 1000 mts due to high noise, dust etc. increase from current arrangements (the distance in the adopted Minerals Local Plan is 400m). R25 The AONB Unit has no comments to make on this question. No comment. R34 The buffer zones are inappropriate for aggregate quarries. The buffer zone Buffer zones are appropriate for all minerals and are placed around should be around development and no quarries should be permitted within quarries to protect sensitive neighbouring property from impacts 400m of villages, hamlets or houses. associated with quarrying and protect minerals from sterilisation. If safeguarding areas had no buffer zones then less mitigation measures would be in place. It would be harder to maintain a buffer around development, as housing and other development extents are always changing, whereas quarry boundaries are more of a permanent feature until a possible extension is applied for. R35 Yes but rock slope and quarry depth should also be considered. Gurney Rock slope and quarry depth do not have significant influence and or Slade quarry already has residential buildings well within the minimum impact on the extent of a buffer zone. Development can occur within buffer. In that circumstance additional protection is needed. close proximity to mineral safeguarding areas if it is considered to not unnecessarily sterilise economic mineral resource or conflict with mineral operations.
Page 145 of 193 R41 If a buffer zone is suggested between a safeguarded geological deposit and other forms of development it is possible that the same buffer might be The impacts of minerals development need to be considered on a used as a limit of working in the vicinity of a sensitive property. Using a case-by-case basis. Environmental assessment is indeed an blanket approach to a buffer zone, whether to safeguard a mineral deposit important and appropriate method to assess potential impacts of a or to safeguard another use, is unjustifiable. The only precise way of site on the surrounding environment and land uses. A safeguarding understanding how close to a quarry or safeguarded mineral deposit area may not only be the extent of a sites planning permission area, development may occur, or how close to a sensitive property could mineral the safeguarding area could be larger, therefore establishing a buffer working be undertaken, is through environmental assessment. Through zone around a safeguarding area not only ensures the protection of this tried and tested assessment process the impacts, particularly of noise, surrounding properties and land uses but also ensures that any dust, vibration and visual, can be objectively assessed and a suitable potential sterilisation of mineral is considered appropriately. All buffer can be determined on a site by site basis. We do not support the stakeholders will be given the opportunity to input into the application of a blanket buffer zone except as a trigger for further, site determination of safeguarding areas. specific investigation.
R43 Yes, a minimum of 250m for low-output quarries (<250kt/annum) and a Noted. minimum of 400m for higher-output aggregate quarries (>250kt/annum) appear to be sensible.
R44 Yes, a minimum of 250m for low-output quarries (<250kt/annum) and a Noted. minimum of 400m for higher-output aggregate quarries (>250kt/annum) appear to be sensible.
R60 We agree with the buffers proposed. Noted. R74 Greater distances are required Noted, this will be considered and discussed with stakeholders. R80 No comment No comment. R85 No relevant knowledge. Distances quoted seamed reasonable, but Noted. presumably be modified in individual circumstances if operators or communities have problems.
R86 Yes as far as I know Noted. R91 Yes. Noted. R93 The values seem to be minimal & if anything should be greater by 25 % This will be considered and discussed with stakeholders. R100 All buffers shoudl be 500m to help local residents Noted. However, this may not be appropriate in all cases.
Page 146 of 193 R103 In terms of noise and vibration and the protection of amenity the answer is yes. However, lower levels of noise and absence of vibration impacts, A safeguarding area may not only be the extent of a sites planning combined with the temporary sporadic nature of stone and peat working permission area, the safeguarding area could be larger, therefore may be accommodated with a stand-off buffer of less than 100m in some establishing a buffer zone around a safeguarding area not only cases. There may also be a need to consider revised buffer regions in the ensures the protection of surrounding properties and land uses but case of property developed and remaining under the control of an also ensures that any potential sterilisation of mineral is considered operator, as may be used by employees of a quarry. This point is linked appropriately. Stakeholders will be given the opportunity to input into with plan acceptance with the concept that lower expectations of amenity the determination of safeguarding areas. may justified under these terms and an attempt to clarify the conflict between MPS1 issues listed as statements 1 and 5 above. These points will be considered in discussions with stakeholders.
R106 The buffers are not appropriate or necessary for the entire mineral deposit For consistency if buffer zones are applied then they should be used unless the deposit is discreet and of limited extent. Buffers or zones for the entire geological resource identified for safeguarding. The should be provided around existing sites or groups of sites as these sites Buffer zones will be provided around existing sites and/or groups of will often continue working for many years or have potential for extensions. sites. The Buffer zones will be considered to be added onto the edge These buffer zones should be regarded as Safeguarding Areas and should of the identified mineral resource extent and collectively regarded as be larger than the distances identified in the consultation document. The Safeguarding Areas. All stakeholders will be given the opportunity to buffer areas used within the existing Minerals Local Plan are appropriate input into the determination of safeguarding areas. as they contain larger areas around groups of sites such as in the East Mendips.
R107 Yes. With respect to para 9.11, CoalPro considers that shallow coal Noted. resources in urban areas should be safeguarded, in line with the principle that prior extraction should be considered in the event of a redevelopment within an urban area.
R108 It may be more appropriate to have a larger buffer (say 1km) around the Noted. Stakeholders will be given the opportunity to input into the main production areas/quarries. determination of safeguarding areas.
R116 Yes Noted. R117 agreed Noted. R119 Consider that the proposed buffers are broadly fine but would suggest that Noted. they are applied on a site by site basis to take into account relevant constraints.
Page 147 of 193 R123 Due to the types of machinery varying – acoustics of different areas buffer Noted Stakeholders will be given the opportunity to input into the zone should be increased. Higher output aggregate quarries at least determination of safeguarding areas. 600m. Effect of blasting. R124 Due to introduction of new types of machinery and use of old equipment Stakeholders will be given the opportunity to input into the and introduction of new plants e.g. (wash plant) and loading activity at determination of safeguarding areas. higher higher output quarries at least 600m.
R125 It is suggested that a buffer of more than 400m is appropriate for a quarry Noted. Stakeholders will be given the opportunity to input into the whose output is greater that 250,000 tons out put and a buffer of 250m for determination of safeguarding areas. a quarry of less that 250,000 tons output.
Question 27: Do you have any concerns about the Minerals Planning Authority identifying areas for safeguarding?
Summary of responses to question 27.
48% (13 responses)
Yes No
52% (14 responses)
Page 148 of 193 Detailed Responses
Rep Respondents’ comments ID MPA Officer responses R15.1 We are concerned about safeguarding peat soils for possible extraction. If the current approach of the Draft National Planning Policy Please see our comments above the importance of retaining peat as a Framework is adopted then the entire peat resource on the Somerset carbon store. If no new peat permissions can be granted in the future, in Levels and Moors would most likely not require safeguarding. line with the draft NPPF policy, then this will not be an issue. However, current permissions and therefore the Peat Production Zones and Areas of Search would need to be safeguarded to ensure that they are not affected by other development as peat use and extraction is phased out in line with Government targets. R18.2 No other than the points about peat above. Noted. R25 The AONB Unit's main concern is in ensuring that the national importance All landscape designations will be considered in the identification of the Mendip Hills landscape is fully considered during the safeguarding process of the safeguarding areas. Stakeholders will be given the process. opportunity to input into the determination of safeguarding areas.
R35 To safeguard communities local Parish Council(s) should be included as a Local Parish Councils have been consulted in the development of formal consultee. minerals policy and will be included in the determination of safeguarding areas and will continue to be consulted in the future. R84 The Coal Authority would object to the removal of any areas of the defined Noted. geological resource (based on our supplied data) from the Mineral Safeguarding Area. As the document acknowledges it is not appropriate to remove urban areas or designated areas from MSAs, a MCA will also be required as Somerset is a two-tier area. R106 Areas for safeguarding should be based around existing quarry operations Noted. or small geological deposits as referred to above. Paragraph 9.13 - no safeguarding reference is made to asphalt and concrete plants even Safeguarding of production facilities and alternative materials is though they are referred to in MPS1. referred to in paragraphs 9.20 – 9.22.
R107 Coal Authority resource maps provide info on the spatial distribution of Noted. shallow coal resources. R116 Shale Gas is likely to be important. No thought given to the effects of Fracking has been acknowledged in Chapter 8 and will be addressed super fracking. in the Core Strategy as appropriate. Research is still on going into the effects of Fracking in the UK – being lead by the British Geological Survey. The emerging evidence on fracking and the
Page 149 of 193 potential for applications to come forward will be considered in preparing the Core Strategy, and a decision made as to whether it merits specific reference. R123 Hydro geological aspects. All of these issues will be addressed in the Core Strategy. However, Effect on water sources and aquifer. it should be noted the County Councils remit concentrates on its duty Interference with natural faults (new faults come to light as blasting as Mineral Planning Authority and is not responsible for technical continues). Night noise. geological matters that arise during the working of sites – operators have qualified geologists who lead on these matters and work within the Health and Safety Executive’s regulations. R124 Hydro geological aspects. All of these issues will be addressed in the Core Strategy. However, it Effect on natural water sources and the aquifer. should be noted the County Councils remit concentrates on its duty Interference with natural faults. as Mineral Planning Authority and is not responsible for technical Blast damage to properties. geological matters that arise during the working of sites – operators Night Noise. have qualified geologists who lead on these matters and work within the Health and Safety Executive’s regulations. R125 The minerals industry in general and the individual mineral operators in The minerals industry in general and individual mineral operators particular should be consulted about the exact boundaries of safeguarding have been consulted in the development of minerals policy and the areas. determination of safeguarding areas and will continue to be consulted in the future.
Would you like to be involved in defining the minerals safeguarding areas?
10 respondents replied explicitly stating that they wished to be involved in defining the minerals safeguarding areas. All of these respondents will receive a copy of the draft Mineral Safeguarding Areas Topic Paper which will outline the County Council’s approach to safeguarding. Comments on the draft Topic Paper will inform the final approach taken by the County Council.
Page 150 of 193 6 Development Management
Development Management Policies
The following list outlines the topics that Somerset County Council feel requires local policy guidance for minerals in Somerset in light of the draft National Planning Policy Framework: • Minerals operations and potential impacts located in or neighbouring to AONBs.
• Minerals operations affecting Sites of Special Scientific Interest or National Nature Reserves. • Mineral operations in local designations for example: County Wildlife Sites, Regionally Important Geological or Geomorphological Sites.
• Mineral operations and potential impacts and benefits to biodiversity/geodiversity.
• Minerals operations and potential impacts in areas of important landscape character, namely areas outside of World, European and National designations. • Protecting the Historic Environment including Listed Buildings, areas of known and proven archaeology, Conservation Areas, Historic Parks, Gardens and Battlefields, and Scheduled Ancient Monuments. • Mineral operations in areas of best and most versatile agricultural land. • Protection of Public Rights of Way. • Restoration and after use of minerals sites.
• Borrow pits. • Mineral operations and traffic.
• Minerals operations and dust, lighting, vibration and noise. • Minerals operations and alternative energy production. • Mineral operations and effects on the stability of neighbouring land and properties.
• Protection of water resources. • Sites for the disposal of minerals wastes. • Cumulative impact of mineral operations. Page 151 of 193 Question 28: Do you agree or disagree with the development management policies list? Please state why.
Summary of responses to question 28.
22% (5 responses)
Agree Disagree
78% (18 responses)
Page 152 of 193 Detailed Responses
Rep Respondents’ comments MPA Officer responses ID R8.1 The Agency must recommend the rewording of 'Protection of water The importance of securing improvements in terms of water quality resources' to reflect the importance of protecting both the quantitative and and quantity is noted. The County Council will work with the Agency qualitative aspects of ground and surface water. It should be noted that and other partners as appropriate. the Agency will seek to secure improvements in terms of water quality and quantity, and not simply protect current baselines. 'Mineral Include reference to SFRA as appropriate. workings/operations and their potential impacts in terms of flood risk' Reference should also be made to the Minerals and Waste SFRA and its Keep exemptions under review e.g. linked with quarry dewatering. use to inform specific proposals, unless they are <1.0ha in Flood Zone 1. Finally, it should be noted that the current exemption for quarry dewatering is likely to be removed at some future point.
