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Minerals Local Plan Background Document
Worcestershire County Council: June 2014
Consultation Statement
Nicholas Dean, Marianne Joynes, Rebecca Schofield, Sarah Button
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Contents 1. Introduction ............................................................................................................. 3
2. First Stage Consultation ........................................................................................ 33
Publicity activities .................................................................................................. 33
Methods used ........................................................................................................ 34
Events with Partners ............................................................................................. 38
Other activities ...................................................................................................... 39
Consultation on relevant appraisals and assessments .......................................... 39
Consultation on the evidence base ....................................................................... 39
Summary of activities under the duty to cooperate ................................................ 40
3. Second Stage Consultation ................................................................................... 55
Publicity activities .................................................................................................. 55
Methods used ........................................................................................................ 57
Events with Partners ............................................................................................. 62
Consultation on relevant appraisals and assessments .......................................... 63
Consultation on the evidence base ....................................................................... 64
Summary of activities under the duty to cooperate ................................................ 65
Discussion with Minerals Industry ............................................................................. 81
Cemex and Tarmac ............................................................................................... 81
Tarmac .................................................................................................................. 81
Salop Sand and Gravel ......................................................................................... 82
Coal Authority and CoalPro ................................................................................... 82
Appendix A: A summary of the legislative and regulatory requirements ....................... 84
Appendix B: Direct mail/e-mail distribution list: first stage consultation ......................... 86
Appendix C: Direct mail/e-mail distribution list: second stage consultation ................... 90
Specific consultees: ...................................................................................................... 90
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1. Introduction 1.1. This Consultation Statement, provides a summary of the consultation activities
undertaken during the preparation of the Worcestershire Minerals Local Plan and sets out:
which bodies were invited to make representations during the preparation of the Minerals Local Plan,
how they were invited to make these representations,
a summary of the main issues raised and
how those issues have been addressed.
1.2. Officers are committed to addressing issues raised at any point in the development of the Minerals Local Plan up until the statutory period of representations prior to submission of the plan to the Secretary of State. However, it can be more difficult for comments made outside formal consultation periods to be addressed in the same way and they are unlikely to be included in the Response Document produced after each consultation.
1.3. This Consultation Statement document sets out the main consultation activities undertaken and summarises the issues raised. If at any stage you feel your comments have not been adequately addressed we would urge you to discuss the matter with us.
2. The Minerals Local Plan must be prepared in legislative and regulatory requirements. Second Stage Consultation
2.1. The second formal stage of consultation on the Minerals Local Plan began on 11
th November 2013 and ran until 31
st January 2014.
2.2. This consultation included:
A portrait of Worcestershire giving an overview of the minerals found in Worcestershire and identifying the key issues affecting the county
A draft vision and objectives for what the Minerals Local Plan should aim to achieve
A spatial strategy diagram which set out very broadly what type of development the County Council would like where
Details of how much of each mineral we need to provide and when, including alternative methods considered in making this calculation and options for when it should be provided
Ideas about how minerals should be worked, setting out the issues to be considered when developing criteria to manage working practices
Ideas about where minerals should be worked, setting out the issues to be considered when developing location criteria for all mineral workings and identifying 'areas of search' for aggregates and an 'opportunity area' for clay
Ideas about how mineral workings should be restored, setting out issues to be considered when developing principles for all workings and a proposed approach to identifying key considerations and restoration priorities for each individual 'area of search'
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Details of how minerals should be safeguarded for future use including alternative options to consider
2.3. A variety of consultation and engagement methods were therefore used to meet
these different objectives:
Consultation document, summary document and questionnaire;
Open day drop-in sessions;
Stakeholder workshops offered; and
Online quiz. More details about these methods are outlined later in this section.
Publicity activities
Worcestershire County Council Website
2.4. All relevant documents were included in a dedicated section on the Council's website with the shortlink www.worcestershire.gov.uk/minerals. This link was included in all public notices, press releases, via social media posts, and in letters and emails.
2.5. The consultation was also listed on the Council's "consultation portal" and was publicised in two articles posted to the front-page news section of the Council's website during the consultation.
Public notices 2.6. Public notices were placed in newspapers covering the county:
Bromsgrove and Droitwich Advertiser (13th November 2013)
Evesham Journal (14th November 2013)
Kidderminster Shuttle/Times (14th November 2013)
Ludlow & Tenbury Wells Advertiser (14th November 2013)
Malvern Gazette and Ledbury Reporter (15th November 2013)
Redditch Advertiser and Alcester Chronicle (13th
November 2013)
Stourbridge News/County Express (14th November 2013)
Worcester News (14th November 2013)
Press releases 2.7. Two rounds of proactive media activity, tailored by news patch, were undertaken
during the consultation period with press releases being sent to all County newspapers and radio stations. 11 articles appeared in local media.
2.8. Press releases were also sent to other organisations and stories were carried in the following publications:
Worcestershire County Association of Local Councils, CALC Update, Issue 42 (8
th November 2013)
Wychavon's Strategic Partnership and LSPs newsletter, Communicate (December 2013)
NFU's weekly email newsletter to all members in the West Midlands (from 15
th November for several weeks) and the regional pages of
NFUOnline.com.
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Direct mail
2.9. On 11th November 2013, an email was sent to all contacts on the Council's
Minerals Planning Database who had opted to be contacted by email (394 email addresses) and all other contacts on the database were sent a letter (113 postal addresses). Both of these included details of and links to the summary and main consultation documents, questionnaire, open days, and background documents.
2.10. Following further consideration of the contacts who had registered an interest in the Minerals Local Plan, it was felt that there may be additional contacts who it would be desirable to inform about the consultation. All contacts on the SCI and Waste Core Strategy consultation database had previously been sent the "Get involved in Planning" Questionnaire but a number of contacts either did not respond, or responded but did not request to receive information on minerals policy. These contacts were considered and three groups were identified:
"white group" – this group were not considered essential to the development of the Minerals Local Plan and were not contacted again.
"blue group" – this group were considered important to be involved in the development of the plan. This group were added to the Minerals consultation database but given the option to be removed on request.
"pink group" – this group were considered to have a potential interest in the development of the Minerals Local Plan. This group were sent the "Get Involved with Planning" questionnaire again but not automatically added to the Minerals consultation database.
The "blue" and "pink" groups were sent letters or emails on 12th December 2013
which contained the same information as the 11th November letters and emails
with additional details of why they were receiving the communication. 122 letters and 49 emails were sent to blue group, and 165 letters and 52 emails were sent to the pink group.
2.11. A full list of consultees is set out in Appendix C.
Social Media
2.12. Twitter: 7 social media messages were posted through the County Council Twitter channel over the consultation linking through to dedicated website section. The Council had approximately 9,000 followers at this time.
Methods used
Open days
2.13. Three open days were held near the beginning of the consultation period to give the public a chance to find out more about the second stage consultation, look at the background documents, and ask officers questions. The event was publicised in the consultation leaflet and in all publicity on the consultation in general.
2.14. A number of key pages from the consultation document were produced at
poster scale, and all of the Areas of Search were also printed at a large scale. Background documents, the Sustainability Appraisal and Habitats Regulations Assessment, and large-scale geological maps of the county were also available for the public to peruse during the events. Though we attempted to direct the public to the digital copies of the documents, a number of printed consultation
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documents, summary documents and paper questionnaires were available for the public to take away.
2.15. Worcester Open Day was held on Saturday 30 November 2013, 10:00 - 15:30, at Worcestershire Countryside Centre. There were 7 attendees. This event deliberately coincided with a well-attended fun run in the park, the Worcestershire Christmas Market (the County Council car park serves as a park and ride for Christmas shopping weekends) and a rugby match, all of which were expected to attract passing interest in the consultation.
2.16. The main interest on this day came from Longdon/Queenhill, with parish councillors and residents from the Longdon, Queenhill and Holdfast Parish expressing concern about an existing application on a site near Holdfast.
2.17. Bromsgrove Open Day was held on Wednesday 4 December 2013, 14:00 - 20:00, in the Spadesbourne Suite at Bromsgrove District Council Office. There were 21 attendees. This event was added to the schedule on the request of the Cabinet Member for Economy, Skills and Infrastructure and deputy leader of the council as there was local interest in the plan. Attendees at this event included Bromsgrove District Council, Gloucestershire County Council, local residents, and representatives from a number of parish councils (Bentley Pauncefoot, Belbroughton, Hagley). The main areas of interest were concerns about landfills in former quarries and potential links with housing proposals.
2.18. Kidderminster Open Day was held on Saturday 7 December 2013, 10:00 - 16:00, at Kidderminster Library. The Open Day was advertised on hoardings outside and inside the Library. There were 3 attendees. All attendees at this event were members of the public.
2.19. The number of attendees in itself does not indicate the success of these open
days as many in-depth conversations were held about detailed aspects of the plan. People were primarily interested in learning about resources and sites in their areas, and some looked at Areas of Search maps in detail. Following specific questions, electronic links and detailed maps were emailed to answer individual queries. A number of attendees took full consultation or summary documents and questionnaires away with them. There were also a lot of general questions asked about the consultation and the minerals local plan.
Workshops
2.20. We proposed to hold two types of workshop during the consultation period:
An industry workshop aimed specifically at operators to get an industry perspective and to focus on technical issues and deliverability.
