Object

Representation ID: 166

Received: 10/10/2019

Respondent: Minerals Products Association

Legally compliant? No

Sound? No

Duty to co-operate? No

The policy as drafted is UNSOUND as it does not accord with National Policy, is not effective and is not positively prepared. NPPF para 204c requires;
…that known locations of specific minerals of local and national importance are not sterilised…
There is no reference to economically important mineral resources. The purpose of the safeguarding approach is to safeguard all known mineral resources for future generations. Economics change over time.
In addition, buffer zones should be put on both the MSA and the added value operations/mineral infrastructure sites. In addition, the mineral infrastructure sites should be listed by name and location as well as being identified on the policy map.
In addition, the agent of change principle should be incorporated as required by paragraph 182 NPPF.
All the above comments need to be recognised in the supporting text to this policy.