Object

Representation ID: 254

Received: 11/10/2019

Respondent: Tarmac

Agent: Heaton Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Whilst Tarmac support paragraph 3.11 and a ‘restoration led approach’ when considering
mineral operations, it is considered that a biodiversity led approach/focus taken by Policy
SP2 is overly onerous, not an effective strategy and is therefore unsound. As opposed to
being categorical about ‘significantly enhancing’ biodiversity (paragraph 3.12), the policy
should be supportive where it is ‘possible’ or ‘appropriate’. The policy as worded makes no
reference/acknowledgment to the beneficial use of land and the opportunities/potential
aspirations of landowners to have land restored back to economic/commercial/agricultural
after uses. Paragraph 3.14 goes part way to recognising that there needs to be a
balance/weighting of restoration considerations but it neglects to reference the economic
potential, instead referring only to social/recreation and environmental opportunities.
Paragraph 3.14 discusses restoration for leisure or agriculture. Leisure and agricultural
9
restoration are the most common forms of restoration strategy. We agree with the
sentiment that there are opportunities to incorporate biodiversity/habitat enhancement but
there should not be emphasis on a biodiversity led approach.
This policy should be retitled to ‘restoration led approach to minerals development’ to
provide emphasis on a restoration focus without being overly prescriptive of restoration
type. In addition, the policy makes no acknowledgement of the long term financial burden
on ecological management post restoration and who has to fund and manage these areas.
Paras 3.23 to 3.25 should commence with the wording ‘If restoration allows, priority habitats
… . This would be more effective in delivering the Plan and strategy to reflect the comments
made above.