A green infrastructure workshop aimed at organisations involved in delivering and managing green infrastructure in and around the county to focus on the implementation and deliverability of our restoration aspirations.
2.21. These workshops did not take place as no expressions of interest were received
for either event.
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Consultation Documents
2.22. We produced a main consultation document which set out the processes we had undertaken and options we had considered to arrive at the proposed approaches. The consultation document included:
A portrait of Worcestershire giving an overview of the minerals found in Worcestershire and identifying the key issues affecting the county
A draft vision and objectives for what we think the Minerals Local Plan should aim to achieve
A spatial strategy diagram which set out very broadly what type of development the County Council would like where
Details of how much of each mineral we need to provide and when, including alternative methods considered in making this calculation and options for when it should be provided
Ideas about how minerals should be worked, setting out the issues to be considered when developing criteria to manage working practices
Ideas about where minerals should be worked, setting out the issues to be considered when developing location criteria for all mineral workings and identifying 'areas of search' for aggregates and an 'opportunity area' for clay
Our ideas about how mineral workings should be restored, setting out issues to be considered when developing principles for all workings and a proposed approach to identifying key considerations and restoration priorities for each individual 'area of search'
Details of how minerals should be safeguarded for future use including alternative options to consider.
2.23. The consultation document included 44 questions some of which were technical
in nature and others which were more general. The questionnaire could be completed online or returned to our dedicated email address or freepost mailing address.
2.24. As the main consultation document was lengthy (327 pages including Appendices), we also produced a summary document. The summary document was composed of extracts from the main consultation document and gave an overview of the issues the new Minerals Local Plan will address and how we used the comments made on the first consultation on the Minerals Local Plan to develop the approaches proposed.
2.25. The summary document was intended to give a good overview and enough
information to help readers decide which sections they might want to look at in more detail. It set out some of the consultation questions in full, and signposted the reader to the main consultation document where the detailed information was required to answer the questions.
2.26. Both documents were available in a "page turner" version, a downloadable PDF, or in printed form on request. 10 copies of the main document and 6 copies of the summary document were posted out on request. Printed documents were also made available in the county's libraries and at County Hall reception.
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2.27. We received 30 questionnaire responses and 36 general responses by letter or email that did not use the questionnaire format for a total of 66 responses. This gives an overall response rate of 8.9%.
2.28. The comments received to the second stage consultation were broadly
constructive and positive. The restoration-led approach was especially lauded by conservation organisations, though the minerals industry expressed some reservations and we anticipate that some refinement of the areas of search and the methodology employed to determine them will be necessary. We received very useful feedback from industry respondents regarding ways in which we may strengthen our approach as we begin to draft policies. Local Authorities within and neighbouring Worcestershire also brought a number of important cross-boundary issues to our attention that will require further work. These include projected housing development and demand for aggregates, crushed rock provision, and sustainable transport. Individuals and parish councils expressed concern about particular sites, and ensuring that Worcestershire's local character is captured and expressed in the draft plan.
2.29. There was general agreement with the "issues that need to be addressed through policy criteria" which were identified in tables 5, 10 and 24. Some respondents identified issues that they would like to see strengthened or added, and these will be addressed as we develop the draft policies. Monitoring was identified as a cross-cutting issue in the responses we received, and we will be looking at how monitoring requirements could be incorporated into the draft policies at the next stage of consultation.
2.30. Below is a brief summary of the key issues that arose in each section of the consultation:
Portrait of Worcestershire
Respondents broadly agreed with the Portrait of Worcestershire, but in this section and in others, respondents indicated that we could do a better job identifying the things that make Worcestershire unique. Some people recommended that specific sites or locations be included, and we realise that we will need to do a better job conveying Worcestershire's local character in the draft plan.
Vision and objectives
Most responses were in general agreement with the vision and objectives. We received a number of suggestions for amended wording to help clarify our intentions, especially around the historic environment, and some respondents would like to see the objectives become more locally specific.
How much mineral will we make provision for?
Respondents expressed a number of views regarding our proposed approach to meeting our landbank. Some consultees have suggested that we take different approaches to sand and gravel which will have some landbank at the start of the plan period and crushed rock which we currently have no landbank for. We are considering the comments we have received to establish the most appropriate way forward.
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Cross-boundary issues, crushed rock provision, and protection of AONBs all also figured heavily in responses to this section. There were also concerns expressed about the conversion factor we used to calculate the amount of mineral in resource areas, and about the reliability of information used for one particular resource area. We will undertake further work to refine these estimates and will produce a revised version of the Analysis of Mineral Resources in Worcestershire in due course.
When will minerals be worked and when will our reserves meet national targets?
Consultees clarified that national policy regarding landbanks does not set targets. We acknowledge that this is correct and we mis-used the term "targets", but as we have used this terminology throughout the second stage consultation, we continued to use it in the Consultation Response Document in order to remain consistent with the consultation documents and the questionnaire. We will refine our terminology for the draft plan.
How will minerals be worked?
Proximity of mineral workings to "sensitive receptors" caused some concern, along with the removal of the now-outdated "sieve test" approach. The rationale for the removal of the sieve test is outlined in Appendix 1 of the main consultation document, along with a detailed explanation of changes to the regulatory and national policy context since the adoption of the 1997 Hereford and Worcester Minerals Local Plan. These changes mean that we have had to re-think our approach to identifying constraints and establishing "buffer zones" as the policy context is substantially different than it was in 1997.
Where will minerals be worked?
Respondents expressed concerns about the protection of Worcestershire's AONBs and other landscapes, and concern that visual impact has not been addressed satisfactorily in the second stage consultation. There was also concern expressed from industry and the public about how any proposed sites outside of the areas of search will be handled. We will be refining the areas of search based on the comments received during this consultation, and we believe that some of our earlier assumptions will need to be revisited.
Respondents have also specifically asked that we consider Nitrate Protection Zones, agricultural land quality and source protection zones in preparing our draft policies.
How will mineral workings be restored?
Responses to the restoration-led approach were generally positive, and were met with special acclaim from conservation organisations. Industry respondents expressed more reservations, however, and a number of suggestions were received for ways to refine the approach as we develop the draft plan.
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We are considering several ways to further refine the areas of search and ensure delivery of the restoration priorities which may include spatial masterplanning, concept planning, or 'corridor plans' in order to better convey the restoration-led approach. This approach will be informed by the responses received, and we plan to explore these options further with the members of the Green Infrastructure Partnership working group which has helped inform the development of the Green Infrastructure aspect of the Minerals Local Plan to date. Several respondents suggested that further clarity is needed about how restoration priorities should be balanced or prioritised if more than one issue is identified for a particular area.
How will we safeguard minerals for the future?
There was general agreement with our proposed approach to safeguarding minerals and mineral infrastructure, but we expect that our approach will be further refined as we develop draft policies.
Next steps
We are planning a series of meetings to address respondents' requests and concerns before beginning to draft policies. Cross-boundary issues, including crushed rock provision, sustainable transport, demand forecasting linked to local development plans and potential AONB impacts all require further cooperation with surrounding authorities. A number of respondents have also offered their expertise and access to their data to help us to fill gaps in our knowledge, particularly around the Mercia Mudstone (clay) and building stone resources in the county. We are embarking on a phase of further information gathering to ensure our evidence base is as robust as possible, and to ensure we have fulfilled our duty to cooperate as we begin to prepare the draft wording for the next consultation.
Online Quiz
2.31. The interactive quiz which was developed for the first stage consultation remained active on our website during the second stage consultation. The quiz asked 'general knowledge' questions about what minerals are used for, how much is needed to build a house, how far minerals are transported, what activities are going on locally and which local recreation facilities were previously mineral workings, with an invitation to provide their contact details if they would like to be involved in participating in future Minerals Local Plan consultations.
Events with Partners
Worcestershire Green Infrastructure Partnership
2.32. A presentation about the consultation was made at the Worcestershire Green Infrastructure Partnership meeting on 29
th January 2014, highlighting the role of
Green Infrastructure in the emerging Minerals Local Plan. Although the meeting was close to the end of the consultation period, partner organisations were encouraged to make individual responses as soon as possible.
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1000 years of building with stone
2.33. An Officer attended a meeting of the Steering Group for the project on 21st
November 2013, explained the Second Stage Consultation and discussed the part the project could contribute to the Plan and how, it, in return could enable demand for building stone to be met.
2.34. On 13th March 2014 an Officer met volunteers for the project, explained the
Minerals Local Plan and the council's support for the 1,000 years project and how the project would be used within it.
2.35. A brief update on the responses to the Second Stage Consultation on the Plan and reference to the continued commitment to encouraging building stone development in the county was reported to a further meeting of the Steering Group on 13th June 2014.
West Midlands Regional Technical Advisory Body for waste (RTAB) 24/01/14
2.36. The Minerals Local Plan and Second Stage Consultation were explained to the RTAB. Relevant Waste Core Strategy policies and the need for "urban quarries" and the free movement of Construction and Demolition waste through the Green Belt were discussed. The need for the Plan to emphasise the value of this waste and to ensure delivery of aggregates from recycled Construction and Demolition waste was stressed. The poor quality of data on this waste stream was agreed.