R9.3 We are happy to support a specific policy on the Historic Environment. Noted. Included within this policy should be World Heritage Sites. We include some wording for more detailed policies for stone quarrying that you may wish to consider.
R13 We broadly agree. There are a couple of omissions we feel should be It will be important to ensure that the Minerals Core Strategy covers addressed. Firstly, European and internationally designated nature issues of importance locally without repeating national and/or conservation sites should be added to the list also. Secondly, in line with international policy and guidance. the draft NPPF, mention of Somerset's EcoNet could be made to reflect this approach to environmental conservation and ecosystem service Note terminology distinction between County Wildlife Sites and Local protection. SWT is pleased to see the inclusion of Local Wildlife Sites Wildlife Sites. Support for inclusion of Local Wildlife Sites is noted. (formerly County Wildlife Sites on this list). LWS are recognised in 'Making Space for Nature' and the Natural Environment White Paper as performing It will be important to ensure that the evidence base supporting an essential role in rebuilding biodiversity, acting as core sites and policies is as clear and robust as possible, including reference to stepping stones within ecological networks. relevant tools, guidance and data sources as/where appropriate.
Page 153 of 193 R15.1 There are some surprising omissions from the list; principally Special It will be important to ensure that the Minerals Core Strategy covers Protection Areas (EC Birds Directive), Special Areas of Conservation (EC issues of importance locally without repeating issues already covered Habitats Directive), Ramsar Sites (Ramsar Convention) and the by national and/or international legislation. requirements of the Water Framework Directive. National Parks should be included with AONBs. Carbon capture and carbon storage (particularly in Consider reference to carbon capture and storage and/or the role of relation to peat) should be added to the list. minerals planning in carbon management. Ensure that minerals policy includes appropriate policy on sustainable development and the impact of minerals development on the environment and local communities.
R16.1 The topic list for Local Policies includes Historic Environment issues but Consider reference to sites with potential archaeological interest. should also include "sites with potential archaeological interest" as well as known and proven archaeology. This would place the local policy in line with PPS 5 and most likely reflect the National Planning Framework (based on the draft NPF).
R18.2 Landscape should be identified as an important issue, not just Protected Landscape character is picked up in the proposed list, which landscapes. The term Amenity does not cover this sufficiently. references not only formal designations but also areas outside of formal designations. This will be expanded further in the Minerals Core Strategy.
R22.1 Development management policies to be drafted should require Review any discrepancy between the summary paper and the main development proposals to be accompanied by a transport assessment document. and a travel plan in line with adopted national policy and guidance, and guidance issued by the transport authority (see above). In this instance, It will be important to ensure that transport impacts of proposed the bullet points are different in the summary and the main document - development are appropriately identified and assessed and the particularly with regard to 'minerals operations and traffic'. Minerals Core Strategy will need to appropriately reflect this issue.
R25 Where the list refers to AONBs it could also refer to the importance of Consider adding reference to AONB Management Plan to the considering the AONB Management Plan in developing minerals supporting text – considered in context alongside other Plans and schemes. Programmes when preparing the Core Strategy.
R35 Yes, it covers the primary concerns and interests of local communities. Noted.
Page 154 of 193 R44 The list detailed at 10.2 of the Mineral option Paper outlines topics that the Noted. County Council feel requires local policy guidance for minerals in Somerset. The draft National Planning Policy Framework (NPPF) proposes the cancellation of policy documents to include Minerals Planning Statements (MPS) and a number of Mineral Planning Guidance Notes (MPGs) that cover various individual minerals, their environmental effects and the relationship of mineral working with various environmental assets. It would appear that the draft NPPF leaves the technical aspects of quarrying such as noise limits, blasting limits etc to be set by Local Planning Authorities (LPAs) with an absence of national technical guidance. This will create an inconsistent approach across the country. The content and degree of detail in the final NPPF is uncertain but should no changes be made on the above matter it would be essential for the Quarrying Industry to be formally consulted on any detailed local policy guidance. Under these circumstances the list detailed at 10.2 of the Mineral Option Paper seems sensible. R49 Need to ensure that they acknowledge and cover the potential impacts on This should be covered via relevant policy(ies) in particular linked the Bath Hot Springs. with protection of water resources.
R60 The bullet point relating to protection of the historic environment needs to Arguably these are two separate issues. Matters of demand and be clarified so as to refer to both protection of the historic environment supply should be covered via strategic policies in the Minerals Core from harm associated with mineral extraction, and protection in terms of Strategy, whereas the protection of the historic environment is more ensuring a supply of stone for future repair and conservation. likely be covered by development management considerations.
R71 The list needs to include the effect on roads and transport of mineral The importance of identifying impacts on roads is noted. However, it extraction. Those roads where lorries are likely to travel should have should also be noted that the Minerals Core Strategy will need to be alternative provision for pedestrians/cyclists/motor-cyclists. read in conjunction with other documents such as the Future Transport Plan.
R74 Share the concerns listed in 10.2 No comment R75 As all criteria are important. What about the effect on the water table - Minerals policy will need to give due consideration to the relationship Williton's table is high plus effect on local community between proposed minerals development and the water table.
R8 1 needs more information More information will be added when preparing the Minerals Core Strategy. The Options paper was provided to identify headline
Page 155 of 193 matters that inform the preparation of the Core Strategy. R85 Officers with the County Council are currently following national guidelines Noted and adapting them for local needs presumably. Therefore they are well placed to set out those matters they are dealing with. If they identify other matters that concern them I hope they would raise them with those relevant.
R86 Seems to be very comprehensive Agree Noted R91 I agree with your list in Chapter 10. Noted R92 The necessity to safeguard the environment. Resources are finite - except Noted. It is envisaged that the development management policies will for the human race of course. provide the safeguards being sought.
R93 I agree with the list but it is disturbing that there are so many areas which It will be important to ensure that the Minerals Core Strategy covers appear to be passed on to local level but need national policy clarification. issues of importance locally without repeating issues already covered I am shocked if guidelines on all of these, but particularly the first 6 by national and/or international legislation. (including decisions on NNRs, RIGS, AONBs, SSSIs, ancient monuments) are left to local authorities to determine.
R98.2 I agree with the above list because it appears to cover all the areas of Noted concern.
R102 Dorset agrees that more detailed policy will be required at a local level Noted following the removal of the existing detailed national policy. The topics listed in paragraph 10.2 seem appropriate for local policy guidance.
Page 156 of 193 R103 I agree with the list and would suggest that further clarification is Consider how this issue may be considered further in preparing the necessary to define the extent to which planning might downgrade the Core Strategy. It will be important to give appropriate protection to the level of protection afforded to residents living in property under the health and well being of residents living in areas impacted by quarry ownership of the quarry operator. The conflict between MPS1 issues listed development. as statements 1 and 5 above were tested at Public Inquiry with Moons Hill Quarry likely to create significant impacts at its Yellow Marsh Farm. The inspectors decision would suggest a lower standard of protection might be afforded to a quarry owned property during the daytime period beyond that indicated under planning guidance MPS2. Under these circumstances a more general approach might be put forward based on balancing the issues associated with residents choice and the health and wellbeing impact of noise and vibration against stress of eviction.
R108 Disagree - the list appears to be unnecessarily long as some issues will Review the approach to Development Management after the National be covered by national policy or European Directives. However, we Planning Policy Framework is published. appreciate that the content and degree of detail in the final NPPF is uncertain so it may be sensible to start with this 'long list' and refine it once the NPPF is published.
R115 I agree with the list provided in para. 10.2. Two of the bullets points could Consider the proposed changes in further detail with regard to be further strengthened as follows: Protecting the Historic Environment, protecting the historic environment and the restoration and after use including conservation and restoration of buildings, Listed buildings, areas of mineral sites. of known and proven archaeology, Conservation Areas, Historic parks, Gardens and Battlefields, and Scheduled Ancient Monuments. Restoration and after use of mineral site, especially realising potential opportunities for enhancing wildlife or biodiversity, the retention of geological features and geodiversity for education and research benefits, and provision of community or recreational amenities.
R116 O.K. as a list Noted R117 obvious No comment
Page 157 of 193 R119 Please state why. Minerals operations and potential impacts located in or Further detail will be included in the Minerals Core Strategy. The final neighbouring to AONBs. Minerals operations affecting Sites of Special structure of the Core Strategy has yet to be determined. Efforts will Scientific Interest or National Nature Reserves. Mineral operations in local be made to ensure the structure is straight forward and as concise designations for example: County Wildlife Sites, Regionally Important and precise as possible. Geological or Geomorphological Sites. Mineral operations and potential impacts on biodiversity/geodiversity. Minerals operations and potential Review the approach to Development Management after publication impacts in areas of important landscape character, namely areas outside of the NPPF. of World, European and National designations. Agree that all of the above issues should be covered but would suggest that issues are combined into a single policy rather than separated. Protecting the Historic Environment, including, Listed Buildings, areas of known and proven archaeology, Conservation Areas, Historic Parks, Gardens and Battlefields. and Scheduled Ancient Monuments. The protection of the Historic Environment is currently covered in National Guidance (PPS5) but suggest this issue is reviewed in the context of the final NPPF. Mineral operations in areas of best and most versatile agricultural land. Restoration and after use of minerals sites. Sites for the disposal of minerals wastes. Mineral operations and traffic - transport assessments. Mineral operations and effects on the stability of neighbouring land and properties. Protection of water resources. Cumulative impact of mineral operations. Agree with the suggested issues raised above as warranting specific policies. Protection of Public Rights of Way. Disagree with the need for a Policy specifically on Public Rights of way. There is no need as this can be handled through a Development Management approach. R122 The National Planning Policy Framework should be reviewed once it is Review the approach to Development Management after publication issued and the Somerset Local Policy amended to ensure that it covers all of the NPPF. relevant aspects which are no longer within the reduced national policy (Previously a "raft of policies"). It is therefore too early to agree with the list. R123 Local knowledge is invaluable. Noted R124 Local knowledge is of vital importance. Noted R125 It is ludicrous that highly technical aspects of quarrying should be The County Council is working with the industry in this consultation, considered at local level in a piecemeal fashion across the country. The whilst adhering to national policy and guidance listed aspects should be discussed with the Industry and standards agreed with them.
