WRITTEN EVIDENCE
SUBMITTED BY
THE MINERAL
PRODUCTS ASSOCIATION
(LOCO 065)
SUMMARY
¾ An adequate
and steady supply of mineral products (aggregates, asphalt, cement,
concrete, mortar, industrial and agricultural lime, silica sand
and recycled and secondary aggregates) is essential for the construction
and manufacturing industries, to the UK economy, and our everyday
lives.
¾ Of the
2 billion tonnes of all materials we use every year in the UK,
mineral products (at 280 million tonnes or 14%) are the biggest
material flow.
¾ Every
year the UK mineral products industry supplies over £5 billion
worth of materials, directly and indirectly employs over 60,000
people and underpins the vast £110 billion construction sector.
¾ Land-won
indigenous non energy minerals, particularly aggregates and other
non aggregate minerals are therefore an essential component of
supply.
¾ On average,
MPA members deliver one million tonnes of mineral products every
working day, more than oil, gas and coal combined.
¾ The
major non energy mineral products flows are aggregates both primary
and secondary.
¾ These
kinds of flows have to be managed for this vital supply to national
infrastructure to be maintained. It will not happen purely on
the basis of local decision making, some form of national requirement
to supply both local and more distant markets from local sources
is vital to avoid unsustainable and unsteady supply.
¾ The
opportunities for community input that are already incorporated
into the planning process are comprehensive. The introduction
of third party rights of appeal would add another layer of uncertainty
and a significant barrier to economic recovery.
¾ There
is a danger that decentralisation and localism may result in result
in councils (Mineral Planning Authorities - county and unitary
councils) failing to provide for and permit new minerals developments
due to the increased power of local communities to object to mineral
development.
¾ The
current plan-led system is unfit for purpose and is failing to
deliver plans in a timely manner. Anything which could add to
the time taken for plans to be adopted will create inertia which
will act as a drag on the economy and its recovery.
¾ Minerals
are not evenly distributed and can only be worked where they naturally
occur, which may be distant from the end market and use, and a
wider strategic perspective to supply and planning for future
provision is therefore essential.
¾ For
aggregates (crushed rock, sand and gravel) a managed supply system
at national (England and Wales) level has operated for over 30
years, and should continue to operate, with appropriate modifications,
under a more localist regime.
¾ There
is a need for continued Government action and oversight of local
authority (and mineral planning authority) performance to ensure
a secure and steady supply of aggregates and other non aggregate
minerals. This could include:
¾ Inclusion
of clear statements, including in the proposed National Planning
Framework on need ensure a secure and steady and adequate supply
of aggregates and other non aggregate minerals from a range of
sources.
¾ Continued
[financial and policy] support for Aggregates Working Parties
(AWPs) to undertake their joint technical, monitoring and advisory
role, with coordination at national level.
¾ Ensuring,
including through the Planning Inspectorate, that Mineral Planning
Authorities continue to make adequate provision and permit developments,
and for aggregates they reflect technical advice from AWPs in
development plan documents.
¾ Rigorous
maintenance of minimum landbanks as set out in existing minerals
policy and guidance.
¾ Local
ring-fencing of an increased proportion of the Aggregates Levy
Sustainability Fund to ensure benefits accrue to the communities
closest to mineral workings.
BACKGROUND AND
DETAILED COMMENTS
The Mineral Products Association submitted written
evidence to the Committee's inquiry into the abolition of Regional
Spatial Strategies (letter and enclosure of 15 September 2010).
The comments we made in that submission are relevant to the Localism
Inquiry, in that they concern the minerals, predominantly aggregates,
supply system in the future, including the working of the planning
system.
Value of Minerals to the economy
The economy depends on an adequate and steady supply
of mineral products. Minerals products (described in our summary)
are essential to construction and manufacturing industries, to
our economy and our everyday lives. Of the 2 billion tonnes of
materials we use every year in the UK, mineral products (at 280
million tonnes) are the biggest material flow.
Every year the mineral products industry supplies
over £5 billion worth of materials, directly and indirectly
employs over 60,000 people and underpins the vast £110 billion
construction sector. Every £1 invested in construction generates
£2.84 in total economic activity - construction relies on
mineral products.