Worcestershire Planning Officers Group (WPOG) 04/02/2013 and 08/03/2013
2.37. Brief presentations and question and answer sessions about the MLP were made at the WPOG meeting of Development Management Officers on 4
th
February 2013 and the WPOG meeting of Policy Officers on 8th March 2013;
discussions focussed on restoration considerations and the wider implications of and links between mineral and housing development. .
Consultation on relevant appraisals and assessments
Sustainability Appraisal (SA)
2.38. An Initial Sustainability Appraisal was prepared by the Council and was published for consultation alongside the Minerals Local Plan Second Stage Consultation. This exceeds the six week minimum period which is required for consultation on the Sustainability Appraisal. It was publicised through all direct mail correspondence, the public notices and the minerals pages in the council's website.
2.39. The three statutory consultees for Sustainability Appraisal were also informed specifically. These bodies are Natural England, Environment Agency and English Heritage.
2.40. Comments were received from two of the three statutory consultees: Natural
England and English Heritage. No specific comments were received from the Environment Agency on the SA itself but related issues were referred to in the Agency's response to the Consultation as a whole..
2.41. Natural England were supportive of the initial SA and did not give any detailed
comments for inclusion or further consideration. English Heritage were broadly supportive and highlighted some issues for continued or further inclusion, such
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as suggesting the inclusion of specific objectives and monitoring indicators for the historic environment within the SA.
2.42. A further response was received from a member of the public, stating that the
consultation was "too complex to comment on properly".
Habitats Regulations Assessment (HRA)
2.43. A Habitats Regulations Assessment Scoping Report was prepared by the Council and was published for consultation alongside the Minerals Local Plan Second Stage Consultation. It was publicised through all direct mail correspondence, the public notices and the minerals pages in the council's website.
2.44. The statutory consultee for Habitats Regulations Assessment was also informed specifically. This body is Natural England.
2.45. Comments were received from Natural England. Natural England was
supportive of the approach taken to the HRA, and gave further information about Natural England's project to make finalised Conservation Objectives for all European sites available online. They suggested that soil compaction should be recognised as an environmental impact which could occur as a result of the extraction of any materials. They advised that requirements for project-stage HRA highlighted in the Scoping Report should be written into the Minerals Local Plan.
2.46. A further response was received from a member of the public, stating that the
consultation was "too complex to comment on properly".
Equality Impact Assessment
2.47. An Equalities Impact Assessment desktop screening was prepared by the Council and was first published for consultation alongside the Minerals Local Plan First Stage Consultation. This was not revised for the Second Stage Consultation but remained available for comment.
2.48. No comments were received.
Consultation on the evidence base
2.49. It is essential that the Minerals Local Plan is based on robust evidence. To
develop this evidence base a suite of background documents will be developed to support and inform the emerging policy framework.
2.50. The background documents which were available for comment alongside the
Second Stage consultation were: What minerals are found in Worcestershire?
Background Document: Analysis of Mineral Resources in Worcestershire – which sets out the methodology for analysing the available information about the mineral resources which are present in the county in order to evaluate the likelihood of them being suitable and commercially attractive for exploitation during the lifetime of the plan.
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Background Document: Coal in Worcestershire
Background Document: Salt and Brine in Worcestershire
Background Document: Clay in Worcestershire
Background Document: Building Stone in Worcestershire How much of each mineral do we need to make provision for?
The Local Aggregates Assessment for Worcestershire – June 2013
The Draft Local Aggregates Assessment for Worcestershire – October 2012
Background Document: Ensuring adequate and steady supply of industrial and energy minerals
What are the other local issues?
Background Document: Contributing towards Worcestershire's priorities -which sets out how the minerals local plan could contribute towards the Council's corporate priorities and the priorities of the Sustainable Community Strategy.
Background Document: Minerals and Climate Change – which considers the contribution that the Minerals Local Plan could play to reducing Worcestershire’s climate change emissions and planning for and adapting to climate change.
Background Document: The Malvern Hills Acts - which sets out the unique legislative framework regarding mineral working in the Malvern Hills.
Profile documents for Environmental Character Areas – these detail the mineral and environmental context in the Environmental Character Areas which form the basis for the Worcestershire Green Infrastructure Framework. There are 30 Environmental Character Areas.
2.51. No comments were received on any of the background documents specifically,
although some responses to the main consultation referred to the Local Aggregates Assessment and the Analysis of Mineral Resources.
2.52. The background documents will be reviewed as necessary and further background documents will be produced during the development of the Minerals Local Plan.
Summary of activities under the duty to cooperate
2.53. A more detailed summary of the discussions held with each of the bodies we
have a duty to cooperate with is set out in the Annual Monitoring Report.
2.54. Following the close of the First Stage Consultation in January 2013, the following activities have been undertaken:
Body Method of engagement Outcomes
Worcestershire Local Authorities
Herefordshire and Worcestershire Planning Policy Officers Group Presentation and discussion
Awareness raised, broad issues of mutual interest identified, particularly with regard to the contribution mineral workings could make to recreation sites
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on 8th March 2013. being proposed in district wide
Local Plans. Informal links established.
Herefordshire and Worcestershire Development Management Officers Group Presentation and discussion on 4
th February 2013.
Awareness raised and broad issues of mutual interest raised, particularly with regard to liaison procedures over possible future mineral and housing development sites. Informal links established.
Bromsgrove District Council: Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation. Officers attended the open day held in Bromsgrove and subsequently asked for clarification of whether there were any minerals issues for any of the proposed development sites. WCC officers compared each site with known mineral resources and provided a commentary on each of the proposed development sites (10
th December 2013). This
identified one site which would require further assessment and advised on what the assessment should address.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Redditch Borough Council: Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
Response received noting that there are no commercial or cruising waterways within Redditch Borough's boundary.
Wyre Forest District Council: Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation, supporting the restoration-led approach and close links with Green Infrastructure, and highlighting the District Council's Green
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Infrastructure Study and Strategy as an information source. WFDC supported the vision, objectives and strategic restoration priorities. It supported the approach to identifying areas of search and safeguarding minerals.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
South Worcestershire Authorities: Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. South Worcestershire made many comments, broadly focused on:
The need for policy criteria
Adequate and steady supply of minerals, impact of housing numbers on demand, phasing of working and delivery milestones, concern at lower target after 2016
Preference for identifying specific sites or preferred areas
Appropriateness of protecting and enhancing Worcestershire's key economic sectors
Need for references to sustainable transport and community engagement in the vision
Maximising use of secondary and recycled materials, acknowledging imports and exports and comprehensive working of permitted reserves
The need for high environmental standards throughout site life
Transport, traffic impacts and the use of sustainable modes of transport
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Methodology for identifying areas of search,
Desire to input into restoration priorities and profiles
Implications of mineral overlap with South Worcestershire site allocations for housing or employment land
Potential impact on Malvern Hills, AONBs, Abberley Hills, Green Belt, landscape character
Appropriateness of "restoration-led" approach
Need for more information on safeguarding resources and infrastructure assets.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Surrounding Minerals Planning Authorities
Shropshire: Meeting held 11
th March 2013
– discussed proposed approaches by both counties to plan making, green infrastructure and environmental networks, Local Aggregates Assessments, building stone and waste.
No issues of conflict identified. Agreed to continue discussions as approaches develop, but no areas of concern or conflict at present. Agreed both counties are proposing appropriate levels of production. The only significant possible issue of cross-border supply is that Shropshire's high-quality roadstone may be supplying part of Worcestershire's need but this reflects normal workings of the market due to the special nature of the material.
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
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Herefordshire: April/May 2013 – Email discussion regarding the two counties' crushed-rock sales data which have been merged for many years, making it difficult to establish an average of past 10 years sales in the Local Aggregates Assessment.
Discussion regarding the methodology led to agreement to maintain the RAWP "apportionment" to 2016, followed by average of past 10-years sales on the assumption that 2/3 of crushed rock has been produced by Herefordshire and 1/3 by Worcestershire.
June 2013 – email exchange regarding mineral development in the Malvern Hills and Herefordshire's Core Strategy policies M3 and M4.
Discussion of wording and sharing data regarding the legislative context of the Malvern Hills led to minor amendments to policy wording and agreement that no conflict is anticipated between the emerging Worcestershire Minerals Local Plan and Herefordshire's emerging Core Strategy over mineral development in the Malvern Hills or the emerging plans and minerals issues generally.
17th July 2013 – meeting with
an update on the status of Minerals Planning Policy preparation in both counties, status and principles of Local Aggregate Assessments, discussion of any complementary or conflicting issues or matters of concern, data availability and sharing.
Agreed that there are no conflicts or matters of concern between the councils' timetables or approaches, and that both counties would proceed on the basis of supplying the WMRAWP sub-regional apportionment up to 2016 followed by average of past 10-years sales. Agreed that WCC intends to plan for supplying its share of both sand and gravel and crushed rock, but reliant on industry to make applications. WCC does not seek to rely on other counties contributions to meet its LAA requirements, but if the market were to look to quarries in Herefordshire to meet some of this need, Herefordshire Council agrees that its landbanks and productive capacity are capable of supplying some of those
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needs without difficulty and it would not object to this. Agreed that WMRAWP's AMR is the best source of data. For crushed rock, agreed to maintain the principle that 2/3 crushed rock production from Herefordshire and 1/3 from Worcestershire as a realistic way to aim for future supply. In the long term, 10 years supply average will become meaningful and usable. Agreed that there were no conflicts between the 2 counties' approaches to the LAA. Agreed that future meetings would be useful to ensure compatibility between approaches and the use of data.