Page 158 of 193 7 Additional Comments
Detailed Responses
Rep Respondents’ comments MPA Officer responses ID R1 Introduction. We own several pieces of turbary land on Westhay and The County Council will prepare the Minerals Core Strategy in Tealham Moors, turbary land is land that has been used for peat accordance with national policy and guidance, informed by responses production in the past and where conditions exist for new peat to grow, on to the consultations arranged by the County Council and the turbary land this new peat is the only growing crop. Peat production is evidence base it has gathered. most compatible with nature conservation and it has created the wildlife habitat on Westhay Moor. The natural accumulation rate for new peat is approx 2mm per annum but this can be increased by a process for which I was awarded a Patent to make peat production sustainable, the process has been approved by prof David Bellamy, it is a new source of renewable energy, a form of carbon capture and a World First, samples of new peat can be seen at Sweet's Peat & Science Museum, Blakeway, Wedmore, Somerset. The Facts The Nature Conservancy Council made claims on our property, which is our livelihood and capital investment, but did not understand the difference between turbary land and grazing marsh and have not paid us any compensation, they have caused me and my family 26 years of distress, hardship and torture with untold damage to our health, it seems that we have been condemned and downtrodden for no reason instead of being rewarded. The managers of Somerset Wildlife Trust have also made claims on our property without paying any compensation and we are opposed to our application to use some of our land as a nature reserve. Somerset County Council have imposed unworkable conditions where we do have planning permission and refused us permission in the Peat Production Zone, where peat working is deemed to be allowed, again without paying us any compensation. As long as the Government sponsored organizations such as NCC/EN, who are now known as Natural England and the managers of Somerset Wildlife Trust have their own pockets full of money they have no concern for the damage they may inflict on innocent people who have to earn a living from their land, it is no wonder the number peat producers have reduced substantially, 6.10, they have already killed a number by worrying
Page 159 of 193 them to death even though peat production has created the wildlife habitat. What is Peat? 6. Peat is an organic material made up from layers of preserved vegetation that has grown on the land, on turbary land it is the growing crop and cannot be regarded as a mineral or put in a class to which mineral rules apply. R9.3 We have previously corresponded with you on this evolving development The acknowledgement from R9.3 that prior stages of engagement plan in 2010 and can see that this has helped to influence the current have informed the development of minerals planning policy in documents. Minerals extraction and the activity associated with it should Somerset is welcome. not normally take place if it would result in the loss or damage to important historic or archaeological sites, buildings (whether designated or not) or How the Minerals Core Strategy is used to assess the impact of their setting. The soundness of the DPD will be affected by your response proposed minerals development on "heritage assets" is certainly an to this area of policy. However, we also recognise the importance of the important consideration pertaining to the soundness of the document stone industry and the benefits it presents for repairs to heritage assets. (though it is not the only consideration regarding soundness). Dewatering and impacts within Bath also need to be considered against restoration works to existing quarries as it would appear from past Minerals policy will need to give due consideration to the relationship experience that the water table is sensitive to such things. Under Energy between proposed minerals development and the water table. Minerals we believe that there should be some contingency policy concerning Fragging in the Mendips. We are concerned about the The emerging evidence on fracking and the potential for applications potential harm this may cause to the water tables in and around Bath - a to come forward will be considered in preparing the Core Strategy, World Heritage Site and implications on the Spa waters. Within the and a decision made as to whether it merits specific reference. Glossary we note the inclusion of Conservation Areas and Scheduled Monuments. We would, however, suggest that a better way of defining Further work will be undertaken on the glossary, informed by the different heritage assets would be to have a single definition under evidence base and consultation responses and in light of any "Historic Environment" that could use the definition from PPS5. changes to national policy and guidance. It is noted that R9.3 suggests a change to the way "heritage assets" are defined.
Page 160 of 193 R12 Restoration of sites - We welcome recognition of the importance of Support for paragraphs 5.61, 5.65, 5.66 and 5.67 is noted. shallower margins for the benefit of nature conservation highlighted at para 5.61. We strongly support paras 5.65 and 5.66 which recognise the It is noted that flood mitigation and nature conservation are not importance of sand and gravel quarries to provide significant new areas of mutually exclusive. priority European and UK BAP habitat within the green infrastructure network. We also welcome and support recognition at para 5.67 that a Support for para 6.15 is noted. The County Council will continue strategic approach to planning nature conservation through the MCS working to strengthen the quality of its data on peat and peat-related process is required, and that links into other strategic plans need to be activities in Somerset. made. In reference to para 5.69, flood mitigation and nature conservation are not mutually exclusive and can be combined successfully in multifunctional wetlands including reedbeds, wet woodland and wet grassland, all of which are Somerset priority BAP habitats. Current state of the Somerset peat industry - It is very difficult to make an accurate assessment of the current state of the Somerset peat industry without up to date information from the peat producers. We note the lack of adequate data necessary to help forward planning by the MPA, and strongly support the statements at para 6.15. This should be highlighted in the MCS as key issue. It is critical to get an accurate understanding from the producers of: Current levels of peat output; Trends over the last 10 years and current volumes of peat imported for milling from Eire and the Baltic; Trends over the last 10 years and current output of non-peat alternatives in Somerset; The volume of potentially non-accessible peat within current permissions; The volume of potentially accessible non-consented peat reserves within the Brue area. In the absence of adequate data from the producers it is helpful to note that output from Somerset continues to decline and has almost halved in the last decade. R13 We are currently running four Living Landscape initiatives which showcase Support for the Options paper is noted and welcomed. the many benefits a healthy, functioning natural environment brings to society and local economies. Two of these initiatives, the Mendip Hills It will be important to maintain close and regular dialogue with the Living Landscape and the Brue valley Living Landscape in the Somerset County Ecologist(s) and link, as appropriate, with initiatives such as Levels and Moors, cover important protected landscapes which are EcoNet that contribute toward a clear implementation plan for new impacted respectively by the quarrying and peat extraction activities minerals policy in Somerset. discussed in this document. A critical factor of Living Landscapes is to show that positive action for nature and the environment makes economic sense. This accords with the Government's Natural Environment White Paper and the England Biodiversity Strategy 2020, documents which recognise the importance of the environment's role in socio-economic well-being, and the urgent need for collaborative action across all sectors
Page 161 of 193 on the protection and enhancement of the environment. SWT considers this Options Paper to be thorough, clearly presented and well reasoned document, which posits some sound policy options for consideration. To help with context setting for the Plan, mention could also be made in Chapter 3 of Somerset's ecological network. Larry Burrows at SCC is currently leading on the development of an ecological network model and methodology for the whole county, which should be transferred into local policy by all Local Planning Authorities. This is in line with the draft National Planning Policy Framework which requires Local Authorities to "set out a strategic approach in their Local Plans, planning positively for the creation, protection, enhancement and management of networks of biodiversity and green infrastructure" and to "identify and map components of the local ecological networks, including: international, national and local sites of importance for biodiversity, and areas identified by local partnerships for habitat restoration or creation". This policy reflects some of the aspirations for biodiversity and access to nature contained in the Government's Natural Environment White Paper, and has the full support of SWT. Somerset's ecological network, called EcoNet, is well progressed in its development, and the intention is to release methodology, maps, and a draft SPD to local authorities in April 2012 for their comment; following any necessary refinements, it is expected that adoption of the network will be achieved during 2012. EcoNet comprises of core areas - critical sites for biodiversity based on existing statutory nature sites - and a range of buffers, opportunity areas, corridors and stepping stones, which, taken together, provide a framework for the creation of a connected, coherent network of habitat, enabling species to move across the landscape. Examination of the known mineral reserves against the network maps may help with policy and guidance development: the network will provide an indication of the most ecologically sensitive areas on the network, and identify creation and enhancement opportunity zones. The principles of ecological networks are protecting the remaining "best bits" for nature, and enhancing and creating new habitat areas, corridors and stepping stones in order to provide areas of sufficient size and connectedness to permit populations to breed, feed and migrate: these should be key considerations in some of the policy option questions below.
Page 162 of 193 R14 A full response to the DEFRA consultation on future peat reduction targets The County Council welcomes engagement with the SPPA in the was submitted in 2011 and the SPPA is now an active member of the development of the Minerals Core Strategy. DEFRA 'Sustainable Growing Media Task Force'. DEFRA's Natural Environment White Paper established target dates for a voluntary phase- As the SPPA acknowledges, it is impossible for the County Council to out of peat in horticulture by 2030, but recognised that significant technical put on hold its consultations whilst other issues are resolved, since and commercial challenges need to be tackled in order to achieve that the nature of national and international policy development suggests aim. DEFRA therefore established the 'Sustainable Growing Media Task a constant evolution. Force' to take this work forward. Under the chairmanship of Dr Alan Knight, the Task Force has managed to pull together a broad range of With this in mind, the County Council looks forward to working with stakeholders including peat and non-peat based manufacturers of growing the SPPA and other partners within the framework provided by media, growers, retailers and environmental NGOs. The Task Force has national policy and guidance. set itself an ambitious work programme, including twelve different sub- projects, to deliver a "roadmap" of evidence based recommendations to Ministers by 30 June 2012. The SPPA has been heavily involved in the process along with colleagues at the Growing Media Association (GMA) and the Horticultural Trades Association (HTA). One of the key issues to emerge from the early work of the DEFRA Task Force is the suggestion that some further UK peat extraction might be preferable, in terms of sustainability and biodiversity, to a blanket prohibition. There has finally been recognition that not all peat is the same and the impact of working 'peatland' is very different to extraction of 'peat bogs'. Dr. Alan Knight has termed this the "Somerset Question", in acknowledgement of our success in extracting peat from drained agricultural peatland in Somerset followed by restoration to internationally important wetland habitat. It is argued that this is environmentally preferable to importing sphagnum peat from virgin bogs in the Baltic, for example. The appended exchange of letters between Dr. Alan Knight and Richard Benyon MP, Minister for the Natural Environment & Fisheries, gives an indication as to how Government thinking is progressing. Responsible growing media sourcing and the greenhouse gas (GHG) emissions of different growing media constituents are two of the key Task Force sub-projects and the "Somerset Question" is central to both. The SPPA is committed to the Task Force and we are one of the team leaders responsible for developing the criteria for responsible sourcing. We also sit on the GHG emissions sub-group. Whilst we would not wish to prejudge the outcome of the process, it is important for SCC to consider that the Task Force may conclude that responsible sourcing of growing media means that that peat which is required in future should be sourced from archaic peatland under
Page 163 of 193 agriculture. We are already aware of research which suggests that GHG emissions from worked archaic peatland are less than from similar land in agricultural use. In GHG terms it already appears that it is preferable to source peat from drained archaic peatland which is already emitting carbon than from raised bogs which are, or are capable of, actively sequestrating atmospheric carbon. At the same time the SPPA has responded to DCLG with respect to the peat policy section of the draft NPPF. Both DEFRA and DCLG have acknowledged that the UK cannot ban the import of peat and the NPPF will only apply to England. The SPPA is making the case that it is far better to work peatland in England which is already drained and in low value agricultural use than to import peat extracted from raisedn bogs. This is the model adopted by German horticulture, where all peat extraction is similar to that in Somerset, and without continued indigenous peat supply UK horticulture will be vulnerable to competition from EU importers. By working peatland in England high standards of environmental protection can be guaranteed, GHG emissions minimised, wetland habitat created and the UK economy supported. These are the very points now recognised as potentially important by the Task Force and representatives of the SPPA and the HTA were one of the few interest groups to be permitted a follow up meeting after submitting a response to the draft NPPF. This allowed the case to be made in person to Mark Plummer, DCLG Team Leader Minerals & Planning Policy. As we made clear, it would seem incongruous for DCLG to decide planning policy on this complicated and sensitive issue before the Task Force has produced a roadmap of action that has been agreed by consensus amongst Government, NGOs and the industry. The timetable for publication of the final NPPF is, however, 31 March, three months before the Task Force is scheduled to deliver its findings. We understand this subject was also raised with the Rt. Hon Caroline Spelman MP at her recent meeting with the All Party Parliamentary Gardening and Horticulture Group. We believe the DEFRA Secretary of State acknowledged the potential for the NPPF to pre-empt the findings of the Task Force and undertook to liaise with DCLG in an attempt to avoid any unnecessary conflicting policies across government. The SPPA has considered the 'Minerals Options Paper' and responses to the questions posed are set out below. Fundamentally, however, we believe the SCC consultation to be premature. It is recognised that SCC cannot indefinitely delay the Minerals Core Strategy for Somerset whilst Government
Page 164 of 193 develops peat policy. At present, however, there is such uncertainty as to the shape of future policy within both DEFRA and DCLG that responses to many of the key issues raised within the 'Minerals Options Paper' could be outdated within months. We have sought to be as helpful as possible, but at this stage all SPPA responses should therefore be regarded as provisional. We will, of course, continue to be fully engaged in the process and keep SCC informed of the progress of the Task Force.
