Minerals and Waste Development Framework Statement of Representations Somerset Building Stones Paper – Issues consultation for the Minerals Core Strategy Statement of compliance with Regulation 30 of the Town and Country Planning (Local Development) (England) Regulations 2004 October 2010 Contents 1. Role of the Statement of Representations 2. Somerset Building Stones Paper – Issues consultation for the Minerals Core Strategy: a brief overview 3. The questions posed 4. Representations 5. Consultation Responses 6. Feedback on the consultation 7. Other Issues 8. Key Issues 9. Concluding remarks Appendix A – Consultees 1. Role of the Statement of Representations When a development plan document (DPD) is submitted to the Secretary of State for independent examination, the DPD must be accompanied by documents such as the ‘Statement of Representations’ that demonstrate how the authority has complied with relevant requirements contained in the Town and Country Planning (Local Development) (England) Regulations 2004. The purpose of the Statement of Representations is to set out: Which bodies and persons were invited to make representations on the document. How those bodies and persons were invited to make representations. A summary of the main issues made in the representations received. How the representations have been taken into account. This submission stage of the Somerset Building Stones Paper – Issues consultation for the Minerals Core Strategy is known as a Regulation 30 document, because it is carried out in accordance with Regulation 30 of the Town and Country Planning (Local Development) (England) Regulations 2004. 2. Somerset Building Stones Paper – Issues consultation for the Minerals Core Strategy: a brief overview From 2nd August 2010 to 24 th September 2010, Somerset County Council undertook consultation relating to the supply of building stones in Somerset in order to identify key issues to be considered whilst creating planning policy for building stones in the future. This exercise was the beginning of the consultation process for the development of the Somerset Minerals Core Strategy (MCS), which will replace the MLP. The consultation was distributed to 330 specific internal and external consultees (see Appendix A) and made publicly available via the Somerset County Council website. The following subject headings were used in the consultation paper: • Introduction • Policy background and framework • Valuing the built heritage • Resource and source • Quarrying of building stones Within this structure, a total of 18 specific questions were posed, seeking to gather opinions on the above topics. The questions are detailed in the next section. Consultees were also encouraged to provide additional comments and questions. 3. The questions posed QUESTION 1. Should there be a mechanism in place to help match policies and decisions relating to the provision of local building stone (e.g. within the MCS) with policies relating to the demand for local building stone (e.g. local district Conservation Areas, new housing allocations)? QUESTION 2. Is the importance and use of local building stone as part of Somerset’s built heritage and local character recognised and/or promoted enough? QUESTION 3. How much local building stone (if any) are you or your organisation likely to need over the next 15 years? Is this mainly for restoration, conservation, ornamental, decorative or new build works? QUESTION 4. Is the need for building stone for conservation / restoration work similar to that for new buildings, or is the importance / demand of one greater than the other? QUESTION 5. How can the Minerals Planning Authority facilitate the recycling of local building stone for use by the industry? QUESTION 6. Where the use of natural stone is impractical (for example, for economic or non-availability reasons), does reconstituted or cast stone offer an alternative material for heritage and aesthetic (e.g. matching) purposes? Should the MCS provide guidance on the use of such reconstituted stone? QUESTION 7. Should imported stone be used in preference to local Somerset or UK sourced stone where suitable stone is available and economically viable to use? QUESTION 8. Should there be a ‘hierarchy’ or ‘order of preference’ for the sourcing and use of building stone? For example, reclamation of used local stone, then use of fresh quarried local stone, then use of UK sourced stone, then use of imported stone, then use of reconstituted stone? QUESTION 9. Are there any benefits or preferences in maintaining on-site stone dressing and cutting facilities (e.g. at the quarry source) or should these be operated off-site? QUESTION 10. Should there be a ‘hierarchy’ or ‘order of preference’ relating to the quarrying of fresh building stone where geological resources are available? For example, the lateral extension or deepening of existing quarries, the re-opening of former quarries of the opening of new quarries? QUESTION 11. Are there any benefits in the re-opening of former quarries instead of creating new quarries? QUESTION 12. Should preference be given to the use of more, smaller quarries as a source of local building stone, or fewer larger quarries supplying the county’s needs where possible? QUESTION 13. Under what circumstances (if any), should the opening of quarries for small scale extraction of local, specialist building stone types (e.g. 1000 – 2500 tonnes per annum) be considered? QUESTION 14. What potential impacts of quarrying mentioned above are particularly relevant or concerning for Somerset, and are there other issues not mentioned? QUESTION 15. How important is the carbon footprint of quarrying, working and transporting local building stone? How can it be mitigated? QUESTION 16. What are the opportunities and priorities for the future restoration and after-use of completed building stone quarries? QUESTION 17. Should areas of proven local building stone sources be safeguarded for future extraction, and if so, how? QUESTION 18. If developments threaten to sterilise proven valuable resources of building stone, should these be extracted and stored prior to the development commencing? 4. Representations A total of 37 representations were received from a broad range of consultees, including parish councils, quarry operators, stonemasons, geologists, conservation organisations and internal partners. All representations have provided valuable comments. Some respondents commented on all 18 questions with the majority commenting on 12 or more questions, whilst others commented on only one or two questions. Fifteen questions received over 20 responses and all questions received 14 or more responses. Apart from demonstrating that the County Council has complied with the requirements of the Town and Country Planning (Local Development) (England) Regulations 2004 the intention of this Regulation 30 statement is to summarise the representations received in order to assist the development of mineral planning policy for the future extraction of building stones in Somerset. While this Regulation 30 statement does not include all of the comments and information from every representation received, some comments are included in the following pages. Detailed comments from specified consultees are presented in text boxes. 5. Key Issues Within each subject heading a number of key issues were identified which formed the basis of the questions posed in the consultation paper. The key issues under the various headings were as follows: Policy background and framework • Minerals Local Plan – current strategy for building stones • Local Plan policies for building stones • Minerals Core Strategy Valuing the built heritage • Somerset’s building stones • Conservation Areas Resource and source • Supply of building stone • Demand for building stone • Reclamation of used stone • Use of reconstituted stone • Use of imported stone • Dressing of stone Quarrying of building stones • Re-opening of former quarries and new quarries • Scale of extraction • Impacts of quarrying • Restoration and afteruse • Mineral Safeguarding Areas 5.1 Policy background and framework Question 1 Should there be a mechanism in place to help match policies and decisions relating to the provision of local building stone (e.g. within the MCS) with policies relating to the demand for local building stone (e.g. local district Conservation Areas, new housing allocations)? A total of 26 responses were received in relation to Question 1. The overwhelming number of responses were in favour of a link between policies in the MCS and local development plans. A number of concerns were raised however that certain building stones served a much larger area than would be considered as ‘local’ and therefore policies restricting stone use to the local area would be problematical. • [R51] ‘Ham Hill stone has been used in the construction of historic buildings from Cornwall in the west to Kent in the east, and from Hampshire in the south to Cambridgeshire in the north.’ • [R53] ‘Yes, it is very important to match supply and demand.’ • [R60] ‘Should the policy also reflect on the demand for some Somerset stones outside the County.’ [R15.2] ‘There should definitely be a mechanism to match the provision of building stone to the demand. There is clearly a demand for a range of local building stones within the County, this is not currently matched to supply as many local stones are simply not available as fresh quarried material.’ [R61] ‘There should be some mechanism to help ensure that, where development is proposed