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Warwickshire: Contacted by direct mail regarding Second Stage Consultation. Informal discussions between officers about the content and progress of both counties' Plans were held at the WMRTAB meetings.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Gloucestershire: February 2013 – email exchange confirming sites in
WCC confirmed the sites shown were correct and that there were
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Worcestershire to appear in maps in Gloucestershire's Minerals Local Plan.
no longer any operational quarries producing crushed rock or building stone in Worcestershire.
17th June 2013 – see "Joint
meeting" section below.
See below
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. Gloucestershire suggested that preferred areas or specific sites may be required to provide certainty to both industry and communities, demonstrate deliverability and avoid putting pressure on neighbouring authorities. Gloucestershire highlighted that potential development near to the county boundary could have cross-boundary implications which need to be considered at the next stage of plan preparation.
Informally consulted on Water Transport Paper, Winter 2014.
Gloucestershire replied stating that they had no specific comments, but referred us to their Transport Evidence Paper background document.
Staffordshire: Contacted by direct mail regarding Second Stage Consultation. Informal discussions between officers about the content and progress of both counties' Plans were held at the POS Mineral and Waste Learning Project Meetings and WMRTAB meetings.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
West Midlands conurbation
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"county" as Mineral Planning Authorities: Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation from any of the West Midlands Unitary Authorities.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Joint meeting: 17
th June 2013 – Hosted by
Worcestershire County Council and attended by:
Gloucestershire County Council (and South West RAWP representative),
Warwickshire County Council, and
Herefordshire Council Discussion of: status of MLP in each county (mineral types, timetable, broad principles, matters of mutual interest); status of Local Aggregate Assessment preparation and principles; any complementary or conflicting issues, matters of concern, and cross boundary initiatives; data sharing; working together effectively.
General discussion of these issues did not result in any specific actions. Agreed that ongoing dialogue is necessary.
West Midlands Resource Technical Advisory Body: A brief presentation was given to and discussion held with the WMRTAB meeting on 24
th January 2014.
Informal confirmation and re-assertion of RTAB support for earlier regional policy stance that C and D recycling made an important contribution to aggregate supply and that such facilities were appropriate in both urban and Green Belt locations.
West Midlands Aggregate Working Party: 18
th October 2013 - Meeting
of "West Midlands" Planning Authority officer
Noted WCC's close working relationship with Herefordshire but separate LAAs produced.
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representatives at Birmingham City Council Offices. Confirmed role of AWP in giving advice on Local Aggregate Assessment (LAA) production, compliance with guidelines and 'fair share of burdens'. Also discussed potential for establishing non-aggregate minerals group.
Noted that Worcestershire's LAA has gone to Cabinet. Other LAAs in the region may be produced jointly (i.e. Shropshire with Telford & Wrekin, Staffordshire with Stoke on Trent, West Midlands unitary authorities)
Other Aggregate Working Parties: The following Aggregate Working Parties were contacted by direct mail regarding Second Stage Consultation:
East Midlands AWP
East of England AWP
Greater London Authority AWP
London AWP
North East AWP
North Wales AWP
North West AWP
South East AWP
South Wales AWP
South West AWP
Yorkshire and Humber AWP
Response to Second Stage Consultation received from East of England AWP. Notwithstanding any comments that individual members of the AWP may make on the Plan, the EEAWP does not believe that the content of this Plan will have any significant impact on the AWP area. No response received to Second Stage Consultation from other AWPs.
Other authorities Surrounding Authorities: All surrounding Local Planning Authorities were contacted by direct mail regarding Second Stage Consultation.
Response to Second Stage Consultation received from Tewkesbury Borough Council. Their comments focused on cross-boundary impacts from mineral working, such as flooding and surface water management, landscape impact, biodiversity and transport, and the need to make appropriate provision throughout the plan period to prevent undue pressure on surrounding authorities. They also highlighted potential demand from development in
22
Gloucestershire. No response received to Second Stage Consultation from other surrounding Local Planning Authorities.
All surrounding Local Planning Authorities were informally consulted on the Water Transport Paper in Winter 2014.
No responses received.
The Planning Officers Society Mineral and Waste Learning Project (4 meetings p.a.): The content and progress of members' Mineral Plans is formally discussed at every meeting.
Bedfordshire Authorities (Central Bedfordshire, Bedford & Luton Boroughs),
Bradford, Derbyshire/Derby,
East Sussex/Brighton & Hove,
Essex,
Hampshire,
Hertfordshire,
Lincolnshire,
Northamptonshire,
Nottinghamshire, Oxfordshire,
Staffordshire,
Surrey,
West Berkshire,
West Sussex/South Downs NPA
Potential matters of mutual interest and concern are discussed at every meeting.
The Environment Agency
Member of the Minerals Green Infrastructure Steering Group (see below)
See below.
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. The Environment Agency supported the draft spatial portrait, suggesting greater reference to
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the Water Framework Directive and Flood Risk betterment, and supported the vision as being progressive and positively worded. They also supported the draft objectives, but suggested that explicit reference to 'Flood Risk' and 'betterment opportunities' would highlight their importance. Similarly, they supported the proposed policy issues, suggesting that future policy wording should commit to 'betterment opportunities'. They also highlighted that the 'sequential test' would need consideration and guidance in emerging policy, but that a balance will be needed between locating workings in low flood risk areas and providing opportunities for meaningful flood alleviation. They supported the progressive approach to assigning restoration priorities to areas of search, but suggested flexibility would be needed to take account of site-level conditions which may not align with strategic priorities.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
English Heritage Member of the Minerals Green Infrastructure Steering Group (see below)
See below.
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. English Heritage welcomed references to background data. They noted that traditional building and roofing stone is fundamental to maintaining built heritage. They welcomed references to the historic environment throughout and particularly the specific objective, but suggested that a reference could be included within the vision. They
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highlighted that clarity will be needed to show how appropriate areas/sites have been identified ensuring the protection, conservation and enhancement of the historic environment. They welcomed the opportunity to work with us to ensure a positive legacy for the historic environment as a result of minerals development and restoration, and encouraged consideration of the historic environment as an overarching restoration principle. They also commented fully on the Sustainability Appraisal.
Informally consulted on Water Transport Paper, Winter 2014.
No response received
Natural England Member of the Minerals Green Infrastructure Steering Group (see below)
See below.
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. Natural England supported the section on the Environment in the Portrait of Worcestershire, particularly the inclusion of green infrastructure, and welcomed the environmental aspects of the draft vision and draft Objective 6. Natural England particularly supported the inclusion of policy criteria on the natural and historic environment, but suggested that Green Infrastructure and soils could also be included. They fully supported the GI-led approach to restoration. They also commented fully on the Sustainability Appraisal and Habitats Regulations Assessment.
Informally consulted on Water Transport Paper, Winter 2014.
Natural England responded to say that "As a general principle the use of any waterways for
25
transporting minerals should ensure protection and enhancement of the environment".
The Mayor of London
Did not respond to the "Get involved in Planning" leaflet. No issues have been identified which require co-operation with the Mayor of London, therefore not consulted by direct mail regarding Second Stage Consultation.
N/A
Civil Aviation Authority
Contacted by direct mail regarding Second Stage Consultation.
Responded to Second Stage Consultation setting out CAA's areas of interest. No issues of conflict identified.
The Homes and Communities Agency
No issues have been identified which require co-operation with the Homes and Communities Agency. However, added to "blue group" and contacted by direct mail for Second Stage Consultation.
No response received to Second Stage Consultation.
Clinical Commissioning Groups (CCGs)
The Primary Care Trusts have been disbanded and new Clinical Commissioning Groups set up. These are:
South Worcestershire CCG
Redditch and Bromsgrove CCG
Wyre Forest CCG
New single point of contact established to act as conduit for all liaison over health matters.
National Health Service Commissioning Board
See above See above
Office of Rail Regulation
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Transport for London No issues have been identified which require co-operation with Transport for London. Not consulted.
N/A
Integrated Transport Authority: Centro
Added to "blue group" for Second Stage Consultation and contacted by direct mail.
No response received to Second Stage Consultation.
Highways Agency Contacted by direct mail regarding Second Stage Consultation.
Responded to Second Stage Consultation highlighting the Highways Agency's
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responsibilities in Worcestershire, requesting to be consulted as policies are developed to ensure adequate consideration is given to impacts on the Strategic Road Network.
WCC Highway Authority
WCC Highways were not sent the Second Stage Consultation in error. Subsequent discussion led to an individual contact being identified and the consultation material was forwarded on 12
th June 2014 for comment.
No response received at time of publication.
Informally consulted on the Water Transport Paper in Winter 2014.
No response received.
