MPA Response to the Draft National Planning Policy Framework Consultation.

This submission provides MPA's responses to questions posed by the House of Commons CLG Committee:

The National Planning Policy Framework (NPPF) sets out the Government’s objectives and national policies for planning in England. This section contains the objectives and policies that relate specifically to minerals but it should be read alongside other relevant parts of the NPPF, which relate more generally to all forms of development. Read MPA's response by clicking on the link, left.

MPA's views on the Government’s proposal for changes to planning application fees in England.

MPA have serious concerns about those parts of the Bill which relate to community empowerment and reform of the planning system.

MPA raises a concern about proposals to develop land adjacent to the Tolworth Depot site and to support the representations made on behalf of Day Group Ltd.

MPA's representations on the Validation Document  produced by Worcestershire County Council. MPA feels the Validation Document is well intended but it substantially repeats information in DCLG’s The Validation of Planning Applications and several other government advisory and policy documents. It is still potentially useful to applicants but needs substantial editing to reduce it to what the County Council requires locally and then bookmarking it to the other documents, policy and advice already referred to.

West Sussex Minerals and Waste Development Framework -
comments on the background papers by the Mineral Products Association.

The MPA believes the Suggested Policy Response is unwarranted and unworkable and goes against national policy on aggregates supply.

Whilst MPA can support the intention of the policy (i.e. to ensure mineral proposals are sustainable) it is unrealistic to expect every application to meet all of the government’s national objectives for minerals planning (MPS1, para 9). Only some objectives in the list will be applicable to an application for development. For example, securing an adequate and steady supply of minerals is a function of the development plan process, not an individual application.

Having reviewed the document, MPA only wish to make one comment. We support the proposed Further Proposed Modification MOD370 in respect of extending mineral safeguarding High PSV Hard Rock resources north of Garth.

Whilst MPA generally supports the conclusions of the RTS’s analysis of Newport’s position and the conclusions of the ‘Former Gwent’ Aggregates Safeguarding Study there is no formalised procedure for the redistribution of apportionments, which gives our members cause for concern. Unless there is agreement before the adoption of plans, there will be a risk that unilateral decisions may be taken by some authorities under the erroneous assumption that future agreement with others will be forthcoming, when in fact it may not be.

The MPA's response to the Leeds Local Development Framework Consultation. The MPA feels that statements in public documents need to be carefully phrased to bring out the nuances.

The MPA responds to the Leeds Local Development Framework Consultation.

The MPA supports the proposed Additional Focused Change FC19 in respect of extending mineral safeguarding to the edge of settlements.

The MPA supports the selection of MSA Option 1 and therefore the favoured MSA Option. It is important to safeguard the whole deposit since designated areas are not absolute constraints and mineral working could take place in them should the national need tests be satisfied. Despite the possible duplication involved in such designated areas, the MPA believes it is important for local authorities to recognise the significance of safeguarding minerals and taking them into account in all planning decisions whatever the status of the area concerned.

MPA is in general support of the policy approach for minerals. For Specific comments click on the download..

MPA's response to the Hampshire Minerals and Waste Core Strategy consultation.

The MPA's view continues to be that the Regional Guideline for Aggregates Provision for the South East of 195 mt of land-won sand and gravel for the period 2005-2020, which equates to an annual average of 12.18 mt is an appropriate figure for the South East, with an appropriate apportionment for East Sussex to be determined in due course in consultation with SEERAWP.

MPA's response to Norfolk County Council's Minerals and Waste Local Development Framework -Minerals Site Allocations Development Plan Document.

MPA's response to the Peak District National Park Authority's Local Development Framework - Core Strategy Preferred Approaches consultation.

MPA highlights that it feels strongly that, whilst the responses to the questions posed in the consultation will be of relevance when considering the future of the Regional Aggregate Working Parties, the conclusions of the research commissioned on the subject by CLG in 2007-2008 are of much greater significance.

MPA's response to Northumberland County Council's Local Development Framework: Core Strategy Minerals and Waste Consultation.

MPA's response to Essex County Council's Mineral Development Document: Site Allocations Issues & Options Consultation.

MPA consultation response to Tees Valley Joint Strategy Unit on their Joint Minerals and Waste DPD. The main concern was the approach towards mineral safeguarding. Comments were also raised on the use of the term ‘setting’ in Policy MWC1.

MPA response to the Core Strategy Policy Directions Consultation. A number of issues were raised. In particular stressing the importance of mineral safeguarding and that Mineral Planning Authorities need to do more than avoid other forms of development in MSAs. Comments were also made on the approach towards allocating sites.