R18.2 There is need for a greater input of landscape advise on many of the Landscape character is identified in the Development Management issues discussed that SCC is currently provided with. There is currently (DM) section of the Minerals Options paper. This will be further very significant emphasis on biodiversity while landscape issues are often expanded in the DM section of the Minerals Core Strategy. neglected despite these often being very important to the communities affected.
R22.1 The Secretary of State will soon abolish Structure Plans and Regional The County Council is mindful of its responsibilities under the new Spatial Strategies per order. In future, strategic priorities such as minerals Duty to Cooperate and is, indeed, co-operating with Devon County will be subject to a 'Duty to Cooperate' as set out in the draft National Council regarding sand and gravel extraction at Whiteball. Planning Policy Framework and the Localism Act. You will know that under the recently enacted Localism Bill important changes will be made Transport related aspects of minerals planning will continue to be to the statutory development plan. Regional Planning Guidance 10 and informed by adopted county strategies and guidance. The list of the saved policies in our Exmoor and Somerset Joint Structure Plan relevant adopted plans is noted. Review 1991-2011 are to be abolished. This will mean that the strategic elements of the development plan will cease to have effect, which has implications for all local authorities in Somerset and how they approach plan making and development control. The strategic planning group within Somerset County Council has in the past provided observations on a wide range of strategic planning matters in line with our role as a strategic planning authority. As you know, the Localism Bill received Royal Assent on 15 November 2011 and is now law. We are in a transitional period until various provisions within the Act are enacted by statutory instrument and development order over the next few months and years. For example, the forthcoming abolition of Regional Spatial Strategies and saved Structure Plans is anticipated in April 2012. In this context you will be aware that the Localism Act 2011 now requires authorities to comply with the Duty to Cooperate (Section 110). The draft National Planning Policy Framework (NPPF) currently identifies key strategic priorities (para. 23 ff) local authorities and other prescribed bodies will have to cooperate on (para. 44 ff), including minerals. By the time the Minerals Core Strategy progresses
Page 165 of 193 to examination you should be able to present an audit trail of how you have complied with the Duty in line with current and forthcoming national policy and guidance on this matter. As an example, co-operation with the environmental bodies and neighbouring authorities should be undertaken. One example could be cooperation with Devon County Council concerning planning for sand and gravel extraction in the Whiteball area. During the early part of the consultation period planning application was granted for deepening of Torr Works (East Cranmore). This will significantly increase the permitted reserves of crushed rock in Somerset which needs to be reflected in future consultation documents. We welcome that transport aspects have been included and addressed in the document. You will know that from our perspective highways and transport related strategies and technical guidance form an important material consideration in the planning process. Somerset County Council has adopted the following documents with may contain useful advice for you in preparing the evidence base and policies for the Minerals Core Strategy:
• The Future Transport Plan for Somerset 2011-2026 • Technical Note 'Transport and Development' • Travel Planning Guidance • Freight Strategy
Paragraph 5.74 in the consultation document states that aggregate transport will continue to be dealt with in line with national guidance (e.g. as in MPS1, PPS13) and in accordance with the Development Control policies. In addition to the documents mentioned above you will also need to consider national policy on transport in the forthcoming National Planning Policy Framework, as acknowledged in para. 10.2. Peat production in England is likely to be reformed through forthcoming national policy. Implications of this will need to be considered in environmental and sustainability terms, and how peat areas are to be monitored. Transport related aspects of minerals planning should continue to be informed by adopted county strategies and guidance.
Page 166 of 193 R25 Management of the Mendip Hills AONB is co-ordinated through the The Minerals Core Strategy must link with and be informed by Mendip Hills AONB Management Plan 2009-2014, which sets out a relevant Plans and Programmes, such as the AONB Management number of themes, objectives and actions to ensure the long-term, Plan. sustainable management of the AONB. Key objectives in relation to quarrying are as follows: F3 - The restoration and after use of all quarries On adoption the Core Strategy will become the main minerals is planned and carried out to minimise the impact on the landscape, and to planning policy document in Somerset, setting minerals planning be compatible with the purposes of the AONB designation. D1 - All Local policy in Somerset for the Plan Period informed by consultation and Development Framework (LDF) documents and planning decision-making technical evidence. processes will use the following criteria to determine the acceptability of a proposed development in the Mendip Hills AONB. Development will:
• Ensure quarrying takes place in the least environmentally damaging manner until the consent expires. (one of a number of bullet points)
The AONB Unit considers that the Core Strategy should make clear cross- references to the AONB Management Plan in relation to any proposals that may impact on the AONB. The Management Plan is a statutory requirement under the Countryside and Rights of Way Act 2000 and has been endorsed by Somerset County Council. R34 The bulk of Aggregates extracted in from the Eastern Mendips: This area As stated in the Options paper, minerals are essential for economic is the most densely populated rural area in Somerset. As such it is the development, for our quality of life and for the creation of sustainable worst possible area (other than towns) for the major extraction of bulk communities. In this context, mineral planning ensures that the need minerals. Large scale extraction has been going on for the last 60 years. for minerals by society and the economy is carefully balanced against Albeit the Eastern Mendips was designated a sacrificial area, c. 1970, the the impacts of extraction and processing on people and the local population were not consulted, and did not wish it to be sacrificed. environment. The use of limestone as an aggregate is not very satisfactory as it is chemically active, and dissolves in rain water (which is slightly acid). As The Minerals Core Strategy will need to provide an appropriate policy the levels of carbon dioxide have increased in the atmosphere it is framework for minerals development in Somerset, acknowledging becoming more unstainable. Indeed it is not used as railway ballast supply and demand issues, the technical evidence available and the because of this fact. We feel that the general policy of SCC should be local geology. The geology of the Mendips means that it plays an towards running down and terminating carboniferous limestone quarries in important part of the economy. the Eastern Mendips. In the past promises have been made that quarrying in the Eastern Mendips would cease in 2040 (when current permission As stated in paragraph 3.8 of the Options paper: "Approximately expire). Landscape Value: The Eastern Mendips are more attractive 1,400 people were employed by quarrying in the Mendips in 2009, visually - except where scarred by quarries than the Western. East while approximately £160million was spent in 2009 in association Mendips consist of fertile deep valleys - with streams and rivers, often with the winning, working and processing of crushed rock into heavily wooded - there are two Special Areas of Conservation and many aggregates and the production of associated products within the
Page 167 of 193 wildlife sites. The Western Mendips are a flat, rather barren windswept Mendip Hills". Furthermore, the county's resource has a wider plateau, described as lumpen. We think that Eastern Mendip would have strategic role. As stated in paragraph 5.4 of the Options paper: been listed as an AONB, but for the quarrying activity. Due to quarrying, "Somerset is the second largest aggregate producing County in the roads have been closed, bridleways closed for 30 years or more years, country, second only to Leicestershire. The Carboniferous limestone new roads built and new railway built. All of which have helped to degrade of the Mendip Hills is of national importance, serving not only the the landscape. needs of Somerset but also contributing to the needs of the South West region, London and the South East." Economics: There has been a reluctance by Government to allow market forces to work properly. If the supply of primary aggregate were restricted, It will be important that the Core Strategy helps to foster a policy the price would go up and secondary aggregate would become more environment in which unacceptable impacts are prevented and where attractive. Users would be more economical in their use of all aggregates. local communities have a meaningful opportunity to engage with and The economical benefits to the Eastern Mendips is limited. Only a few of benefit from local development via the planning process. In forming the employees live in the villages. Others live in the surrounding towns: the Core Strategy, the County Council will take account of the results many live outside the county, in Banes and Wiltshire etc. of Sustainability Appraisal and other technical research which feedback on the impacts of different policy options. 1.11 - Quarries, by their very nature, are never sustainable. 2.5.6 - International areas of nature conservation importance are being damaged The Minerals and Waste Local Development Framework can support by quarry - Asham Wood and Mells Valley being to most important. There better use of recycled aggregates in Somerset. This will include both are no exceptional circumstances to justify extraction in their villages. 3.5 minerals and waste planning policy. - Nature conservation and landscape constraints should apply to the Eastern Mendips. The Eastern Mendips are more important as they are The approach to the use of buffer zones around statutory heavily populated and the residents' lives are disrupted by quarrying. 3.8 - designations will be reviewed in preparing the Core Strategy. Many of the people employed in quarry live outside Somerset. The Perry report is not universally accepted, and it was not an independent study. 5.4 - We note that no consideration has been given to East Mendip residents to get tickets for the Olympics games. This also means that the need for aggregate will be reduced in the future, since the Games are unlikely to be held here in our lifetime. 5.6- Southwest is close to South Wales which has better transport facilities. It also has higher unemployment rates. We should support them by reducing supplies of skid resistant stone. 5.9 - The Eastern Mendip quarries output of carboniferous limestone should be reduced as well, due to environment consideration. 5.12 - If the supply of premier aggregate is reduced, market forces will make the use of transport of secondary aggregate more attractive and economically viable. 5.23 - Over supply in the past has led to wastage and inhibited the uses of secondary aggregate. This mineral plan should have the objective of remedying this. As Somerset has produced so much in the past, its actions by reducing supply would be
Page 168 of 193 most important. 5.31 - The local communities do not want quarrying to continue in their area for many years to come. Eastern Mendip has made its sacrifice. Now is the time to consider ways of alleviating their burden. Somerset apportionment has been greater than sales every year. Therefore it should be reduced to a more realistic figure. 5.34 - If demanded rises, market forces should operate, rather than making more primary aggregate available. 5.38 - These three quarries are all in Eastern Mendips. 5.40 - New plant often reduces employment opportunities. 5.44 - Quarrying activity is easily switched off. It's switched off every Christmas and Easter. With reducing output there may be no need for new plant. New plant tends to reduce the number of employees. 5.47 - Market forces should be allowed to operate. Recycling would be encouraged. 5.60-5.62 - Water supplies have already been affected in the Mendips. Water is sustainable; quarrying is not and damages a sustainable supply. 5.68 - We welcome reducing extraction and closure if quarries in the Eastern Mendips. There is no need for Somerset to allocate new areas for extraction - Somerset has given enough. Appendix A, Fig. 2. - Shows no quarries producing carboniferous limestone for building. All the aggregate quarries should produce enough for local need. Special Areas of Conservation (SAC): There are two SAC's in Eastern Mendip, Asham Wood and The Mells River Valley. SAC's should have a buffer zone around them where development is controlled and detrimental to the SAC. (Special Sites of Scientific Interest (SSSI's) should also have a buffer zone). The buffer zone around the SAC's should be reviewed regularly, and harmful development should be reversed. The new Somerset Minerals and Waste Policy should emphasise this point. R35 No questions were asked on Chapter 8, 'Energy Minerals'. Section 8.3 The emerging evidence on fracking and the potential for applications mentions that 3 licences have been issued for the exploration and to come forward will be considered in preparing the Core Strategy, extraction of oil and gas resources. Binegar Parish Council is concerned and a decision made as to whether it merits specific reference. The that 'Fracking - Shale gas exploration or extraction' in the Mendips could evidence base supporting the minerals policy development in have significant impacts. We would like to see the Risk Assessments Somerset will be openly available to the public. surrounding these activities to be openly available to the public.
Page 169 of 193 R36.2 We would like to see a far better use of secondary and recycled aggregate The Minerals and Waste Local Development Framework can support being used. With respect to a downturn it cannot be assumed that there better use of recycled aggregates in Somerset. This will include both will be a significant improvement in demand for the duration of the minerals and waste planning policy. Minerals Option Paper and there should not, therefore be any such opinion included in this paper.
