Object
Minerals and Waste Local Plan: Pre-Submission Publication
Representation ID: 99472
Received: 19/12/2022
Respondent: Sibelco UK Limited
Legally compliant? No
Sound? No
Duty to co-operate? Not specified
The supporting text to MPSS1 makes a number of assumptions without evidence and quite fatally disregards the fact that minerals can only be worked where they are found. In particular, the policy is dismissive in relation to silica sand being a mineral of national importance. It follows that there will be a number of potential sites either within or in close proximity to designated areas that may be acceptable for mineral extraction upon balance. However, the Council’s approach is to blanket dismiss areas and hide behind designations is a flawed understanding of what they are intended for.
We suggest that a hierarchy of delivery to properly set out a spatial strategy for silica sand development is included to properly plan for the forecasted need for silica sand. This will help to ensure development of mineral resources to directed to more acceptable locations. It is considered that the criteria -based approach could in fact have the opposite approach given the incoherence of the silica sand policies both in approach and wording.
We suggest Policy MPSS1 should be reworded as follows:
Proposed Changes
“Planning applications for silica sand extraction located outside of allocated sites [insert: 'will only be permitted where it can be demonstrated that greater priority schemes, as outlined in Policy MS2, are either unavailable or not viable to meet future silica sand needs. Otherwise planning applications which would'] address the shortfall in permitted reserves, will be subject to compliance with the Minerals and Waste Local Plan policies and all the following requirements:
a. To address the shortfall in silica sand supply to meet the requirements of the existing [delete: 'processing plant'] [insert: 'site'] (as set out in the NPPF);
(no changes are proposed to policy requirements b. to q. of MPSS1)