MPA response to the Management Plan Draft Version 2 consultation.

MPA response to Durham’s Minerals Safeguarding consultation. Issues were highlighted on their approach to mineral safeguarding. In particular a reminder that there is no absolute presumption against mineral working in designated areas and Minerals Planning Authorities making a judgement of what might be required in the foreseeable future and safeguard those resources.

MPA members continue to be of the view that any infrastructure needs that should arise as a consequence of minerals development cannot be covered by a one-size-fits-all CIL system which is tailored to the circumstances of built development.

Mineral Products Association members are of the view that key aspects of the proposals for dealing with stalled ROMPs in Wales are disproportionate to any threat that an uncompleted review might pose and carry unreasonable potential implications for both mineral operators and the Welsh economy.

MPA's response explains that our members are seriously concerned about the manner in which this consultation has been conducted.

MPA response to the West Midlands RSS Phase 3 Revision Options Consultation. A number of issues were raised. In particular the approach towards mineral safeguarding and the confusion over what should be safeguarded. The MPA strongly supported a continuation of apportioning future supply by existing methods.  

MPA response to the Core Strategy Preferred Options Consultation. Issues were highlighted on the approach towards mineral safeguarding and landbanks.

MPA consultation response to Monmouthshire on their Local Development Plan Pre-Deposit (Preferred Strategy). Issues were raised in relation to the minerals section in particular safeguarding, landbank and restoration.

MPA consultation response to Powys Council regarding their UDP Further Proposed Modifications June 2009. MPA queried why Powys had not included a modification to ensure sand and gravel resources are safeguarded. A requirement under a formal direction from Welsh Assembly Government (WAG).

MPA response to Conwy on their Local Development Plan Deposit Proposals. The main concern was the approach towards mineral safeguarding. In particular highlighting the need for safeguarding resources even if no allocations for hard rock are required.

MPA consultation response to Nottinghamshire on their Minerals Safeguarding Draft Background Paper. A number of issues were highlighted on this background document. Among them some confusion between MSAs and buffer zones. Also prior extraction is not about making propositions attractive to developers it is about ensuring irreplaceable resources are not sterilised.

MPA's response to the partial review of the South East RSS Review of Policy M3 - Primary land-won aggregates and subregional apportionment.

In this MPA response we fully support the comments made by both the Mendip Quarry Producers and officers of Somerset County Council and must join them in registering our own formal objection to the proposals. In particular, the MPA is of the view that there can be no justification for the significant increase in CO2 emissions that will result directly from the restrictions on the A362 (Order 2 – Ref:KAD/TRO/CORY).

MPA consultation response to Cardiff Council on their Deposit Local Development Plan. The main concerns were surrounding the approach towards landbanks. There were also issues with the proposed approach towards mineral safeguarding.

MPA response to Lake District National Park Authority on their Draft Core Strategy Policies consultation. Comments were made on the mineral extraction and mineral safeguarding policies. The main concern highlighted was the suggested approach of only safeguarding building stone and slate resources.

MPA response to Warwickshire on their Core Strategy Revised Spatial Options Consultation. A number of concerns were highlighted on the quantity of mineral required to meet apportionment and maintain landbanks, Mineral Safeguarding Areas, transport and the how criteria for site allocations/applications should not be the same.

MPA consultation response to Pembrokeshire Coast on their Deposit Local Development Plan. The main concerns highlighted were in relation to minerals supply, with no mention or policy on apportionment and maintaining landbanks. There were also flaws in the approach towards mineral safeguarding.

MPA response to Kirklees Council on their LDF Core Strategy Options Consultation. The concerns highlighted were surrounding the lack of evidence/figures presented by Kirklees on reserves and the quantity of minerals, which will be required to meet their apportionment and maintain landbanks.

MPA consultation response on the Refined Options Core Strategy. Issues were highlighted on the Peak District NPA approach towards mineral safeguarding and limiting restoration and after-use solely to the improvement of biodiversity and landscape.

MPA consultation response to Bridgend on their Local Development Plan Pre-Deposit Proposals. The main concerns highlighted where in relation to minerals supply, landbank and mineral safeguarding.

MPA consultation response to Rhondda Cynon Taf on their Local Development Plan Deposit Draft. The issues raised where in relation to landbank and mineral safeguarding.

Mineral Products Association response to Essex Minerals Development Document (MDD) Further Issues and Options Consultation.