R38 Our interests primarily relate to the protection of our sewerage assets The need to consult Wessex Water on any proposals for within the area. We note the recommendation to designate Torr Works as development that might impact on the sewer running from Cranmore a "Strategic Site". A foul sewer conveying foul drainage from Cranmore to to the sewage treatment works is noted. the sewage treatment works appears to be in close vicinity to the Torr Works location as shown on "Somerset Strategic Sites Assessment Fig 3.1 Mendip Quarries" Wessex Water should be consulted on any proposals which may affect the protection of this sewer; an extract from the public sewer records for this location is attached to our response.
R41 Wainwrights supports the policies for aggregate production in Somerset's Support for the description of the economic importance of minerals Mineral Options Paper and is pleased to see that the County Council extraction in the Options Paper is noted, alongside support for listing recognises the considerable economic importance of mineral extraction in Moons Hill Quarry as a strategic site. the County and that it provides direct and indirect employment and expenditure within the local community. We support the recognition in Due to the fact that Moons Hill is identified as a strategic site in the paragraph 5.5 of Moons Hill Quarry as a strategic site which is essential to Strategic Sites Assessment and will receive support in policy and meet regional and national aggregates needs. Wainwrights also supports supporting text in the Minerals Core Strategy; a separate landbank a separate landbank for andesite to ensure continued production of road for andesite is not considered to be needed. surfacing materials. The impact of the 1999 Quarry Regulations has caused a reduction in known andesite reserves as a result of adjusted The demand for and importance of minerals should be made clear in working methods to meet higher safety standards. The impact on reserves the Core Strategy. is still unknown as future working areas and depths are still being evaluated but it is likely that the large scale long term reserves which the The Minerals Core Strategy should provide a balanced framework for quarry complex was thought to contain will have to be revised very minerals transport, acknowledging the importance of designated substantially downwards. This means that within the Plan period additional freight routes but also supporting more sustainable modes of reserves from the andesite outcrop will need to be released. Wainwrights transport. Importantly the Core Strategy will help the County Council, believe that an andesite landbank of at least 20 years should be as Minerals Planning Authority, to assess the potential impacts of maintained to allow investment in expensive, specialist static plant and minerals transport from proposed minerals development. machinery for processing extremely hard and abrasive material which is usually designed for a lifetime of at least 30 years. Paragraph 5.7 of the Consultation Paper suggests that it would be too complicated to maintain a separate andesite landbank. However, the reason given for that suggestion is wrong. The overburden material lying above the saleable
Page 170 of 193 andesite is not a general aggregate material. It is, similar to other quarries in the area such as Torr Works, waste which must be discarded into massive storage bunds around the quarry. Very little of the overlying material which must be removed to access the andesite, if any, can be put to good use as an aggregate. There is, therefore, no reason why a separate landbank could not be maintained. As in many minerals papers there is a lack of an explanation of society's need for minerals and construction materials. The public may not be made aware, in any dynamic way, why we need the minerals industry. For many years now, aggregate consumption has been averaging more than 4 tonnes per person in the UK (although the latest published annual figure is slightly less than 4tpp - due to recession). A robust explanation of the need for stone, including the strategic aggregates such as road surfacing materials, would not go amiss. Somerset produces far more than local needs and much of the production is delivered to the south east. It is accepted that, where possible, aggregates should be delivered by rail but it is not possible to move all aggregates by rail. In particular certain aggregate products (such as coated roadstone for road surfacing materials) can never be moved by rail because of the speed with which they must be delivered to the road which is being repaired. Furthermore, movement by rail can only be achieved where a rail head is constructed in a quarry and there is little, if any, scope for additional railheads in the Mendip Quarries. Moons Hill Quarry could not be rail linked yet it provides an important specialist product which is used throughout the south east. The Paper should recognise that where it is not possible to move materials by rail from the Mendips, road transport is the only alternative. The Core Strategy should strongly support the continued improvement of designated lorry routes. R47 In Cornwall there is talk of 'travelling quarryman who go to old quarries, The Options paper included a section on dormant and abandoned take out and process back at base. One might make a search for old sites and the Minerals Core Strategy will need to include appropriate quarries that could be reopened E.G. Marlstome near Ilminster c policy coverage on this issue. ST314148. Have you directly asked English Heritage and district conservation officers about there needs although they should comment in English Heritage and District Councils are separate consultees in this response to the Consultation. process.
Page 171 of 193 R49 The Council would like to stress that the key concern for Bath & North The importance of the Bath Hot Springs area is noted. The Core East Somerset is the impact of any mining operations on the Bath Hot Strategy will need to cover the protection of water resources in its Springs. Whilst Minerals Options Paper acknowledges the potential for policies. The County Council looks forward to working further with quarrying to significantly impact on water resources in the Mendips it does Bath and North East Somerset in matters relating to minerals policy. not yet fully consider the implications of this and the potential for this activity to impact on interests outside of Somerset, in particular the Bath One of the objectives in the SA framework is to maintain and improve Hot Springs. The Council would therefore like to be reassured that the ground and surface water quality. Somerset Minerals Core Strategy is developed continuing the precautionary approach to deep quarrying activity and that the Review the inclusion of groundwater as a key issue in any key issues precautionary approach is extended to cover energy exploration and section of the Core Strategy. extraction proposals in the Mendips. In addition there should be explicit reference to the international importance of the Bath Hot Springs and the Support is noted for taking a precautionary approach to the impact on need for deep quarrying and energy proposals in the Mendips to water resources from proposed minerals development. specifically consider potential impacts on them. The Council is therefore keen to work with Somerset County Council, mineral operators and the The emerging evidence on fracking and the potential for applications Environment Agency to identify means for protecting hydrogeological to come forward will be considered in preparing the Core Strategy, interests in the Mendips. Chapter 1 - Introduction This section refers to and a decision made as to whether it merits specific reference. sustainability appraisal (SA) which identifies the key issues associated with mineral extraction in Somerset. It will be necessary to ensure that the SA includes the potential for extraction to impact on the Bath Hot Springs as part of the appraisal process. Chapter 2 - Policy Context No implications for the Council Chapter 3 - Minerals in Somerset This section should also reference groundwater as one of the key issues for minerals in Somerset. Chapter 5 - Aggregates This chapter recognises at paragraph 5.27: In recognition of the particularly sensitive groundwater situation in the Mendips, due to the geology and combined pressure of quarry dewatering and abstraction for drinking water supply, the Minerals Local Plan takes a precautionary approach to protecting water interests." And at paragraphs 5.61 and 5.62 on Water Resources: There is potential for quarrying to impact significantly on groundwater resources and as proposals for quarrying become deeper and deeper the risks are increased. The Minerals Core Strategy will continue to place a very high importance on the protection of the water regime. The water resources in the Mendips are particularly pressured because they are important for public water supply, local agricultural supply and are within an area of particularly deep quarrying activity. The Mendip Hills groundwater system is complex and predicting the effects of drawdown to access minerals is also complex. The Minerals Local Plan policy advocated a precautionary
Page 172 of 193 approach regarding water impacts. There is no reason to alter this approach in the Core Strategy. The continuation of a precautionary approach to future deep quarrying in the Mendips is welcomed. However, the recognition of the sensitivity of the Mendips needs to be expanded to acknowledge the potential for impacts on the Bath Hot Springs to ensure that this is acknowledged within the Core Strategy and that future applications take this into account. The existing Somerset Minerals Plan confirms at paragraph 6.5.9 that: "Somerset County Council will continue to work with the mineral operators, the Environment Agency and adjoining authorities to identify means for protecting hydrogeological interests in the Mendips. This approach should be continued and the Minerals Core Strategy should set out clearly what measures will be put in place to ensure that the interests of adjoining authorities are properly considered. Chapter 6 - Peat No implications for the Council Chapter 7 - Building Stone No implications for the Council Chapter 8 - Energy Minerals This chapter provides no consideration of the potential impacts on future energy exploration and extraction proposals on hydrogeological issues, in particular the Bath Hot Springs. It is confirmed that 3 licences have been granted by the Department of Energy and Climate Change which are located entirely of partially within Somerset. It is therefore to be expected that proposals for the exploration and extraction of gas will come forward over the plan period. Hydro Fracturing - commonly known as "fracking" - is the process for extracting natural gas (methane) from differing depths and rock layers underground. This is done by drilling boreholes vertically and laterally and then injecting water, sand and chemicals in at very high pressure to induce fracturing in the rock layer. This then holds open the fractures and allows the gas to escape and be collected at the surface. There are a number of potential risks to the Bath Hot Springs from fracking operations in the region. These events may be relatively minor in nature at the surface but how they might affect the fracture based delivery system of the Hot Springs to Bath is very uncertain. The Core Strategy therefore needs to recognise the potential for impacts on groundwater from these activities over an area wider than Somerset and ensure that this is properly considered through the planning process, particularly with regard to potential effects on the Bath Hot Springs. Chapter 9 - Mineral Safeguarding Areas No implications for the Council.
Page 173 of 193 R57 Ham & Doulting Stone believes that natural materials, like all of their Support is noted for the coverage of Building Stone in the Options Somerset stones, enhance environments and enrich the lives of those Paper; though it should be noted that the Options paper does not who interact with them. All of their stone products are totally natural and present final policies. the majority is used locally in Somerset and the adjoining counties. Ham & Doulting Stone Ltd supports the policies for Building Stone in Responses to questions 21-24 will help to inform the preparation of Somerset's Mineral Options Paper and the County Council's intention to the Minerals Core Strategy and its approach to supply and demand ensure the continued provision of natural stone products for conservation, issues regarding building stone. restoration and new buildings. We amplify this support with comments on some of the issues. Paragraph 7.17 of the Options Paper refers to the need to maintain the built heritage and character of Somerset. We support this aim but it should be recognised that the built heritage and character of areas which traditionally use stone quarried in Somerset often extends beyond the County boundaries. For example Doulting stone can be used in heritage buildings throughout the country. Blue Lias limestone is traditionally used between Lyme Regis in Dorset and Whitby on the east coast and in places where it outcrops in the Midlands but there are no other sources of supply in these areas. In a planning appeal in 1993 (T/APP/G3300/A/92/213195/P5) for the extension of our operating base in Tout Quarry the Inspector stated in his report; "... the Council, and objectors to the proposal, questioned whether stone from Tout Quarry truly met a local need in view of the fact that stone has been supplied to other parts of the country". The Council conceded at the Inquiry that "local" could be taken to mean Somerset and adjoining counties". It has since to our knowledge not been questioned whether stone from Somerset quarries satisfies a local need when it is actually used across the county boundary, particularly in Dorset, Wiltshire and Devon, to meet traditional needs. The use of Somerset stone in those areas should be acknowledged in your policy. We suggest that 7.17 is changed to state; "The Minerals Local Plan supports quarrying of building stones as long as it can be shown that the material is needed to maintain the built heritage and character of Somerset and areas where the stone is traditionally used".
