Communities and Local Government CommitteeWritten evidence from Cemex UK

Summary Points

The Company supports the presumption in favour of Sustainable Development.

Clarity required with in the NPPF that Mineral development is excluded from Neighbourhood Plans.

Definition of an up to date local plan.

The role of guidance within the NPPF, the need for technical guidance and weight associated.

The recognition of two tier planning systems.

Additional weight given to primary resources that will support economic growth and built development eg Minerals.

Q1. Does the NPPF give sufficient guidance to local planning authorities, the Planning Inspectorate and others, including investors and developers, while at the same time giving local communities sufficient power over planning decisions?

The NPPF needs defined policies and supportive guidance that is clear to all.

The NPPF does not clearly recognise two tier planning authorities throughout the document. Definition of a local plan relative to the planning authority (eg Mineral planning authority—local plan is the Minerals Local Plan).

The framework has been drafted for Built Development and is not directly applicable to minerals. Minerals are a national commodity and resources are restricted by geological factors and therefore need a national strategic overview and cross boundary understanding and communication.

Paragraph 23 makes reference to infrastructure and minerals; it is considered that an additional bullet point is required to support the supply of minerals to the built environment in addition to the infrastructure necessary to release the resources. Minerals are a strategic priority and a national and local supply is essential to achieve sustainable development and economic growth.

Clarification on the definition of an-up-to-date plan. To ensure a national approach and sustainable development all local plans should have a certificate of conformity.

Paragraph 32 is considered vague and open to misinterpretation. Although best available information should be used the strategic importance of minerals it is important to clarify the role of MASS and a national overview to mineral resources (not reserves) to enable sustainable development across the country.

Paragraph 101 needs to be expanded and provide more guidance related to non aggregate minerals for example cement, silica and clay. MPG10 provided beneficial guidance and related landbanks which needs to be reaffirmed within NPPF.

Q2. Is the definition of “sustainable development” contained in the document appropriate; and is the presumption in favour of sustainable development a balanced and workable approach?

We support the MPA’s comments.

Q3. Are the “core planning principles” clearly and appropriately expressed?

It should be recognised that primary requirements are necessary to facilitate new development and economic growth eg minerals and energy.

A steady supply of minerals is necessary.

Q4. Is the relationship between the NPPF and other national statements of planning-related policy sufficiently clear? Does the NPPF serve to integrate national planning policy across Government Departments?

The quantity of international and national regulation is vast and not covered by the current draft of the NPPF.

The document needs to recognise other regulations their impacts, relationship and role within planning and weight given.

Although it is the intention to remove current MPG’s/MPS’s it is requested that the technical date and guidance is retained to support applicants, Local Planning Authorities and regulators.

Q5. Does the NPPF, together with the “duty to cooperate”, provide a sufficient basis for larger-than-local strategic planning?

Minerals are of national strategic importance and require cross boundary communication. The AWP’s and AWP secretaries can play an important role in communicating discussions regarding supply of minerals and this should be reinforced within the framework.

The definition of “greater local important mineral” should be clarified to ensure adequate supply across the country.

Q6. Are the policies contained in the NPPF sufficiently evidence-based?

There is limited evidence for amendments identified within the draft NPPF for example removing reference related to Cement landbanks as stated in MPG10. Existing guidance and figures provide valuable support to the Cement industry and Planning Authorities. Any emissions or amendments should be quantified.

September 2011

Prepared 20th December 2011