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ITEM EX8 - ANNEX 1

EXECUTIVE – 28 OCTOBER 2003

REGIONAL MINERALS STRATEGY – CONSULTATION BY SOUTH EAST ENGLAND REGIONAL ASSEMBLY

Detailed Comments on Draft Regional Minerals Strategy

Policy M1 – Sustainable Construction and Environmental Management

  1. This policy promotes sustainable construction practices through SEERA working with partners to promote good practice, reduce wastage and overcome constraints, with the aim of stabilising annual consumption of primary aggregates by 2016. In particular it says development plans should ensure that development projects use construction materials that reduce demand for primary aggregates wherever practicable. It also says effective environmental management of mineral extraction and restoration and increased movement of minerals by rail and water should be promoted through development plan policies.

    2. Comments

  2. Much of what this policy is promoting is already included in development plan policies in Oxfordshire, but its inclusion in regional guidance will strengthen policy for more sustainable construction and environmental management at local level. In particular, it will require and provide a sound basis for local policies on more sustainable development design and construction, which will largely be a matter for district local plans. It should therefore be strongly welcomed.

  3. The principle of setting a target for stabilising consumption of primary aggregates should be supported. However, it is not clear how this would work in practice, given that aggregates consumption fluctuates in response to construction activity. I consider that SEERA should give further thought to, and should explain how this target would operate in practice.

    4. Policies M2 and M3 – Recycling and Re-use

  4. Policy M2 says use of secondary and recycled aggregate materials in the South East should increase to at least 7.4 million tonnes per annum (mtpa) by 2016; and that MPAs should make provision for recycling facilities to enable this target to be met. Policy M2 also seeks better information on secondary and recycled aggregates to enable effective monitoring. Policy M3 urges Government action to adopt statutory recycling and recovery targets for construction and demolition waste and to promote more sustainable construction practices and recycling projects.

    5. Comments

  5. These policies will help to increase the use of secondary and recycled materials and reduce the need for primary aggregates extraction and should therefore be generally welcomed. However, the target figure for 2016 of 7.4 mtpa seems too low. This is only the average supply level for the period 2001-2016 in the Government’s Aggregates Guidelines (see table at paragraph 11 of report). The Aggregates Guidelines assume an increase in supply of secondary and recycled materials for aggregate use from the current level of 6.6 mtpa over the period 2001-2016. If this increase is to be achieved, a level of supply higher than the average would be required by the end of the period, and therefore the target for 2016 should be set higher.

  6. It would be helpful to MPAs if the RMS included an indication of the recycling capacity that will be needed in each MPA area to ensure the regional target is met.

  7. The figure of 5.3 mtpa given in policy M2 of the current level of use of secondary and recycled materials is incorrect; it should be 6.6 mtpa. It would also help understanding of this policy if the meaning of the percentage figures was explained.

    8. Policy M5 – Other Minerals

    Fullers Earth

  8. Of the other minerals covered in the RMS, only fullers earth is of significance in Oxfordshire. The RMS says fullers earth was previously of some regional importance but is now only worked in small quantities in Oxfordshire (at Baulking). Following an examination of existing reserves and the extent to which the mineral has been replaced by other materials, the RMS says further consideration of this mineral in the strategy is not warranted, but that this should be kept under review. Consequently fullers earth is not covered by any policy in the RMS.

    9. Comments

  9. I agree that a regional policy for future provision of fullers earth is not currently necessary. However, fullers earth is nationally a relatively scarce and important mineral. Whilst the only working and permitted reserves of fullers earth at present are in Oxfordshire, there are resources elsewhere in the South East, particularly in Surrey. Therefore, I consider it important that the need for regional policy on fullers earth provision is kept under review, and also that significant deposits of fullers earth should be safeguarded.

    10. Policy M6 – Safeguarding of Mineral Reserves, Wharves and Depots

  10. Policy M6 says areas permitted and identified in development plans for working regionally significant minerals and existing and proposed wharves and depots for handling and distributing minerals should be safeguarded against other development. The minerals specified in the policy include aggregates, but not fullers earth.

    11. Comments

  11. The inclusion of a safeguarding policy in the RMS is to be welcomed. This will provide a regional policy basis for development plan policies that seek to avoid the sterilisation of mineral resources which might need to be worked in the future. However, this policy should not be limited to permitted and allocated land, since this covers only a small part of the total mineral resource. Government policy is that mineral deposits of potential economic significance should be safeguarded. The proposed Policy M6 could undermine development plan policies that seek to implement Government policy on mineral safeguarding. It should therefore be widened to cover potentially significant mineral deposits. It should also be extended to cover fullers earth, since this is a nationally scarce and important mineral.

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