Page 174 of 193 R60 The Forum generally welcomes the Somerset Mineral Option Paper and, The respondent supports the need for information supplied with in particular, the emphasis on the encouragement for the reopening and applications to be proportionate to the nature and scale of the expansion of existing sites. It strongly welcomes the view that information proposed development. in support of applications should be proportionate to the nature and scale of the proposed development - many small building and roofing stone Support is also noted for sections 7.2 to 7.5 and 7.6 to 7.9. extraction proposals are currently treated as if they were large scale quarrying operations. Section 7.2 to 7.5 (Why are our building stones Responses to questions 21-24 will help to inform the preparation of Important) - We strongly support and agree with the comments in this the Minerals Core Strategy and its approach to supply and demand section. Section 7.6 to 7.9 (Planning policy for building stone) - We issues regarding building stone. strongly support and agree with the comments in this section. Section 7.11 (Demand for building stones) - The demand for natural stone across Habitat Regulations Assessment and other technical research in its the whole country has seen considerable growth over the last 20 years. evidence base will help the County Council to consider its policy The majority of this demand comes from new build, so it is vital that the approach and potential impacts on local biodiversity. Somerset Stone industry is given assistance to tap into this growing market to allow their businesses to be competitive. Section 7.16 (Supply Consider use of the term "small" with regard to building stone of building stones) - This point really covers 2 issues. Regarding the quarries, with reference to consultation responses and government second issue, concerning the distribution of stones used in Somerset, it is policy and guidance. important to recognise that stone usage does not respect county boundaries. In some cases, building stones are widely used well beyond Support is noted for assisting with the development of a list of stones their original quarry sources, often beyond the county boundary e.g. Blue that are not worked at present but that may be needed for future Lias limestone, White Lias limestone, Ham Hill Stone. We believe that the projects. core strategy should consider wider regional and national needs in some instances. A more collaborative regional/national approach between Also support is noted for additional activities at building stone authorities with regard to accessing and supplying some stone varieties quarries (with certain caveats / constraints). should be considered in the strategy, to ensure that wider heritage conservation needs are met. Crucially, producers of certain stone types Regarding safeguarding, it is noted that R60 advocates consideration should not be subject to an artificially restricted market as a result of of carboniferous limestone as a building stone (noting that aggregate planning conditions that restrict the sale of stone to within the county, as in quarries may not be suitable sources on account of micro-fractures many cases this can make extraction un-economic. If all MPAs were to created during blasting). apply such a policy rigorously, this could inhibit supply of material from other counties for conservation in Somerset, where local supplies were no Answers to question 25 in the Options consultation will help the longer available or possibly impractical. Section 7.17 (Quarrying of County Council to determine a final list of mineral types to be building stones) - The comments on 7.16 above also apply to this safeguarded. paragraph. A viable quarrying business will need to supply to a regional or even national market and add to the palette of English stones that are Review adding "Listed Building" and "Dimension Stone" (or building currently available. Most businesses are unlikely to be sustainable if their stone) to the Glossary. market is restricted to Somerset. Section 7.20 - Whilst we would agree that the reopening of an existing site would be preferable in most cases to
Page 175 of 193 a Greenfield site it is important to take a pragmatic approach to the flora and fauna that has developed in the site since the previous extraction. A temporary disturbance to the wildlife habitat can be mitigated by a phased extraction programme and sensitive restoration. A considerable proportion of wildlife sites including SSSIs have developed at former quarries - certainly more than in „monoculture farming?. In many instances it is the simple action of disturbing ground that considerably increases the propensity to generate biodiversity. Furthermore, it is important to balance this positive characteristic of biodiversity with the often much more limited geological resource available (alongside historical precedent) necessary to fulfil the demands of building conservation. Section 7.21 - Almost all dimensional stone operations in the UK are small - so we are concerned at the definition of small. The English Stone Forum has previously defined any quarry with an extraction of less than 2,000 cubic metres per annum as small. See http://www.englishstone.org.uk/documents/small.html There is a danger that a tiny extraction sites with a tiny workforce will not have the resources to train future generations so vital skills will not be passed on. They are also very vulnerable to changes in the market and will be unlikely to be able to take the stone to a wider market, in fact they could lack the skills to even make the local market aware that the stone is being extracted and therefore available. Section 7.24 (Increasing supply of building stone to meet local need)- It is important that unnecessary restrictions are not imposed on quarrying activities. Some overburden and waste dimension stone will probably be required for the restoration, but working space will nearly always necessitate the removal of some rubble from the site and it would make sense that this material is sold to the local market. However it is important that aggregate applications are not granted by stealth at dimension stone sites. Section 7.25 - We would support and assist with the development of a list of stones that are not worked at present but that may be needed for future projects. 7.26 - We would support encouraging additional related small scale activities for the site, in order to make a quarry viable, providing that the production of dimension stone remains the priority activity and focus for the extraction process. Section 9.7 (Which minerals are to be safeguarded?) - Carboniferous limestone is also needed as a building stone and aggregate quarries may not be suitable sources on account of micro-fractures created during blasting. Section 9.8 - It should be noted that most of the building stones used in historic buildings but not currently being worked
Page 176 of 193 are needed at the present time, both for repair and also for extensions to historic buildings or for new build in sensitive locations. Many of these stone types and potential quarry sources have been identified by the Strategic Stone Study. Definitions for "listed building" and "dimension stone" (or building stone) would be useful.
R65 I feel section 4 is well balanced given all the difficulties of trying to please Noted so many different views.
R70 However, one point I would like to make is that all efforts be made to The Minerals Core Strategy will need to provide appropriate support continue to transport bulk products such as minerals by rail as is current for more sustainable modes of transport. the case in the East Mendips. The lack of a rail link to the impending Hinckley Site is a classic example of the problems incurred by transportation by road, despite EDF's best efforts to find alternative means. Therefore, future sites should be able to identify the potential for adjacent or nearby railheads or even the building of rail links into the site, which is not an unreasonable investment expectation if a site is going to worked for many years.
R77 This Council is in support to your proposals and although we are aware of It will be important to ensure that the Minerals Core Strategy provides the financial and employment opportunities that this sector of commerce appropriate protection to the county's water resources. brings to the Community we wish you to remain guarded and ensure that all existing water tables, levels and their non-contamination remain protected at all times.
R78 The extraction of peat has been a contentious issue for a number of years. It is noted that this respondent is concerned by future extraction of Scientific study has long established the value of bog peat as: 1)An peat and supports the use of peat-free alternatives. important environment for the fostering and sustenance of biodiversity, which is a central goal of global conservation. 2)A repository of human activity going bank many thousands of years. The acid environment has preserved everything from ancient track ways to wood and metal artefacts and even human bodies. 3)A carbon sink of enourmous significance. In response to these findings, HM Government has issued a white paper, The Natural Choice (June 2011), in which it has outlined its plans to reduce the consumption of peat in the UK as follows: 1)All local and
Page 177 of 193 central government parks and gardens to desist from using peat by 2015. 2) All amateur gardening use of peat to cease by 2020. 3) All professional horticultural use of peat to stop by 2030. Local peat interests are resisting this time table, using arguments that: 1) Peat provides local employment, which is true but on a very small scale. Less than 200 work in the industry in Somerset, about a third of those seasonally. There is no reason, with careful management, why the transition to peat-free products should not be achieved with any loss of employment. 2)The peat industry is an example of patchwork small companies, which in straightened times should be encouraged. There is no evidence to show that the expansion of these companies is dependent on the use of peat. Many claim to have developed peat-free alternatives, which the consensus among professional and celebrity gardeners is that they are as good or better. Since the widespread collection of compostable organic material from kitchen and garden waste, there is now an abundance of material. Considerable damage has already been done to the environment of Central Somerset with the loss of important species of plants birds and butterflies, which the incidental provision of deep water lake habitats at Ham Wall and Shapwick Heath do nothing to compensate for. The peat loss involved from the area between Sharpham and Westhay alone has probably lead to the release of over 4million tonnes of CO2 to date. The gardening public is largely ignorant of the important issues surrounding the use of peat. In fact many do not realise they are using it when they buy a plotted plant at their local garden centre. This ignorance costs the environment 2million cubic metres annually, which according to DEFRA estimates equates to the release of 660,000 tonnes of CO2.
Page 178 of 193 R80 While the formal need to ensure adequate landbanks for future quarrying The County Council already engages with other mineral planning is understood, the landbank concept seems to assume unlimited reserves. authorities and will continue to do so. It is clear that if production rates up to 2028 are anything like those of the recent past, we shall then be approaching a situation where the long term The future form of the Aggregates Working Party for the South West future of the industry in the area will need to be considered. Expedients should become clear in due course. such as deepening quarries will be expensive and in any case only delay the problem. The construction industry cannot expect a supply of natural aggregate at present prices to continue indefinitely. Use of imported supply merely shifts the problem to countries which have less stringent planning conditions than the UK (one sees this already in the matter of timber and the destruction of rain forests). Somerset alone cannot do anything about this, but I wonder whether a consortium of authorities which have a major interest in aggregate supplies could engage in discussions with the construction industry on the long term situation, and perhaps encourage research into alternatives for aggregates of natural origin. In this matter it is relevant that the EU Commissioner for the Environment, Janez Potocnik, fears the effect of future "price spikes in resources" on the economic situation generally. " ... increasing scarcity, rising prices and today's wasteful methods of using them [i.e. resources] will drive up costs yet further and reduce Europe's standard of living, the commissioner warned." (Reported in The Guardian, European edition, 30 December 2011). R81 I seem to recall - for this submission - one statement suggests a No comment. submission period of days, another years. No matter. The general theme could be using what we got. Now I could do a nice line of flash fused rock. Then there's the new roof material called powder coated iron that looks just like traditional stone - and it has thin film solar. Mutter, mutter.
R83 Would like to see the bio geological after use informed by consideration of No comment. the contribution that it can make to the ecological network on calciferous substrates inc railway lines that extends from Somerset to the Radstock area.
Page 179 of 193 R84 As you will be aware, the Somerset area has been subjected to coal It should be noted that the issue of non-minerals development would mining which will have left a legacy. Whilst most past mining is generally be determined by the District or Borough Planning Authority, with benign in nature potential public safety and stability problems can be reference to its Development Plan. The County Council will continue triggered and uncovered by development activities. Within the wider to work with the District and Borough Councils in Somerset, providing Somerset area there approximately 549 recorded mine entries and around specific technical input on minerals matters as required. 5 other recorded coal mining related hazards. Mine entries may be located in built up areas, often under buildings where the owners and occupiers The County Council does not consider that the wording on coal in have no knowledge of their presence unless they have received a mining paragraph 8.1 is unduly negative; however, this issue can be report during the property transaction. Mine entries can also be present in reviewed once again in preparing the Core Strategy. open space and areas of green infrastructure, potentially just under the surface of grassed areas. Mine entries and mining legacy matters should be considered by the Local Planning Authority to ensure site allocations and other policies and programmes will not lead to future public safety hazards. Chapter 8, Energy Minerals: The recognition that coal exists within Somerset is welcomed, it is considered sufficient for the Core Strategy to indicate that applications will be determined against National Policy if the Authority do not wish to set out a local policy on the issue. Some of the text in paragraph 8.1 is unduly negative, it is correct to say that the Council is not aware of any current plans to work the coal in the County. However the statement made in relation to the Government preferring to see energy supplied by cleaner alternatives is not a true representation of UK Energy Policy which clearly indicates a need for a balanced energy mix including an ongoing requirement to supply indigenously sourced coal for the foreseeable future. R89 Otterford Parish Council has no comments. No comment R90 Having had an opportunity to read it , there is nothing that has any impact No comment on Chard and therefore I have no comment to make.
R91 Providing work for local people is very important for our local economy - its It will be important for the Minerals Core Strategy to consider how criminal to have locals travelling 70miles or more each day to use skills minerals development impacts on the local economy; however, there that should be used locally. are limits to which the Strategy can and should influence the market.
R92 I have answered such questions as I felt able to deal with. Others which No comment required specialist or local knowledge I have left unanswered.
Page 180 of 193 R95 Many thanks for including Nature After Minerals (NAM) within your Noted and welcomed! consultees list. As a partnership programme NAM does not submit an individual consultation response and instead works with colleagues in RSPB and Natural England to submit a joined response. In this event we worked alongside our RSPB colleagues and as such our comments / thoughts are incorporated within the RSPB response that you received last week. Can I take this opportunity to thank you for the support that you have showed the programme within your issues and option paper, it is really encouraging to see that the work we do it being understood and appreciated and it is really rewarding to see biodiversity playing such a major role within emerging policy.
