National Planning Policy Framework

Written evidence from IMERYS Minerals Ltd

Summary

· Q1 - the relationship between the Minerals section and the main text of the Framework is ambiguous and unclear.

· Q2 - the problems identified at Q1, obscure the concept of sustainable development in relation to minerals in the terms set out in the NPPF, but are otherwise balanced and workable.

· Q3 - in general the core planning principles are appropriate and able to be clearly referenced to mineral development.

· Q4 - with respect to minerals, all current planning policy statements and guidance appear cancelled by the Framework.

· Q5 - Industrial minerals in particular, due to their limited occurrence, are good examples of the need for local planning authorities to cooperate on planning for a steady and sufficient supply of minerals. However, it would be helpful if the Framework could make clear that minerals are a strategic priority for the Local Plan.

· Q6 – generally the provenance of the minerals policies is recognised

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

A1. IMERYS Minerals is principally concerned with the Minerals section of the NPPF, but notes that the Framework is required to be read as a whole.

Aside from the dedicated minerals policies, the policies are predicated on urban/built development and it is therefore not sufficiently clear how the policies will be interpreted in relation to mineral development itself.

This is illustrated by paragraph 2 of the Introduction that sets out the Governments expectations of the planning system. It limits its expectations to the delivery of ‘homes, business and industrial units, infrastructure and thriving local places that the country needs’ which carries only an implicit recognition that minerals are essential to underpin such development aspirations.

The inclusivity of minerals within the planning principles and particularly the requirement for strategic priorities is sometimes hard to determine. It is by no means clear if the core planning principles are in fact intended to embrace mineral development. In allocating sufficient land which is suitable for development in their area, local authorities are required to take account of the needs of the residential and business community. The business community does not appear to include the minerals sector as it is approached separately within the draft in considering its requirements. Minerals, therefore, appear relegated to ‘other development needs’.

It is also by no means clear if mineral development, per se, is seen as ‘economic development’ as under the requirement to set out strategic priorities, ‘housing and economic development requirements’ form one bullet point and minerals are confusingly lumped together under infrastructure requirements for transport, waste, energy, telecoms, water supply and water quality, under a further bullet point.

If minerals are not encompassed in ‘economic development’ for the purposes of the NPPF, policies that apply to economic development and business requirements do not relate to minerals. Even in the rural economy, within which most mineral operations are based, minerals receive no mention.

One is required, by this uncertainty, to rely on the dedicated minerals section for policy support and this militates against the advice to read the document as a whole.

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?

A2. The problems identified above, obscure the concept of sustainable development in relation to minerals in the terms set out in the NPPF. It is possible to read mineral development into the economic role, in ‘planning for prosperity’, within a system for the delivery of sustainable development, but only by inference. Otherwise the application of the Brundtland definition seems appropriate and the presumption in favour of sustainable development incorporating the three pillars of the economy, society and the environment should be a balanced and workable approach.

Q3. Are the ‘core planning principles’ clearly and appropriately expressed?

A3. In general a number of the core planning principles are couched in terms that can be read to include mineral development, such as succinct up-to-date plans setting out development needs, account for local circumstances, land allocations, effective use of land and environmental and heritage issues.

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?

A4. With respect to minerals, all current planning policy statements and guidance appear cancelled by the Framework.

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

A5. Industrial minerals in particular, due to their limited occurrence, are a good example of the need for local planning authorities to cooperate on planning for a steady and sufficient supply of minerals. Historically, this has been applied to our sector and we see no problem in its future application.

However, it would be helpful if the Framework could make clear that minerals are a strategic priority for the Local Plan.

Q6. Are the policies contained in the NPPF sufficiently evidenced – based?

A6. We are only able to comment in relation to the section on minerals and china clay and ball clay in particular. The policies are largely derived from existing Government policy and with some notable exceptions that are referred to in our response to the consultation on the draft NPPF; we recognise the provenance of draft policies.

IMERYS Minerals Ltd

September 2011