Distribution of primary materials
Minerals are not evenly distributed, and as primary
raw materials can only be extracted from where they occur.
Some nationally significant minerals with specialist
uses are very restricted, and travel to distant markets. Primary
aggregates (crushed rock, sand and gravel) vary in their distribution
throughout the UK, with sand and gravel being widely spread, and
crushed rock more unevenly spread (figures 1 and 2).
Inter-regional flows of crushed rock are significantly
larger than for sand and gravel, because of the overall larger
demand for crushed rock, particularly for roadstone, and because
regions such as the South East, London, the East of England and
parts of the North West have only minor, or inferior quality,
crushed rock resources. In addition, the consistency and extent
of some hard rock deposits permits their working on a very large
scale, enabling much wider geographical areas to be served economically
by rail. The transfer of crushed rock between regions is more
complex and uneven than for sand and gravel. It reflects the combined
pattern of the extent of crushed rock resources and markets/population
(demand). London and the South East also have substantial landings
of marine dredged sand and gravel.
Figures 3 and 4 illustrate major movements of materials
within in England, and major imports from outside of England and
from marine sources.
Managed Aggregate Supply System
Local supply of some materials cannot fully meet
the pattern and scale of demand and a system of long distance
supply has developed.
The managed aggregates supply system (MASS)[21]
has operated for more than 30 years, evolving in the post war
years due to concerns about increasing demand for construction
aggregates, imbalances in supply and demand at national level,
the need to assess resources and forecast demand, and the social
and environmental impacts of mineral working.
In the period of intense rebuilding of Britain, following
the Second World War, concern grew about the ability of the aggregates
industry to maintain an adequate supply of minerals for construction,
particularly in the South East of England.
As a result, the Government appointed an advisory
committee under Sir Ralph Verney in 1972 and he published his
recommendations in a report in 1976 which led to the MASS as we
know it today.
The system that Verney established effectively addressed
the imbalances in supply that existed post-war and led to a structure
in which the geological location of aggregates deposits were overlaid
on other factors and allowed for a planning regime that ensured
a steady and adequate supply of minerals.
The system allows the Government to identify those
parts of England where the geology shows that aggregates are present
and, using data from production and sales volumes to forecast
future demand, to apportion tonnages of future supply to those
areas that can support them. This provision is then sub-apportioned
to Mineral Planning Authorities (counties or unitary councils)
following the advice of Aggregate Working Parties of council officers
and industry representatives. Minerals development plan documents
then set out policies to provide for their supply including identifying
area and sites. Monitoring enables a landbank of permitted reserves
to be maintained. The plan-led system helps to provide certainty
to investors that helps maintain supply.
What MASS does not do is to force Mineral Planning
Authorities to produce the proposed tonnages, but rather to make
provision for doing so: aggregates will only ever be produced
in sufficient quantities to support demand, which varies from
year to year.
Mineral Supply and Localism
For aggregates, MASS evolved in England and Wales
to address the need to ensure an adequate and steady supply, addressing
the regional imbalances between supply and demand. Maintaining
the managed system under localism will be as, if not more important.
The MASS has been shown to perform relatively well
over the years, evidenced by a high rate of success for planning
applications. It is also relatively cheap and cost effective.
If the fundamentals were changed, it is likely there would be
less certainty for investors, higher planning costs and lower
likelihood of planning permission being granted.
However, slow progress in delivering Mineral Development
Plan Documents is a major concern, with only 15 new-style Core
Strategies adopted in England to date. The necessary degree of
certainty for investors and communities intended by the plan-led
system is still lacking. The principle is right but the operation
of the system is not fit for purpose.
With greater responsibilities on local councils (including
Mineral Planning Authorities) for setting planning policy (with
less guidance from government), and increasing the ability of
local residents to influence and object to developments and decisions
in their locality, there is a real danger that development such
as minerals extraction, often seen as a bad neighbour, will be
resisted even more than currently, by residents and local politicians
influenced by their constituents. This may be the case particularly
where extraction in one location serves distant markets.
