Written from Mineral Products Association
(ARSS 107)
SUMMARY:
Continued Government commitment to maintaining an
adequate and steady supply of minerals is crucial to the economy
and to the interests of our members. RSSs have contributed nothing
to the achievement of that steady supply.
The MPA therefore supports the revocation of RSSs
provided that suitable mechanisms are in place to ensure that
mineral planning authorities have an obligation to act collectively
to make provision for an adequate and steady supply of all minerals.
MPA welcomes the statement from the Chief Planner
that the longstanding arrangements for minerals planning, including
the technical advice provided by the Aggregate Working Parties
and the CLG Guidelines for 2005-20 should continue to fulfil an
essential role.
There is an urgent need for further clarification
from Government in the wake of the revocation action.
FURTHER COMMENT:
The MPA fully supports the submission made by the
CBI Minerals Group of which MPA is a member.
The comments in this submission relate principally
to aggregates provision which is the business of the majority
of our members.
Mineral resources are not distributed evenly across
the nation and they can only be worked where they occur. It is
essential therefore that there is some coordinating framework
to ensure that construction material is supplied where it is needed,
in the most sustainable way, even when there is a geological deficit
of suitable minerals.
The Managed Aggregates Supply System (MASS) has been
successful in fulfilling that role for a period in excess of thirty
years. The MASS pre-dates the establishment of RSSs and RSSs have
never been essential to that system.
MPA members are of the view that the statutory role
of RSSs in planning for aggregates proved to be disruptive in
some areas as it provided an opportunity for political influence
at an inappropriate stage in the strategic planning process.
The endorsement of the work of the Aggregate Working
Parties given by the Chief Planner in his letter of 6 July is
welcomed but it must be acknowledged that the revocation of RSSs
has caused disruption to the process of producing Development
Frameworks.
Some planning authorities (eg Oxfordshire) have already
taken the announcement as a signal to ignore Government Guidelines
on aggregates provision. In some cases it is patently obvious
that authorities have selected a provision tonnage that they feel
comfortable with and are then seeking an evidence base to fit
in with their aspirations.
To prevent spurious and costly challenges to the
recommendations of the Aggregate Working Parties it is essential
that Government give guidance as to what constitutes a "robust
evidence base". Without early and clear guidance, and against
the background of deficient permitted reserves of aggregates ("landbanks")
in critical areas, the ability of the industry to maintain an
adequate and steady supply of construction materials may be seriously
compromised.
Aggregate Working Parties continue to be an effective
way of securing an integrated approach to the provision of materials
and should be maintained in some form. What should not be forgotten
is that the National Coordinating Group of the RAWPs is also part
of the MASS and it is the view of the MPA that the role of that
body should be affirmed and enhanced to provide high-level integration,
particularly in the absence of the RSSs.
September 2010
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