The Marine Management Organisation
No issues identified which require co-operation with the Marine Management Organisation. Following the "Get Involved in Planning" questionnaire, the Marine Management Organisation (MMO) requested not to be consulted, stating that "the remit of the MMO’s work reaches up to the mean high water springs mark along the coast and within any stretches of tidal river. Our maps indicate that there are no rivers within Worcestershire that are under tidal influence and as such this area is outside of the MMO’s remit. We therefore do not feel it necessary to be consulted on any of the areas covered by the questionnaire." On 12
th December 2013 we
wrote again to the MMO, highlighting the Duty to Cooperate and setting out that although we do not anticipate the plan affecting marine and tidal issues, there
Response received to consultation, recommending reference to marine aggregates be included within the Plan and highlighting information sources.
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may be areas of interest for the MMO such as imports from marine dredged sand and gravel or aspects of our Habitats Regulations Assessment.
Worcestershire Local Enterprise Partnership
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on the Water Transport Paper in Winter 2014.
No response received.
Greater Birmingham and Solihull Local Enterprise Partnership
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on the Water Transport Paper in Winter 2014.
No response received.
Worcestershire Local Nature Partnership
The Worcestershire Partnership was remodelled into a wider range of groups during this time. One of the most relevant to the MLP is the newly formed Local Nature Partnership. Contacted via LNP secretary (listed as one of the Worcestershire County Council contacts in Appendix C) regarding Second Stage Consultation.
No response received to Second Stage Consultation from LNP itself, although many of its members are represented in the Minerals Green Infrastructure Steering Group (see below).
Minerals Green Infrastructure Steering Group
2.55. A steering group was established to assist with embedding the Green
Infrastructure approach in the Minerals Local Plan. The group consists of:
English Heritage
Environment Agency
Forestry Commission
Natural England
Nature After Minerals/RSPB
Worcestershire Wildlife Trust
Worcestershire County Council: o Strategic Planning & Environmental Policy o Ecology o Landscape o Development Management o Water/flooding
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o Countryside Access & Recreation o Historic Environment
Not all participants have been able to attend all meetings, but all have been included on email circulations with agendas, minutes and draft documents for comment.
2.56. A number of meetings were held between the First Stage and Second Stage
consultations to develop the Green Infrastructure approach: Meeting of 30th January 2013:
Exploratory meeting to discuss the pros, cons and practicalities of using GI principles and restoration potential to drive the development of the Minerals Local Plan. The group supported taking an innovative GI approach to minerals.
Meeting of 10th April 2013:
Group members had contributed information to inform "Environmental Character Area Profiles". Officers had also been developing Areas of Search, and were using the issues and priorities from the Environmental Character Area profiles to establish the strategic priorities for each Area of Search.
Two mock-examples were presented to the group to critique. An early draft of the vision and objectives was given to the group alongside a table setting out considerations under each objective showing which were likely to be addressed through policy criteria and which might be strategic priorities for areas of search. These were then looked at as a "primary", "secondary" or "tertiary" priorities (working terms) for each of the areas. The group helped make amendments to the strategic priority groupings and suggested ways in which priority levels could be established.
The group agreed that a habitat approach would be better than a species approach, and that landscape changes need to either be consistent with existing landscape character or be wholly different, not piece-meal degradation.
Officers were to commence work on developing the areas of search and profiles. The group asked to be sent drafts and to meet to discuss and refine them in batches, preferably covering diverse areas of search in the first batch to try and iron out most of the major issues up front.
Meeting of 28th May 2013 and 11th June 2013:
A method statement setting out how strategic priorities, secondary priorities and tertiary priorities had been derived and a method for applying these to the Areas of Search were provided for group discussion:
o Each aspect was discussed and the group made suggestions for refining the methods or the data used.
Draft examples of Area of Search profiles were provided for group discussion:
o The group agreed that the level of detail was appropriate. o The group discussed the interplay of the priorities, whether it was
appropriate if the method resulted in some areas having lots of primary priorities, whether there was potential for conflict between
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priorities, whether minerals sites could deliver the priorities, and the need to bring out important issues in each Area of Search.
o Further discussion looking at the examples raised points which needed to be refined in the method or data used, as well as individual points of interest for individual areas of search.
The group agreed that a sub-group would meet to discuss landscape and heritage issues and methodology and report back.
The group agreed that minerals officers would liaise with water interests to finalise methodology for water aspects.
The group agreed that WCC's Environmental Policy team would consider the biodiversity aspect to finalise the methodology.
The group agreed that WCC Minerals officers would pick up on the advice from these subgroups and consult the whole group on final methodology and worked examples through email and file sharing.
Discussion with Minerals Industry
Cemex and Tarmac
2.57. A meeting was held on 16th July 2013 with representatives from Cemex and
Tarmac. This gave a brief introduction to the Minerals Local Plan, the minerals covered, timetable and next consultation stage, and broad principles.
2.58. Discussions looked at:
the nature of and any likely changes to the minerals industry which could affect Worcestershire;
the nature of and likely changes at mineral site level, such as minimum size of workings, new production methods, plant, campaign working and water transport;
what Worcestershire-specific issues should be addressed in the Minerals Local Plan;
what other issues should be taken into account from other Mineral Planning Authorities;
issues which should be addressed regarding sand and gravel, crushed rock and other minerals;
any complementary or conflicting issues, matters of concern and cross boundary issues to be aware of;
data availability and sharing;
ways to work together effectively and appropriately; and
competition commission investigations.
2.59. Outcomes and actions included agreement to discuss:
possible pre-application proposals with the Development Management section and operator's agents in parallel with the Plan process,
The proposed emphasis on a restoration led approach further, if necessary, following the next consultation,
specific matters raised by individual companies individually if requested,
matters of concern to minerals operators as a group at a specific seminar.
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Tarmac
2.60. A meeting was held on 7th February 2014 between Worcestershire County
Council's Minerals and Waste Policy team, Development Management team and PleydellSmithyman Ltd (representing Tarmac). This meeting looked at the relationship between the emerging Minerals Local Plan and future site development at Clifton Gravel Pit.
2.61. Discussions looked at:
Tarmac's existing operations in Worcestershire, likely lifetime left at those sites and plans for future extraction;
Site investigations already undertaken and likely to be required;
Ground water, particularly relating to a nearby SSSI and private water supplies;
Access arrangements, amenity and restoration issues;
Potential for restoration of the Clifton site for recreation purposes;
Likely timescale of an application in relation to submission or adoption of the Minerals Local Plan.
Salop Sand and Gravel
2.62. A meeting was arranged with Salop Sand and Gravel including a site visit at Chadwich Lane Pit for 18
th September 2013. The agenda for this meeting was
the same as for the meeting with Cemex and Tarmac.
2.63. Worcestershire County Council officers attended the meeting, but representatives from Salop Sand and Gravel did not arrive and the meeting was not held.
2.64. A meeting was held at Worcestershire County Council's offices on 7
th February
2014 between Worcestershire County Council's Minerals and Waste Policy team, Development Management team, Mr Parton of Salop Sand and Gravel and PleydellSmithyman Ltd (Salop Sand and Gravel's agent). This meeting looked at the relationship between Mr Parton's operations and potential future plans, the requirement for restoration plans and restrictions to infilling as a restoration option in the future.
Coal Authority and CoalPro
2.65. A meeting was held on 13th August 2013 with representatives from the Coal
Authority and CoalPro. This gave a brief introduction to the Minerals Local Plan, the minerals covered, timetable and next consultation stage, and broad principles.
2.66. Discussions looked at:
the nature of and any likely changes to the minerals industry which could affect Worcestershire;
the nature of and likely changes at mineral site level, such as minimum size of workings, new production methods, plant, campaign working and water transport;
what Worcestershire-specific issues should be addressed in the Minerals Local Plan;
what other issues should be taken into account from other Mineral Planning Authorities;
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issues which should be addressed regarding coal;
issues which should be addressed regarding other minerals associated with coal;
any complementary or conflicting issues, matters of concern and cross boundary issues to be aware of;
data availability;
ways to work together effectively and appropriately; and
competition commission investigations.
2.67. Outcomes and actions included:
Only surface working of coal is conceivable in Worcestershire at present. Alternative hydrocarbon extraction techniques are theoretically possible but likely to be unviable;
Although some coal strata are geologically present, at best the deposits are very thin, in practice all commercial surface deposits may have already been worked out, meaning that there is no coal resource for future extraction in the county;
Coal hazards however are important and have been mapped in Worcestershire. The areas affected should be "safeguarded" to ensure that the ground conditions can be assessed and any remedial action undertaken before other development is permitted;
Policies should be included to enable coal and related minerals to be developed if applications come forward, subject to the provisos in the NPPF.
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2.68. Appendix A provides a summary of the requirements which relate to consultation requirements and cooperation with other bodies.
2.69. This is a working document that will be updated as the Minerals Local Plan is
developed. The final consultation statement will be submitted to the Secretary of State alongside the Minerals Local Plan and will present the information required under section 22(1)c of The Town and Country Planning (Local Planning) (England) Regulations 2012.
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3. First Stage Consultation 3.1. The first formal stage of consultation on the Minerals Local Plan began on 9
th
October 2012 and ran until 11th January 2013.
3.2. This consultation had two main objectives:
to raise the profile of the Minerals Local Plan and build the mailing list for future rounds of consultation; and
to help in establishing an understanding of the issues and local context.