R96 The paper was discussed by Ashwick PC at the meeting held in January, The emerging evidence on fracking and the potential for applications when it was agreed that the PC was in broad agreement with the policy, to come forward will be considered in preparing the Core Strategy, but that the lack of information on fracking was a concern. and a decision made as to whether it merits specific reference.
R97 These comments only deal with Peat and Building Stone. Comments on No comment the remainder of the document are being made separately on behalf of Tarmac Limited.
R98.1 The general concensus of Whatley Parish Concil is: If the water level is It is noted that this respondent supports a) the protection of water protected; extraction is not increased; keep the balance for a competitive resources; b) no increase in extraction; and c) a competitive market field between large operators and the smaller quarries, then the industry in which larger and smaller operators both play a part. and environment can be protected for the future
Page 181 of 193 R99 There is a need to reflect the current Policy 26 and its supporting text Exmoor National Park acts as its own Mineral Planning Authority and relating to National Parks and minerals in the current Somerset and is therefore required to develop and adopt any relevant minerals Exmoor Structure Plan. It will be important in the absence of a policy tier planning policies that it considers are needed to protect the National above the Core Strategy that the essence of this policy, which ensures Park. The County Council will ensure that policy in its Minerals Core protection of the National Park in line with its purposes is included within Strategy does not conflict with the priorities of Exmoor National Park. the Minerals Core Strategy. Furthermore, I note that the only current reference you have to Exmoor National Park Authority is that it is not The County Council looks forward to further engagement with included within the Planning Authoirty of Somerset. As minerals matters Exmoor National Park and to cooperating in policy development do not conform to Local Authority boundaries I would welcome an across the sub-region. approach which considers the wider issues in Somerset. Further consideration needs to be given to the minerals needs of Exmoor National Park Authority and reflected within the Somerset Minerals Core Strategy. I attach our draft policy which provides for small scale minerals extraction for needs within Exmoor National Park only. However, our minerals needs will need to be met from outside the National Park and we will therefore be seeking minerals resources from surrounding authorities. We would welcome your consideration of the minerals needs for the Exmoor National Park Authority. We are working with Devon County Council to ensure a similar approach. R102 Paragraph 5.4 Support the text in paragraph 5.4 as it acknowledges the Support for paragraph 5.4 is noted, as is support for the identification national importance of the limestone resource of the Mendip Hills is, of Moons Hill Quarry, Torr Works and Whatley Quarry as strategic serving not only the needs of Somerset but also contributing to the needs sites. of the South West region, London and the South East. Paragraph 5.5 The identification of Moons Hill Quarry, Torr Works and Whatley Quarry, in Aggregates recycling is also considered in the Waste Core Strategy paragraph 5.5, as strategic sites for aggregate production is supported. and it will be important that the Minerals Core Strategy is developed These sites will enable Somerset to meet regional and national needs for in a way that integrates with and complements the Waste Core aggregates. Paragraph 5.13 Dorset agrees with Somerset's support of Strategy. activities to increase the re-use of waste materials including reprocessing of waste to minimise the need for primary aggregate as set out in Support for the "precautionary approach" to the protection of water paragraph 5.13. However, it is questioned whether aggregates recycling resources is noted. should be considered a resource and therefore dealt with more fully in the Minerals Plan as opposed to the Waste Plan Paragraph 5.61 / 5.62 The precautionary approach to managing water resources is supported.
Page 182 of 193 R103 It would also be valid to expect the Core Strategy to be in line with the Ensure that the Noise Policy Statement for England 2010 is principles detailed in the Noise Policy Statement for England 2010 that considered as part of the relevant Plans & Programmes in the indicates it will 'through the effective management and control of evidence base / document library supporting minerals policy environmental, neighbour and neighbourhood noise within the context of development in Somerset. Government policy on sustainable development: avoid significant adverse impacts on health and quality of life; mitigate and minimise adverse impacts on health and quality of life; and where possible, contribute to the improvement of health and quality of life. The actions taken under this National Noise policy would be expected to be similar to those that would apply to the Core Strategy and guided by the overall objectives defined within 'Securing the future - delivering UK sustainable development strategy', (HM Government, March 2005) under Guiding principles of sustainable development that are: Ensuring a Strong Healthy and Just Society - Meeting the diverse needs of all people in existing and future communities, promoting personal wellbeing, social cohesion and inclusion, and creating equal opportunity for all. Using Sound Science Responsibly - Ensuring policy is developed and implemented on the basis of strong scientific evidence, whilst taking into account scientific uncertainty (through the precautionary principle) as well as public attitudes and values. Living Within Environmental Limits - Respecting the limits of the planet?s environment, resources and biodiversity - to improve our environment and ensure that the natural resources needed for life are unimpaired and remain so for future generations. Achieving a Sustainable Economy - Building a strong, stable and sustainable economy which provides prosperity and opportunities for all, and in which environmental and social costs fall on those who impose them (polluter pays), and efficient resource use is incentivised. Promoting Good Governance - Actively promoting effective, participative systems of governance in all levels of society - engaging people's creativity, energy and diversity.
Page 183 of 193 R1 04 Sport England argues that creating a more active and healthy population The comments and interests of Sport England are noted and will help through the protection, enhancement and provision of opportunities for to inform, in particular, the Development Management section of the sport is a key ingredient of achieving this aspiration and should be Minerals Core Strategy. commensurately reflected in planning policy. Sport England is a statutory consultee on all planning applications affecting playing fields, land used for playing fields at any time in the last 5 years which remains undeveloped, or land which is identified for use as a playing field in a development plan. Sport England has produced a policy which outlines our approach towards the protection of playing fields entitled 'A Sporting Future for the Playing Fields of England' (see www.sportengland.org > Facilities & Planning). Sport England's policy to resist proposals which will result in the loss of a playing field, unless it meets one of five exceptions are defined in this policy document. The document sets out a policy presumption against development that would lead to the loss of, or would prejudice the use of, all or any part of a playing field, or land last used as a playing field. The aim of this policy is to ensure that there is an adequate supply of quality pitches to satisfy the current and estimated future demand for pitch sports within the area (whether the land is in public, private or educational use). This policy objective is also embodied within 'Planning Policy Guidance 17: Planning for Open Space, Sport and Recreation'. With regards to Minerals and Waste development, Sport England would therefore object to any development prejudicing the use of a sports and recreation facility including playing fields. Sport England encourages the early consideration of restoration options for recreational, formal and informal sport use. Mineral working and landfill can provide opportunities for restoration to sport and recreation after-uses. Such after- uses can help support the rural economy and provide tangible benefits to Somerset's communities. Depending on the nature of the opportunity such sports might include (but not limited to) Equestrian; Canoeing; Angling; Cycling; Orienteering; Motorsports; Triathlon; Sailing; Windsurfing and Water-skiing.
Page 184 of 193 R105 We believe that current monitoring of extant quarrying operations is slim Monitoring is undertaken with the resources available. and that on site staff are asked to report back to the planning team, putting them in a difficult position where they are trying to retain positive relations with the quarry operator, yet on occasions report issues with the application area. We would seek the encourage the protection of the The production of Ham Stone will be supported via building stone Northern Spur of Ham Hill (the area between the public house and war policy where there is an identified need and market, and where memorial) in a state similar to that of today, without many further years of production is in accordance with relevant planning considerations. excavation. It would seem appropriate to encourage the building stone resource to be supplied by Ham Hill South in order to protect this famous and intensively used landscape.
R106 Crushed rock landbank (page 6) Paragraph 5.8 A large landbank doesn't It is important that the Minerals Core Strategy helps the county to infer there will be an over-supply or wasteful use of resources. It doesn't maintain an appropriate land bank in Somerset and responses to mean more mineral will be worked as quarry operators are not the questions in the Options Paper will help to inform the development of consumers of the finished mineral product. Society as a whole is the end appropriate policy. consumer and a large landbank does not result in over use. Mineral extraction is too costly for it to be carried out unnecessarily or wastefully.
R109 Lovell Purbeck Ltd supports the policies for Building Stone in Somerset's Support is noted for the coverage of Building Stone in the Options Mineral Options Paper and the County Council's intention to ensure the Paper; though it should be noted that the Options paper does not continued provision of natural stone products for conservation, restoration present final policies. and new buildings. We amplify this support with comments on some of the issues. Paragraph 7.17 of the Options Paper refers to the need to Responses to questions 21-24 will help to inform the preparation of maintain the built heritage and character of Somerset. This aim is laudable the Minerals Core Strategy and its approach to supply and demand but it should be recognised that the built heritage and character of areas issues regarding building stone. which traditionally use stone quarried in Somerset often extends beyond the County boundaries. For example Lias limestone is traditionally used between Lime Regis in Dorset and Whitby on the east coast and in places where it outcrops in the Midlands but there may be no other source of supply in these areas. In a planning appeal in 1993 (T/APP/G3300/A/92/213195/P5) for the extension of a building stone quarry in Somerset the Inspector stated in his report; "... the Council, and objectors to the proposal, questioned whether stone from Tout Quarry truly met a local need in view of the fact that stone has been supplied to other parts of the country". However, the Council conceded, at the Inquiry, that "local" could be taken to mean Somerset and adjoining counties". It has since to our knowledge not been questioned whether stone from
Page 185 of 193 Somerset quarries satisfies a local need when it is actually used across the county boundary, particularly in Dorset, Wiltshire and Devon, to meet traditional needs. The use of Somerset stone in those areas should be acknowledged in your policy. We suggest that 7.17 is changed to state; "The Minerals Local Plan supports quarrying of building stones as long as it can be shown that the material is needed to maintain the built heritage and character of Somerset and areas where the stone is traditionally used".
R110 Wolffstone supports the policies for Building Stone in Somerset's Mineral Support is noted for the coverage of Building Stone in the Options Options Paper and the County Council's intention to ensure the continued Paper. provision of natural stone products for conservation, restoration and new buildings
R111 Oil and Gas Reserves: The Trust has major concerns about "fracking" and The emerging evidence on fracking and the potential for applications its potential adverse impacts on ground stability, structural stability to come forward will be considered in preparing the Core Strategy, particularly of historic buildings, and water quality. We are aware of and a decision made as to whether it merits specific reference. potential problems in relation to the acquifer in the Cheddar area. We would request therefore that the County Council undertakes a detailed study of the potential for fracking in Somerset and includes appropriate guidance and controls in the Minerals Plan.
R112 The Highways Agency currently has no observations to make. We would The County Council is happy to continue working with the Highways be please to be kept informed of future plan preparation stages and Agency in the development of minerals policy for Somerset. offered the opportunity to comment as required in the future.
R113 The main impact of mineral extraction in Somerset on Corsley Parish is Noted. Quarries operate within the limits set in their planning the volume of east bound lorries using the A362. A significant proportion conditions as part of their planning permissions. These conditions of this traffic is mineral related, in particular bulk aggregate vehicles. are enforced and monitored by the Minerals Planning Authority, in Although an A road, the A362 is unsuitable for HGVs because it is hilly Somerset this is Somerset County Council. Quarry traffic follow and winding: the volume of vehicles causes substantial environmental routes agreed as part of their respective sites transport assessment damage, through noise and vibration, and exacerbates risks to road between the Minerals Planning Authority and the Operator. While safety. Recognising this, Wiltshire CC have imposed a 17 tonne weight traffic is one of the largest re-occurring issues associated with limit on their section of the road (although implementation of the quarrying, operators are doing what they can to improve this e.g. eastbound limit has been deferred pending road improvements to the ensuring hauliers keep to the designated routes and establishing new A350). lorry schemes to reduce the impact of quarry vehicles. District and Parish Councils are consulted on planning applications.
