Object

Representation ID: 262

Received: 11/10/2019

Respondent: Tarmac

Agent: Heaton Planning Ltd

Legally compliant? No

Sound? No

Duty to co-operate? No

Policy MP1 is not considered positively prepared and is therefore unsound.
Comments regarding the analysis of predicted aggregate demand have been presented within the section regarding the Local Aggregate Assessment above.
The 10 years average sales figures are not the most appropriate methodology for forecasting
aggregate demand. Forecasts of demand should be based on a rolling average of 10 years
sales data, other relevant information and through assessment of all other supply options.
The 10 years average sales are heavily influenced by the impact of the recession. This is
particularly apparent given the picture across the East Midlands which in all other cases have
seen increases in sales figures. Whilst, recycled and secondary aggregate has a role to play in
meeting demand in some circumstances it cannot be relied upon for ensuring continuity in
supply. In addition, given the location of the County it is unlikely that demand can be met
from other sources (for example marine). Considering this, the other relevant local
information is particularly important in forecasting future demand in the County.
Considering the above the Mineral Planning Authority is underproviding sufficient sand and
gravel resource over the Plan period. We support the MPA in their previous approach which
reviewed sales data pre and post-recession to give a greater appreciation of likely
anticipated demand in recession and a period of economic growth.
The operational capacity of permitted operations within the County needs consideration to
ensure that anticipated demand is met. A decline in sales is not necessarily an indication of a
decline in demand. Production moving outside of the County will impact upon perceived
sales figures as well as sites/resource not being replaced when exhausted.
A Delivery schedule has been prepared as Appendix 1 to the Draft Plan. Tarmac have
enclosed an edited version (Appendix 1a) which shows the available production capacity
from existing sites and proposed allocations as proposed within the Plan against the
identified annual requirement for sand and gravel. The sites proposed for sand and gravel
extraction including allocations are insufficient to even meet that depressed annual
requirement. An edited version is also enclosed at Appendix 1b which shows how additional
allocations could assist in meeting the identified shortfall.
Although the perceived landbank is sufficient at the start of the Plan period, sites will
become exhausted during the Plan period and provision should be made for replacements.
The Plan should not focus or specify a definitive/maximum amount of mineral provision. The
sales data is an indication of current demand and should not be perceived as a maximum
requirement. The Plan needs to provide flexibility to support additional sites/resources
coming forward during the Plan period to meet demand/operational requirements to serve
existing/future markets. Policy M1 should be updated to provide a more realistic sand and
gravel provision figure which is reflective of economic growth at pre-recession levels. As a
minimum the policy should be clear that the provision of sand and gravel, Sherwood
Sandstone and Crushed Rock are minimum requirements.
Part 2 of the Policy or as a minimum the justification section should advocate the need for
the Plan to be flexible and the ability to respond quickly and positively to upturns in demand.

Section 3 of the policy does not make any allowance for the benefit of sustainable extensions to existing operations in securing continued delivery of mineral as advocated by the Strategic Policy SP2.