3.3. A variety of consultation and engagement methods were therefore used to meet these different objectives:
Consultation leaflet and questionnaire;
Open morning drop-in session;
Stakeholder workshop; and
Online quiz. More details about these methods are outlined later in this section.
Publicity activities
Worcestershire County Council Website
3.4. All relevant documents were included in a dedicated section on the Council's website with the shortlink www.worcestershire.gov.uk/minerals. This link was included in all public notices, press releases, social media posts, letters and emails.
3.5. The consultation was also listed on the Council's "consultation portal" and was publicised on the residents homepage.
Public notices 3.6. Public notices were placed in newspapers covering the county:
Bromsgrove Advertiser (17th October 2012)
Evesham Journal (18th October 2012)
Kidderminster Shuttle (18th October 2012)
Kidderminster Times (18th October 2012)
Ludlow Advertiser (18th October 2012)
Malvern Gazette (19th October 2012)
Redditch Advertiser (17th
October 2012)
Stourbridge News (18th October 2012)
Worcester News (18th October 2012)
Press releases 3.7. Press releases were sent to all County newspapers and radio stations at the
beginning of the consultation and before the open morning, however none chose to run the story.
Direct mail
3.8. An email including details of the consultation leaflet, questionnaire, open morning, workshop and quiz was sent to all contacts on the Council's Minerals
34
Planning Database who had opted to be contacted by email. All other contacts on the database were sent a copy of the consultation leaflet and questionnaire by post.
3.9. The database was developed by contacting all parties registered on the consultation database for the Statement of Community Involvement and Waste Core Strategy and asking whether they would like to be involved in consultation on the Minerals Local Plan. Of the 1300 people contacted approximately 520 requested to be contacted about the Minerals Local Plan. This was comprised of 301 'Specific Consultees', 86 'General Consultees' and 126 other interested parties. A full list of consultees is set out in Appendix B.
3.10. In addition, a total of 137 organisations that the council considered could have a
particular interest in the plan were sent a copy of the "Get involved in Planning" leaflet and sent a reminder letter on 23
rd October 2012.
3.11. This database will be developed during the preparation of the Minerals Local
Plan and anyone who expresses an interest will be invited to join. The online quiz was intended as a tool to help to increase the number of interested parties registered on the database.
Social Media
3.12. Facebook: A link to the consultation webpage and quiz were posted on the "Worcestershire" facebook page on 29
th October 2012. At this time the page had
approximately 280 followers and was being 'talked about' by 14 people. The link to the minerals webpage itself received 3 'likes'.
3.13. Twitter A link to the consultation webpage and quiz were posted on the
Council's "WorcCC" Twitter feed on 22nd
October with an additional tweet on 9th
November to publicise the open-morning. The Council had approximately 3,200 followers at this time.
Methods used
Consultation Leaflet
3.14. The primary method of consultation at this stage was a short booklet that gave a brief introduction to what minerals are and why we need them, why people should get involved and what the Minerals Local Plan will aim to achieve. It also gave some local context outlining the minerals found in Worcestershire and likely levels of future provision. The consultation leaflet included seven questions, some of which were technical in nature and others which were more general. The questionnaire could be completed online or returned to our dedicated email address or freepost mailing address.
3.15. 37 responses were received through this method and covered the following
main issues:
Information on mineral resources including additional locations, the quality and quantity of resources, economically viability including site size and minimum amounts of material
New techniques, technology or changes in the economy could affect economic viability, particularly for coal resources
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Potential for the use of recycled aggregates
The amount of minerals to be provided
Issues that should be considered, including: o Amenity impacts; o Traffic and sustainable transport; o National and local economic benefits; o Green Infrastructure; o The potential for multifunctional benefits from site restoration; o Biodiversity gain and protection of designated nature conservation
sites; o Geological conservation; o Historic environment; o Landscape; o Ecosystem services; o Wetland restoration; o High quality agricultural land; o Nature Improvement Areas; o Climate change; o Protecting the Abberley Hills; o Water issues, including groundwater and other water resources,
flood risk and flood storage, the Water Framework Directive; o Waste re-use and landfill; o Public access networks, informal recreation, The Severn Way; o Building stone; o The National Planning Policy Framework; o Parish and Neighbourhood Plans; o The "sieve test" and constraints; o Green Belt; o Restoration, aftercare and long-term management
Information sources relating to: o The National Planning Policy Framework, o Malvern Hills Acts, o best practice Minerals Local Plans, o other Local and Parish Plans, o AONB management plans, o England Biodiversity Strategy and local Biodiversity Action Plans, o River Severn Basin Management Plan, o Nature After Minerals, o Geological records and geodiversity action plan, o Green Infrastructure, o the Strategic Stone Study Database, o Archaeology, o Tame Valley river restoration, o Rowney Green Bog Special Wildlife Site
3.16. The consultation responses are recorded in full in the Response Document
"Feedback on First Stage Consultation" (April 2013) along with the Council's initial response to these comments.
Open Morning
3.17. Officers held an open morning at Worcester Woods Country Park from 9.30-12.00 on Saturday 10
th November so that members of the public, Parish
36
Councils and other interested parties could ask any questions and raise any issue that they thought should be considered in the development of the Minerals Local Plan. There was no need to book places at this event.
3.18. The event was publicised in the consultation leaflet and in all publicity on the consultation in general. Specific links were also put on the Council's twitter feed and front page of the Council's website in the week before the event to raise awareness. A press-release was published but no publications chose to carry the story.
3.19. The open-morning was attended by members of the Earth Heritage Trust, Worcestershire CPRE, Upton upon Severn Town Council, Ripple Parish Council, Hanley Castle Parish Council, Wolverley Parish Council, Longdon Parish Council and the Upton Partnership and four members of the general public. Some of the attendees were part of more than one of these organisations. 30 copies of the consultation leaflet were also distributed to members of the public attending the Countryside Centre activity morning and cafe. Four people registered on the consultation database and two registered to attend the workshop sessions.
3.20. The issues raised at this event have been recorded in the Response Document
"Feedback on First Stage Consultation" (April 2013) alongside the other comments made on the consultation. The main issues raised related to:
the restoration of sites including concerns that the use of the word 'restoration' could be misleading and support for the potential for working and worked quarries to be used for educational purposes;
current and future supply including questions about the current situation and how future provision will be calculated;
a current application for sand and gravel extraction at Holdfast, near Upton on Severn. Several of the issues raised such as the consideration of flooding and impacts on the wider economy including tourism also have relevance as broad concepts to be considered during the development of the plan.
Workshop
3.21. A morning workshop was held 9.30 – 12.00 on Wednesday 21st November
2012. The event was publicised in the consultation leaflet and in all publicity on the consultation in general. Key stakeholders were also contacted directly with telephone invitations to all local authorities in Worcestershire, all adjoining Mineral Planning Authorities, mineral operators which have known interests in the County and the organisations which are statutory consultees for the sustainability appraisal.
3.22. The workshop was chaired by the Council's Minerals and Waste Policy Manager and facilitated by officers from the Planning and Economic Development unit. It was attended by five County Councillors, 3 other council officers and participants from the following organisations:
Local Authorities
Bromsgrove District Council (Councillor and officer)
Herefordshire Council
Malvern Hills District Council
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Warwickshire County Council
Wyre Forest District Council Town and Parish Councils
Bourneheath Parish Council (2)
Upton Parish Council
Local residents
Mrs Spooner
Mrs Inchbald
Operators
Cemex
Tarmac Other interests
Earth Heritage Trust
English Heritage
Environment Agency
Malvern Hills AONB Partnership
Nature After Minerals
Worcestershire LEP
Worcestershire Wildlife Trust
3.23. The workshop was structured into two sessions:
Spatial Strategy: There was a short presentation about the council's proposed approach, then delegates were split into five groups to discuss a) whether they supported a restoration-led approach and if so what objectives should drive this and b) what other considerations should lead the strategy. A restoration-led approach was broadly supported, but would need to be holistic, flexible and to take into account other factors. Implementation and enforcement were key concerns.
Impacts of mineral workings: The groups were asked to identify their main concerns in relation to mineral workings and to discuss potential ways that they could be addressed through policy. It was clear from the issues identified and discussion taking place that an integrated approach needs to be developed that engages with a variety of stakeholders, regulators and other bodies. This approach would need to take account of a variety of factors including impact on environmental character, flooding issues, hydrology, impacts on tourism and pollution control. The potential for a 'River Severn' plan to deliver such an approach was suggested. Other issues discussed included the merits of traditional building stone and the need to consider landfill carefully.
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3.24. The feedback from this event was positive, with stakeholders from a variety of different groups saying that they were satisfied with the discussion. There was some concern that industry and residents should not be asked to discuss these things together, however the majority of attendees felt that meeting different interests was useful. Following the event one delegate also tweeted about his attendance, further raising the profile of the Minerals Local Plan.
3.25. The issues raised at this event have been recorded in the Response Document "Feedback on First Stage Consultation" (April 2013) alongside the other comments made during the consultation.
Online Quiz
3.26. To raise awareness of mineral planning in the County a short online quiz was developed. The quiz asked 'general knowledge' questions about what minerals are used for, how much is needed to build a house, how far minerals are transported, what activities are going on locally and which local recreation facilities were previously mineral workings, with an invitation to provide their contact details if they would like to be involved in participating in future Minerals Local Plan consultations. At least 9 people undertook this quiz
1 and 2 requested
to be involved in future consultations.