The coalition Government's current proposals to introduce
third party rights of appeal combines the developer's twin nightmares
of increased uncertainty and cost for no material gain. The current
plan led process takes full account of the views of local communities
which are tested again once a planning application is submitted.
Third party rights of appeal will add another layer of uncertainty
into the planning process. Combined with slow progress on adopting
development plans and revocation of RSS, this will result in growing
inertia in the planning system. The prospect of another step in
what is already a demanding and expensive process may well deter
developers from submitting applications in the first place just
at the time the economy needs the private sector to help bring
on new development to support the recovery.
There is a risk that the long-term planning and provision
for minerals in development plans would also be undermined. MPAs
may re-visit and challenge the aggregates apportionments in existing
or emerging development plans. Already a number of MPAs have signalled
this course of action following revocation of Regional Spatial
Strategies.
This would result in local and potential nationally
falls in production capacity, with impacts on construction and
infrastructure, delivery of local development strategies, increased
costs to consumers (including taxpayers), and increased distances
minerals would be transported, mainly by road with the associated
environmental and amenity impacts.
Similarly there is also a need for national policy
to recognise the importance of non-aggregate (including industrial
and specialist) minerals such as silica sand, and the need for
continued provision to be made through the planning system, including
from areas of high environmental quality and constraint.
There needs to be continued strategic planning for
minerals supply. We are encouraged by the advice from the Department
of Communities and Local Government Chief Planner (letter to Chief
Planning Officers, 6 July 2010) that in the absence of RSS technical
advice from the RAWPs should be used as the basis for planning
for aggregates in the future. How this operates without RSS policy
providing the statutory regional framework now requires further
consideration and explanation so that all Minerals Planning Authorities
help in delivery and do not seek to opt out.
Local incentivisation to communities to accommodate
minerals development will also be essential, and more local targeting
of funds raised through the Aggregates Levy Sustainability Fund
would help in achieving this.
CONCLUSIONS
The two points in the Committee's Terms of Reference
where we focus our comments are:
The action which will be necessary on the part of
Government departments to achieve effective decentralised public
service delivery;
What, if any, arrangements for the oversight of local
authority performance will be necessary to ensure effective local
public service delivery.
Minerals can only be worked where they occur. The
economy depends on an adequate and steady supply of mineral products,
particularly aggregates and other non aggregate minerals to ensure
national requirements for a range of materials are met. Consequently
there needs to be strategic planning for provision.
The MASS has been shown to perform reasonably well
over the last 30 years, evidenced by a high rate of success for
planning applications. It is also relatively cheap and cost effective.
If the fundamentals were changed, it is likely there would be
less certainty for investors, higher planning costs and lower
likelihood of planning permission being granted.
The principle of the plan-led system is right but
its operation is unfit for purpose. Slow progress in delivering
Mineral Development Plan Documents is a major concern, with only
15 new-style Core Strategies adopted in England to date. The necessary
degree of certainty for investors and communities intended by
the plan-led system is therefore lacking.
Areas where continued action by Whitehall and oversight
of local authority performance will be essential, although inevitably
lighter touch than in the recent past, may therefore include:
¾ Inclusion
of clear national policy statements, including in the proposed
National Planning Framework, on the need ensure a secure and steady
supply of minerals from a range of sources.
¾ Continued
[financial and policy] support for Aggregates Working Parties
to undertake their technical, monitoring and advisory role, with
coordination at national level.
¾ Ensuring,
including through the Planning Inspectorate, that Mineral Planning
Authorities continue to make adequate provision and permit developments,
and for aggregates they reflect technical advice from AWPs in
development plan documents.
¾ Rigorous
maintenance of minimum landbanks as set out in existing minerals
policy and guidance.
¾ Local
ring-fencing of an increased proportion of the Aggregates Levy
Sustainability Fund to ensure benefits accrue to the communities
closest to mineral workings.
October 2010
21 For further information see Gunn et al (2008)
Managing Aggregates Supply in England-a review of the current
system and future options and Hicks L (2008) Aggregates Supply
in England-Issues for Planning
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