Object

Representation ID: 175

Received: 10/10/2019

Respondent: Mick George

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Whilst the objective of the policy is laudable certain considerations are either not clear, or have been missed.
2. Firstly, the supporting text rather oversimplifies the provision of alternative transport for minerals by only mentioning the long distances over which rail is viable. For example, in addition to this requirement the provision of rail or barge transport absolutely requires immediate proximity to the transport route, the ability to provide loading facilities at the quarry, plus a network of receiving depots or a concentrated market location, a large output to support the investment and a large reserve to amortise the investment, none of which gets a mention. This results in a seriously misleading impression that not to offer alternatives to road transport is a matter of choice. Rail transport is extremely rare given that there are over 500 aggregate quarries only 30 or so of which are rail connected. Barge transport is even rarer. There is for the vast majority of cases no choice other than road transport and this needs to be firmly understood by planners and the public. It is proper to require consideration of rail and barge where appropriate but this should not be underestimated.
3. Secondly, minimising travel is a major consideration of national policy for sustainable transport (NPPF para 103). Therefore, it follows that in a local policy on sustainable transport similar considerations will apply. Not only does this relate to the use of alternative transport modes but also to that which reduces the levels of imports to an area, where local material can be used instead, which is a different point to sites being in close proximity to markets; this is about reducing the levels of material traded unnecessarily between areas. This is in accordance with the Plan which says that sand and gravel is a relatively low cost mineral and is not generally cost effective to transport over long distances. Thus where sand and gravel is transported over considerable distances (of up to 70 miles) it indicates there is a severe shortage of material in the market. The plan should actively seek to provide minerals supplies indigenously in accordance with national policy and should repatriate material imported from other areas, if it can be supplied locally.
4. Moreover, the policy should encourage the “backhauling” of materials such that site that utilise inert waste to aid in the restoration, should be encouraged to transport such material using the same material exporting mineral wherever practicable to do so. Such a proposal is wholly compliant with basic sustainable objectives reducing CO2 levels considerably.
5. The observation that pipelines and conveyors can be used to transport minerals internally needs to be qualified by several practical realities. There are environmental advantages in the use of a conveyor over dumptrucks; it can be generally less obtrusive, quieter and less dusty. However, it could raise problems with maintenance, power supply, vulnerability to vandalism, and is relatively inflexible requiring the transport of large quantities of mineral from a fixed point to be economically viable. The use of pipeline is even more environmentally beneficial because it eliminates almost all forms of adverse environmental impact but clearly demands a wet working and substantial investment. The size of the site, its reserves, the distance to the processing plant, the nature of the mineral and the shape of the site plus its location all contribute towards decisions about whether alternative means of transport to dumptrucks is viable.
6. It may be objected that such objections do not go to the issue of soundness. However, MGL would argue that if the Plan is to make references to alternative means of transport, it should not mislead by being oversimplistic in its explanations lest users of the plan get the wrong idea.
7. The reasons for the proposed changes are that the policy and text is not justified or effective.