Events with Partners
Worcestershire Partnership Environment Group (WPEG) 2
3.27. A presentation about the MLP consultations was made at the WPEG meeting on 5
th December 2012. The group suggested that the principles of Green
Infrastructure (GI) that are being developed through the sub-regional GI Strategy should be integrated into the Minerals Local Plan. Partner organisations were encouraged to make individual responses if appropriate.
Worcestershire Planning Officers Group (WPOG)
3.28. A brief presentation about the MLP consultations was made at the WPOG meeting of Development Management Officers on 4
th February 2013 and the
WPOG meeting of Policy Officers on 8th March 2013.
Worcestershire Parish Conference: Autumn 2012
3.29. Officers had a stand at the exhibition before the 8th Worcestershire Parish
Conference which ran 6-9pm 31st October 2012. All Parish Councils in
Worcestershire were invited to attend this event. About 20 people showed interest in the Minerals Local Plan either asking questions or taking copies of the consultation leaflet.
1 This is the number of people who clicked "submit" after taking the quiz. There was no requirement
to do this unless participants wished to join the consultation database, so it is possible that more people took the quiz but are not recorded. 2 This group consists of representatives from all Local Authorities and Local Strategic Partnerships in
Worcestershire, Hereford and Worcester Chamber of Commerce, The Duckworth Trust, Earth Heritage Trust, Act on Energy, Worcestershire Wildlife Trust, Worcestershire Friends of the Earth Network, British Waterways, English Heritage, Environment Agency, Forestry Commission, Natural England, Worcestershire Mental Health Partnership NHS Trust, Worcestershire Primary Care Trust, University of Worcester, Worcester College of Technology, Country Land and Business Association, Worcestershire Biodiversity Partnership, Worcestershire Pollution Group.
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Other activities
'Have your say' Roadshows
3.30. Worcestershire County Councillors and senior officers held a set of roadshows to give residents a chance to help shape future delivery of council services. The specific themes were localism and roads, but officers were also briefed on other issues including the Minerals Local Plan consultation so that they could inform anyone they thought may be interested. The roadshows were held in Bromsgrove, Worcester, Malvern, Wyre Forest, Redditch and Pershore town centres between 9
th and 30
th November 2012.
Consultation on relevant appraisals and assessments
Sustainability Appraisal
3.31. A Sustainability Appraisal Scoping Report was prepared by the Council and was published for consultation alongside the Minerals Local Plan First Stage Consultation. This exceeds the five week minimum period which is required for consultation on the Sustainability Appraisal Scoping Report. It was publicised through all direct mail correspondence, the public notices and the minerals pages in the council's website.
3.32. The three statutory consultees for Sustainability Appraisal were also informed specifically about the Scoping Report. These bodies are Natural England, Environment Agency and English Heritage.
3.33. Comments were received from each of the three statutory consultees. They
provided constructive feedback on how the proposed approach could better reflect sustainability issues. This included signposting to additional plans, policies and programmes which should be reviewed, and suggesting amendments and additions to the proposed SA framework to allow a more nuanced consideration of particular issues which might otherwise have been lost within too broad an analysis.
Equality Impact Assessment
3.34. An Equalities Impact Assessment desktop screening was prepared by the Council and was published for consultation alongside the Minerals Local Plan First Stage Consultation. It was publicised through all direct mail correspondence, the public notices and the minerals pages in the council's website.
3.35. No comments were received.
Consultation on the evidence base
3.36. It is essential that the Minerals Local Plan is based on robust evidence. To
develop this evidence base a suite of background documents will be developed to support and inform the emerging policy framework.
40
3.37. In summer 2012 background papers were published3 on:
Coal in Worcestershire Consultation document
Salt and Brine in Worcestershire Consultation document
Clay in Worcestershire Consultation document 3.38. They were made available for comment during the consultation period and will
be reviewed as necessary during the development of the Minerals Local Plan. 3.39. The following background documents were prepared by officers and were also
made available for comment during the consultation period:
The Draft Local Aggregates Assessment for Worcestershire
Ensuring adequate and steady supply of industrial and energy minerals
Background Document: Contributing towards Worcestershire's priorities which sets out how the minerals local plan could contribute towards the Council's corporate priorities and the priorities of the Sustainable Community Strategy.
Background Document: The Malvern Hills Acts which looks at the unique legislative framework regarding mineral working in the Malvern Hills.
3.40. Only one comment was received, relating to the use of imperial units in the Salt
and Brine document.
Summary of activities under the duty to cooperate
3.41. A more detailed summary of the discussions held with each of the bodies we
have a duty to cooperate with is set out in the Annual Monitoring Report.
3.42. Leading up to and during the First Stage Consultation in January 2013, the following activities were undertaken:
Body Method of engagement Outcomes
Worcestershire Local Authorities
Herefordshire and Worcestershire Planning Policy Officers Group: A brief presentation about the MLP consultations was made at the meeting of the WPOG Policy Officers on 8
th March 2013.
Awareness raised, arrangements for formal and informal liaison agreed. Discussion focussed on:
the importance of mineral development in enabling the physical construction of new development, and
links to and implementation of the county Green Infrastructure policy.
Herefordshire and Worcestershire Development
Discussion focussed on:
opportunities the restoration
3 In summer 2012 Worcestershire County Council welcomed three budding young planners into the
minerals planning team for a fortnight each. The volunteers were each tasked with preparing background evidence on a particular topic for the emerging Minerals Local Plan. The quality of the papers they prepared was such that we have published the reports they prepared for consultation with only minor editing.
41
Management Officers Group: A brief presentation about the MLP consultations was made at the meeting of the WPOG Development Management Officers on 4
th February 2013.
of sites offered, and
the likely location of new mineral workings.
Worcestershire Partnership: A brief presentation about the Minerals Local Plan was made at the Worcestershire Partnership Environment Group (WPEG) on 5
th December 2012.
Awareness raised, arrangements for formal and informal liaison agreed. Discussion focussed on:
the environmental (particularly with regard to flood management) and recreational opportunities the restoration of sites offered, and
links to and implementation of the county Green Infrastructure policy.
Bromsgrove District Council: A meeting was held on 21
st
September 2012. A briefing note to introduce the Minerals Local Plan and anticipated timetable was circulated.
Bromsgrove officers agreed to pass invitation to Minerals consultation workshop up to BDC councillors. Bromsgrove officers also supported the idea of an officer steering group approach to drafts of later consultations. Any complementary or conflicting priorities were discussed. Discussion of housing allocation sites and potential cross-over with Mineral Consultation Areas – at first glance didn't appear to be a major conflict, but WCC will comment in detail on request. There are nationally important Silica Sand reserves in Bromsgrove district, but not in problematic areas for BDC future development. Bromsgrove DC did not identify any particular current or anticipated concerns arising from mineral working in their district. Green belt could be a significant
42
issue when considering restoration/afteruse, some post restoration uses can only be permitted by the district council. The potential for joint SPDs restoration could be discussed in the future if appropriate.
Contacted by direct mail regarding First Stage Consultation. An Officer and a Councillor from Bromsgrove District Council attended the First Stage Consultation workshop.
No formal response received to First Stage Consultation.
Redditch Borough Council: A meeting was held on 24
th
September 2012. A briefing note to introduce the Minerals Local Plan and anticipated timetable was circulated.
Redditch officers agreed to pass invitation to Minerals consultation workshop up to RBC councillors. Any complementary or conflicting priorities were discussed. Discussion of Redditch's site allocations and minerals safeguarding noted that minerals assessment has been carried out at Tack Farm, results to be sent to WCC. Prior extraction may be required if it is a workable deposit (following receipt of results, prior extraction will not be required). Noted that the Minerals Local Plan will need a safeguarding policy/protocol, and that BGS report is a good starting point. The MLP will have a spatial strategy with restoration priorities, some after-uses would be determined by RBC – the potential for joint SPDs could be discussed in future if appropriate. Security of supply was discussed and the potential to jointly respond to other MPA consultations could be explored if necessary. WCC suggested that Redditch Local Plan should consider
43
geodiversity alongside nature conservation, and should make reference to the Waste Core Strategy.
Contacted by direct mail regarding First Stage Consultation.
No response received to First Stage Consultation.
Wyre Forest District Council: A meeting was held on 23
rd
August 2012. A briefing note to introduce the Minerals Local Plan and anticipated timetable was circulated.
Invitation to attend MLP consultation workshops was extended to WFDC officers and members. WFDC supported the idea of an officer steering group approach to drafts at later stages. Any complementary or conflicting priorities were discussed. Flooding and water quality are big issues for Wyre Forest. Development around Stourport in areas with mineral deposits will need to be considered in MLP development and responding to WFDC's development documents. Wyre Forest has a GI strategy which aims to fit GI around development sites, but could be updated once MLP has progressed further if necessary. Prior extraction requirements were discussed, not considered to be a significant issues as most allocated sites are previously developed land. Cross-over with SuDS requirements and the possibility of borrow pits was discussed. Green belt could be a significant issue when considering restoration/after-use and will need careful liaison. WCC supported the listing of all geological sites in Wyre Forest's DPD. The potential for joint SPDs re restoration could be discussed in the future if appropriate. WFDC highlighted a number of
44
their policies and other useful documents. Security of supply was discussed and the potential to jointly respond to other MPA consultations could be explored if necessary. Waste issues were discussed.