Page 186 of 193 R114 The Internal Drainage Boards in Somerset have responsibilities for water The draft National Planning Policy Framework (NPPF) places clear management (flood risk, land drainage and conservation) within their restraints on peat extraction, which in effect should give the priority districts. This includes statutory powers over planning and development in, being sought to the completion and restoration of peat sites. The or near, any watercourse that may impact flood risk or water level County Council will need to be mindful of the NPPF as it prepares its management. IDB districts include all areas in Somerset where peat Minerals Core Strategy. extraction is carried out. We wish to respond to issues relating to the impact of peat extraction on flood risk and water level management. The It is noted that R114 advocates a 10 metre buffer from watercourses Somerset IDBs are implementing a number of Water Level Management for peat extraction. Plans (WLMPs) that aim to improve water level management for Sites of Special Scientific Interest and the Somerset Levels and Moors Special Protection Area. IDB Favourable Condition Projects in both the South Drain and Westhay Moor depend on the completion and restoration of peat sites in these areas. Priority should be given to the completion and restoration of peat sites within the Somerset Levels and Moors Special Protection Area. There are a large number of extant permissions that should be worked to completion and restored before new permissions are granted. Many active sites remain unfinished and are awaiting restoration. This situation is impacting routine IDB watercourse maintenance and water level management activities. It is also a significant cost and constraint for publicly funded IDB project that aim to restore wetland SSSIs to favourable condition. The IDBs would like to work with SCC and peat producers to help restore peat sites to high value, functional and maintainable wetland habitats that contribute positively to flood risk and water level management. Any work in, or adjacent to, watercourses requires IDB consent. This includes control structures, connections, blocking or diversion. The provision of access for watercourse maintenance is also required by the IDB. Peat extraction should not be permitted within 10 metres of a watercourse, in order to maintain bank stability ensure access for maintenance. If ditches are to be blocked or removed as part the extraction process, their drainage function and ecological features should be assessed and either offset elsewhere or restored after extraction.
Page 187 of 193 R115 General comments on Somerset's peatlands: Peatlands represent one of General comments on Somerset's peatlands and building stones are the most fragile and scarce natural habitats recognised within the UK and noted. Europe, and have formed by the accumulation of organic matter in specific environmental conditions over several thousands or tens of thousands of It is noted that the proposed approach on energy minerals seems years. Once damaged or destroyed (e.g. by peat extraction) these habitats appropriate. The emerging evidence on fracking and the potential for are not re-creatable within a practical human timescale, if at all. Peatlands applications to come forward will be considered in preparing the Core are also a proven 'carbon sink' and their protection and preservation Strategy, and a decision made as to whether it merits specific reduces potential carbon loss and helps mitigate against effects of climate reference. change. This is in addition to peatlands' intrinsic value as a nationally and internationally important wildlife habitat, and also containing important archaeological remains whose in-situ preservation depends on specific hydrological and anoxic conditions being maintained within peat deposits. Peat extraction on the Somerset Moors was historically an important local industry and employer. Today the industry it is greatly diminished in terms of numbers of peat producers still active, and is likely bolstered by adoption of operations involving the use of imported peat. Government policy regarding the damaging effects of peat extraction, and promoting the use of sustainable alternatives , is unambiguous and clear in its direction of travel (e.g. the peat-related targets in the Natural Environment White Paper, June 2011; namely 'Amateur gardening peat-free by 2020' and 'Professional horticulture peat-free by 2030').
General comments on Somersets' building stones. The recent English Heritage / British Geological Survey project 'Strategic Stone Study' identified approximately 45 main building stone types used within Somerset; this figure nearly doubles when one considers the many local variants of these stones with informal names applied to subtly different lithologies. The character of many of Somerset's prestigious buildings, monuments and villages relies substantially upon the use of locally quarried stone. However, many of the former quarries have long disappeared, or been abandoned, or become extensively overgrown and are now difficult to locate. Consequently the original source quarries of some of the older, traditional varieties of building stone used in Somerset either no longer exist, or require considerable detective work to re-find. Even where the location is known or re-discovered, the implications of opening these quarries requires careful determination. For example, several former quarries within the same vicinity may have yielded very similar stone types, but knowing which would represent the best future
Page 188 of 193 source of the stone, and would be the most practical to re-open (even on a very small scale for conservation/ restoration purposes) is likely to require a degree of research work, and possible field survey. Although the demand for some stone types is small and highly specialised, it is present. For example, during the preparation of the Building Stone Consultation Document for Somerset Mineral Planners, discussions with stone masons in the Cheddar area revealed that quarry sources for one popular variety of local stone, 'Draycott Marble', were no longer available - and the only opportunities for obtaining this stone for restoration, conservation or ornamental purposes were by re-cycling from demolition yards or from large arched gate posts constructed from the stone. A similar situation exists in Wedmore, where many of the buildings and walls in central Wedmore, including the church, are constructed from local Wedmore Stone. However, all the original quarry sources for Wedmore Stone have long been abandoned, and present building work requiring the stone relies on reclaimed Wedmore Stone or re-use.
ENERGY MINERALS The proposed contents and policy approach to be set out within the Core Strategy seem very appropriate. Within Somerset, energy minerals such as coal, and offshore opportunities (oil and gas) are unlikely to be significant for the reason set out in the consultation paper. For completeness, it may be beneficial within the Core Strategy to draw attention to Somersets' contribution to energy generation, e.g. through development of Hinkley C etc.
One aspect which is not mentioned within the document, and yet is becoming an increasingly 'hot-topic' is the process of hydraulic fracturing ('fracking'), especially given the recent news about possible exploration in the Mendips (e.g. www.bbc.co.uk/news/uk-england-bristol-15099549). R116 The fact that shale gas and underground water is virtually ignored is very The emerging evidence on fracking and the potential for applications poor to come forward will be considered in preparing the Core Strategy, and a decision made as to whether it merits specific reference. R117 Refer to main comment reference local issue No comment. R118 We have read with interest the Minerals Option Paper and agree with Noted. most of the paper.
Page 189 of 193 R119 South Somerset District Council is specifically interested in existing The County Council looks forward to further engagement with South Minerals workings within its area and welcome discussions on any Somerset District Council in developing new minerals policy and in proposed; safeguarding zones, extensions to existing quarries or particular the quarries of Ham Hill North and South. restoration proposals associated with existing works. The District Council note that the quarries of Ham Hill North and South at Stoke Sub Hamdon are of specific concern to residents given the importance of the stone for use in local conservation work balanced against the potential impact on the local settlements of Stoke Sub Hamdon and Montacute.
R120 I have observed that different quarries vary in their relationships with the Any new such initiative would need to be industry driven to be local communities and their willingness to co-operate. Liaison committees successful. There are already platforms / fora for such dialogue to seem to operate on a quarry by quarry basis. I wonder if some way could occur, such as the Minerals Quarry Producers. be found to spread good practices so that the approach of the "better" quarries might be shared more widely. Maybe a voluntary code of practice which all quarries could sign up to might facilitate this? It could cover matters such as complaints handling and co-operation on environmental matters.
R122 1. There is great emphasis on the amount of aggregate (i.e. land bank). 1. Consider reference to policy controls relating to increase in land However as the individual land banks are commercially confidential (or not area and change to the output rate from proposed minerals quantified) this could be difficult to control. It is the area (footprint) and the development. rate of output through the gates which has the biggest impact to the residents of Somerset. We would therefore propose that there is some 2. The importance of securing an appropriate approach to restoration planning policy covering the increase in land area and any change to the is noted. output rate (tons pa). 3. The emerging evidence on fracking and the potential for 2. Restoration and after use is a fine idea but there is limited funding applications to come forward will be considered in preparing the Core (apart from those currently active which have a restoration/sustainment Strategy, and a decision made as to whether it merits specific funding arrangement). It is suggested that any new quarrying planning reference. approvals which extend output in time or quantity should contribute to a restoration/sustainment fund for closed quarries (in addition to the existing local restoration/sustainment fund).
3. Please consider including a policy on "fracking".
Page 190 of 193 R123 Protection and assurance of the monitoring systems to insure the natural The protection of local amenity will be covered by appropriate waters sources. Noise, dust, light pollution and blasting especially night development management policy. noise – dumper trucks, loading.
It is particularly appreciated by the residents of Downhead that there is no quarry activity on Sundays. Now just recently no working at the subsidiary plants – brickworks.
R124 Protection and assurance of the monitoring systems to guarantee the The protection of local amenity will be covered by appropriate confidence of industries and residences so affected by the cumulative development management policy. impact of mineral operations.
Night noise – Dumper Trucks and loading
Appreciation that there is no quarrying or subsidiary plant working on a Sunday/Saturday afternoon. R125 5.8 This paragraph does perhaps suggest a misunderstanding of how the The landbank should be used as an indicator of when new reserves mineral commercial market works. Minerals will only be extracted and may be needed to avoid both a shortage in supply and over-supply. sold if customers want to buy. How can minerals be oversupplied If too large a landbank is maintained there is the risk that primary particularly if there are no substitutes, which there are not in resources could be unnecessarily worked, rather than consider Somerset? A 350million ton landbank (or indeed a 465million ton alternative sources such as secondary or recycled aggregates. The landbank after the recent Tor permission) does not mean that any importance of adopting a sustainable approach will be embedded more minerals will be quarries that if there were a 120million ton throughout the Core Strategy. landbank (12 million tons a year multiplied by ten years).
Again the assumption that minerals in the Mendips are a finite resources is questionable, see comments of objective D. R126 S. Morris Ltd is based in Somerset and is a major purchaser of aggregates Chapter 5: it will be important to ensure that the Core Strategy – perhaps the largest independent aggregate purchaser in the South provides a balanced policy framework, taking into consideration the West. Annual aggregate purchases approach 400,000 tons. The economic impact of minerals working alongside its environmental and purchased aggregates are primarily used in added value construction social impacts. products. Chapter 7: it is vital that that the Core Strategy takes a balanced view S, Morris Ltd is also the owner of Tout Quarry located near Somerton when assessing the potential impacts of proposed development. Somerset. As this quarry Blue Lias building stone is extracted and stone from other quarries is imported and processed.
Page 191 of 193 Chapter 5: Aggregates Policy should clearly prevent a larger landbank providing a reason for refusal of an extension to one of the non strategic quarries. It is important to maintain a variety of sources of local limestone to provide a competitive market. The economic activity associated with production of added value stone products is economically important in Somerset. These activities rely on competitively priced primary aggregates as there are no substitutes available.
We are aware of the point that if the price of primary aggregates were to be raised significantly it may be economic to transport in substitutes and therefore reduce the amount of quarrying in the area. This argument disregards the environmental cost and the effect on local people, of moving the substitutes over large distances. Furthermore the added value of industries would become economically unviable if the input prices were to be increased.
Chapter 7: Building Stone The narrative in the chapter supporting the quarrying of building stone is necessary and strongly supported. But it cannot be expressed strongly enough that the red tape associated with bringing small scale proposals forward has a significant negative effect which will cause these sort of quarries to dwindle away.
7.11 states “There may, however, be economic factors that mean that………applications or new sites are not received”. The primary reason for this are the large costs associated with these sort of applications. The application requirements are way out of proportion to the operations sought and the finance available.
7.12 reinforces this point and is strongly supported.
7.13 states “guiding applicants with regards to building stone proposals……….” This may help but it is substantially reducing the processes that have to be undertaken, that will encourage proposals.
Page 192 of 193 R127 Point 6.24: Suggest no water based activities, leave to the wildlife. The Minerals Core Strategy will need to set an appropriate policy framework that takes into account the need to protection It is felt that all Areas of Natural Beauty and Sites of Special Scientific environmental and historic assets in Somerset. Interest and any rare species found therein should take precedent over and quarrying and any other activities both during the quarry's lives and after.
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