Minerals and Waste Local Plan: Pre-Submission Publication

Comment

Representation ID: 99481

Received: 19/12/2022

Respondent: The Lyndon Pallett Group Ltd

Agent: PDE Consulting Limited

Timescales
In examining the sites put forward for allocation within the MWLP we have taken note of the anticipated lifespan of the sites which have been proposed for allocation (as described above). Having taken into consideration the proposed start dates and anticipated lifespan of the developments it is notable that there will be a slight reduction in mineral production towards the middle of the plan period. This is because virtually all of the proposed allocations are planned to commence towards the start of the plan period (2022-2025). This means that as the shorter life developments end, overall mineral production will decline as only one site (MIN 208) is planned to commence later within the plan period.

If the Feltwell extensions were to be allocated within the MWLP this would help to bridge a gap within the centre of the plan period following the cessation of extraction from the shorter-lived sites prior to the commencement of further extraction later within the plan period. The proposed extensions to Feltwell would represent a mid-range in terms of lifespan, operating for approximately 11 years from a start date of 2024 when mineral extraction would cease within the existing quarry.

Mineral Production Shortfall

With regard to mineral production, the MWLP makes provision for 1,506,000tpa of sand and gravel production over the plan period. This demand figure is based upon sales during the period 2011 to 2020 plus an allowance of 10% in order to account for increased mineral demand during the three year period between 2018 and 2020. It is, however, recognised within the industry as a whole, that there is an ongoing decline in permitted aggregate reserves nationally.

The Mineral Products Association (MPA) recently published a report titled Aggregates Demand and Supply in Great Britain: Scenarios for 2035.
Within the report the MPA note that the decline in permitted reserves for primary aggregates urgently needs to be addressed within the next 15 years.
Demand projections suggest that, by 2035, some 277 to 323 million tonnes of aggregates will need to be supplied each year. This means that between 3.8 and 4.1 billion tonnes of aggregates will be required between 2022 and 2035, compared with a total of 3.2 billion tonnes of aggregates supplied in the previous period, between 2008 and 2021.

In Britain as a whole for the past decade, for every 100 tonnes of sand and gravel produced from permitted reserves, only 63 tonnes have been replaced through new planning permissions.

Whilst there is an element of uncertainty within the MPA forecasts due to future changes in economic
output and changes in industry practices which may impact the demand for aggregate, it is still predicted that aggregate demand will increase over the next 15 years. This is based on the general resilience of the construction industry to recent economic uncertainty and government investment in upcoming infrastructure projects.