Memorandum from The Council for the Protection
of Rural England (CPRE)
THE NEW DEAL FROM THE AGGREGATES INDUSTRY:
A PARTNERSHIP PROPOSAL FOR ENVIRONMENTAL IMPROVEMENT—A CPRE
RESPONSE
INTRODUCTION
1. We acknowledge that the QPA has worked
hard to produce this comprehensive set of measures and consider
that these would undoubtedly help to reduce bad practice in some
areas and help to raise environmental standards across the industry.
For this, it should be commended. Nevertheless, we do not consider
the package provides an alternative way forward to the proposed
tax on the extraction of primary aggregates. We explain this position
further below.
2. There are elements of the package which
we strongly welcome. For example, the proposed introduction of
planning enforcement fees and the industry-wide introduction of
ISO 14001. We remain concerned, however, at the "voluntary"
aspect of the package, and unconvinced that it will be taken up
sufficiently by the whole industry—particularly by non-members
of the QPA.
3. A key weakness of the package is that
the New Deal does not address the fundamental issue of how to
influence demand for primary aggregates and therefore of reducing
the actual amount of material that is quarried. This is key to
CPRE's support for an aggregates tax which over time would tackle
this issue by sending a clear signal to industry of the environmental
costs of quarrying. The fact that it is usual for an extra 10
per cent of construction material to be provided on a building
site to allow for wasted materials shows a clear need for a tightening
up of practice even if only to reduce waste. Although we accept
that in the short term demand for primary aggregate is likely
to be relatively inelastic, we believe that an aggregates tax
would provide an incentive which would mean that less primary
aggregate would need to be quarried over time.
Our main concerns about the New Deal are set
out in more detail below.
AVOIDANCE OF
RESPONSIBILITY
4. The package seems to pass responsibility
for action to others in several places. Bearing in mind this is
a package of voluntary measures, the effect is to substantially
weaken confidence in delivery. For example:
— it puts forward the case that in
order to increase the amount of recycled materials used as opposed
to primary aggregate, a revision of construction specifications
is needed. Although this may help, the quarry industry should
be looking for ways to increase the quality of recycled material
itself in order to encourage greater use;
— it supports measures by the Government
to ensure that Mineral Planning Authorities (MPAs) have the resources
to monitor and regulate the industry. Good practice should mean
there is little need to provide better monitoring and enforcement
resources for local authorities and companies should already be
taking measures to address past mistakes; and
— it promises to try to increase the
amount of aggregate transported by rail—but stresses that
this will require reliance to be placed on EWS and the rail system.
CPRE feels that there is more that the industry
could do to tackle issues such as these itself, as well as forming
partnerships with other stakeholders.
LANDSCAPE IMPACTS
5. Two major impacts which the London Economics
report, The Environmental Costs and Benefits of the Supply
of Aggregates, identified as being of primary concern to the
public were the impacts of quarrying on flora and fauna and visual
landscape impacts. Despite commitments to ISO14001 and other measures,
there are no mechanisms for dealing with those specific problems
in the new package. CPRE believes that the most important way
to reduce these environmental impacts is to reduce the rate of
extraction. While the New Deal offers to review permissions every
15 years, this will not tackle the issue that the current generation
will have to put up with the impact now and is a desperately slow
way of securing change.
VALUE OF
THE PACKAGE
6. The QPA has estimated that the package
is worth £150 million annually. The Government's research
into the costs and benefits of the supply of aggregates has come
up with a figure of £380 million for environmental impacts—which
is significantly more than the QPA's offer. Clearly this suggests
that the package does not put a high enough value on the environment
and the impacts that the industry has.
7. In addition, we believe it is worth submitting
the package to a critical assessment of whether it achieves the
objectives set by Government, that the package should be deliverable,
guaranteed, proportionate and credible. We believe that it does
not satisfy these tests and is therefore not an adequate substitute
for the aggregates tax.
8. In our view the New Deal is:
— voluntary and not industry-wide and
therefore is not fully deliverable;
— not able to demonstrate how the commitments
can be guaranteed because of their voluntary nature;
— not proportional to the value of
the environment as suggested by London Economics; and
— not credible on its own, since it
does not tackle the demand side of aggregate provision, but it
could complement other measures.
CONCLUSION
9. We are pleased that the industry is now
thinking carefully about the impact that it has on the environment,
and welcome the ideas that it proposes in this package. We hope
that in due course the quarrying industry will realise the benefits
of implementing many of these measures whether or not a tax is
introduced in the interest of economic gain and protection of
natural resources for future generations.
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