Contacted by direct mail regarding First Stage Consultation. Officers from Wyre Forest District Council attended the First Stage Consultation workshop.
No formal response received to First Stage Consultation.
South Worcestershire Authorities: A meeting was held on 27
th
June 2012 with officers from Wychavon and Worcester City (Malvern Hills sent apologies and would liaise with Worcester City following the meeting). A briefing note to introduce the Minerals Local Plan and anticipated timetable was circulated.
The types of minerals in South Worcestershire were discussed. Any complementary or conflicting priorities were discussed. Restoration options and the potential to tie in to Green Infrastructure were discussed, such as agriculture, horticulture, forestry, and informal recreation. Noted that landfilling would be dependent on geology and is discouraged by the WCS. Noted that Landscape Character Assessment needs to be considered. Discussed the potential for fixed plant with "feeder" sites, depending on economics and transport issues. Some SWDP site allocations could be in mineral safeguarding areas. Districts should be using the existing MLP proposals map until better data is produced. WCC requested details of any concrete batching plant operating under district permissions. Effects on transport network from mineral development particularly need to be considered. SWDP will be a demand factor
45
for the MLP to take into account. Mineral safeguarding and consultation areas was identified as a key area of work. Security of supply was discussed and the potential to jointly respond to other MPA consultations could be explored if necessary. South Worcestershire would support involvement in an officer steering group. Evidence documents were highlighted. Memoranda of Understanding could be produced for specific issues if required.
Contacted by direct mail regarding First Stage Consultation. Officers from Malvern Hills District Council attended the First Stage Consultation workshop.
Response received to consultation welcoming the development of the Minerals Local Plan. South Worcestershire recognised the role of the county council as MPA and that minerals form an important part of South Worcestershire's economy. They identified a number of areas that the Minerals Local Plan should address and responded to each of the specific consultation questions.
Surrounding Minerals Planning Authorities
Shropshire: Contacted by direct mail regarding First Stage Consultation. Officers from Shropshire had booked places on the consultation workshop but were unable to attend.
No response received to First Stage Consultation.
Herefordshire: A meeting was held on 28
th
June 2012. A briefing note to introduce the Minerals Local Plan and anticipated timetable was circulated. Herefordshire's Core Strategy timetable was also discussed.
Agreed that development in Herefordshire could be a demand factor for the MLP to take into account, but not likely to be high as relatively little housing proposed near to Worcestershire. No issues of potentially significant conflict between the two counties with regard to
46
minerals planning have been identified, and joint planning for the provision of waste management facilities in the JMWMS has been successful. Data issues, an overview of the active mineral sites in both counties and the status of the regional apportionment were discussed. The pros and cons of developing a joint evidence base, or shared assumptions and a separate plan were discussed, and it was agreed to share evidence where possible. Agreed that producing a joint plan was not likely to be viable due to timetable and resource issues and differences in structure and priorities of the two councils. Both councils agreed to consider whether any of these options might be viable.
Contacted by direct mail regarding First Stage Consultation. Officers from Herefordshire attended the consultation workshop.
No formal response received to First Stage Consultation.
Warwickshire: A meeting was held on 16
th
August 2012. A briefing note to introduce the Minerals Local Plan and anticipated timetable was circulated. The meeting was followed by site visits to Mancetter Quarry and Middleton Hall RSPB reserve (former quarry).
Worcestershire noted crushed rock data and provision difficulties and outlined the other mineral types which are important in Worcestershire. Warwickshire previously suspended work on MLP to concentrate on Waste Core Stategy, which is due to be submitted September 2012. Warwickshire gave an overview of their existing sites, landbank levels and sites previously proposed. Safeguarding issues were discussed, and it was noted that there are examples of retaining plant and transporting from satellite sites in both counties. Cross-boundary considerations
47
might include water transport, depending on source and destination, and habitats and landscapes. Agreed that any cross county initiatives will need to be recognised. No complementary or conflicting priorities were identified, agreed to continue "ideas exchange".
Contacted by direct mail regarding First Stage Consultation. Officers from Warwickshire attended the consultation workshop.
No formal response received to First Stage Consultation.
Gloucestershire: Contacted by direct mail regarding First Stage Consultation. Officers from Gloucestershire had booked places on the consultation workshop but were unable to attend.
No response received to First Stage Consultation.
Staffordshire: Contacted by direct mail regarding First Stage Consultation. Officers from Staffordshire had booked places on the consultation workshop but were unable to attend.
No response received to First Stage Consultation.
West Midlands conurbation "county" as Mineral Planning Authorities: Contacted by direct mail regarding First Stage Consultation.
No response received to First Stage Consultation from any of the West Midlands conurbation Mineral Planning Authorities.
West Midlands Resource Technical Advisory Body: The consultation and progress on the emerging plan and issues being considered was reported to the WMRTAB members (Warwickshire CC, Shropshire CC, Coventry City Council, Birmingham City Council, Derbyshire CC, Dudley Council, Flintshire Council, Herefordshire
Awareness raised at meeting of 25
th September 2012.
Discussion at meeting of 3
rd
December focussed on:
the importance of recycled Construction and Demolition (C and D) waste to mineral supply,
48
Council, Sandwell Council, Staffordshire County Council, Stoke City Council, Solihull District Council, Telford Council, Walsall Council, Wolverhampton Council, the Environment Agency, National Industrial Symbiosis Programme, Biffa UK, Greenwatt UK, Robert Hopkins Ltd, the East Midlands RTAB, the South Wales RTAB Friends of the Earth) at their meetings of:
25th September 2012 and
3rd
December 2012
the need for "urban quarries" (C and D recycling depots) and
problems of data collection.
West Midlands Aggregate Working Party: There were no meetings of the West Midlands Aggregates Working Party during this period.
N/A
49
Other Aggregate Working Parties: The following Aggregate Working Parties were contacted by direct mail regarding the First Stage Consultation:
East Midlands AWP
East of England AWP
London AWP
North East AWP
North Wales AWP
North West AWP
South East AWP
South Wales AWP
South West AWP
West Midlands AWP
Yorkshire and Humber AWP
The Convenor of the AWP secretaries and secretaries of
East Midlands AWP
North Wales AWP
North West AWP
South Wales AWP
South West AWP
Yorkshire and Humber AWP
were all contacted by email and sent a reminder letter on 23
rd
October 2012. Discussions with the POS Mineral and Waste Learning Group suggested that the other AWPs were either not significant with regard to Worcestershire or not operational and unable to reply.
No response received to First Stage Consultation from any of the Aggregate Working Parties.
Other surrounding authorities
All surrounding Local Planning Authorities were contacted by direct mail regarding the First Stage Consultation.
No response received to First Stage Consultation from any of the surrounding authorities.
The Environment Agency
A meeting was held on 7th
August 2012 as a preliminary informal meeting to air ideas. Several aspects of the Environment Agency's remit were represented at the meeting:
Planning liaison
Water framework
Matters discussed included:
Assessing need, increased recycling and zero carbon context
Biodiversity offsetting
Groundwater recharge
Flexibility for new technologies
Climate change
50
directive
Flood risk management
Biodiversity
Hydrogeology. A brief introduction was given to the Minerals Local Plan.
Temporary land use - opportunity for landscape scale biodiversity gain. Particularly water, wet meadow, wet woodland. Poor quality soil can mean good botany.
Restoration
Benefit of voids
Hydraulic continuity - water protection problems or local water supply issues (wells)
Flood risk, SFRA should lead to application specific FRAs
Impact of bunds on flood storage
Ability for restoration to offer flood storage
Birdstrike/airport issues
Visual impact of voids/lakes
Developer contributions
Restoration management by natural processes
Land ownership
After-use: examples - rock climbing facilities at restored sites can keep people off sensitive faces elsewhere. Water skiing on a new lake will mean little damage, much better than using sensitive existing lakes.
Enhancing degraded rivers (presentation): o Break down barriers
between gravel pits and river
o Low/no cost to minerals companies (income from extra resource)
o Improves fish populations in pits and rivers
o More difficult if the river is navigable, but could still link site
51
and river.
Hydropower and hydrothermal energy schemes
Potential information sources and some examples of good and bad practice were highlighted. EA were willing to take part in stakeholder groups and comment on early consultation drafts. EA highlighted that the MLP should address operational phase and restoration phase, and restoration opportunities need to be built into operational phase.
Contacted by direct mail regarding First Stage Consultation. Attended the First Stage Consultation workshop.
Response received to First Stage Consultation. The Environment Agency provided comprehensive comments on groundwater, biodiversity, flood risk issues, the interaction with waste and mineral needs, and commented on the outcome of group discussions at the consultation workshop. They also commented fully on the Sustainability Appraisal Scoping Report.
English Heritage Contacted by direct mail regarding First Stage Consultation. Attended the First Stage Consultation workshop.
Response received to First Stage Consultation. English Heritage commented on each of the aspects covered by the consultation questions, highlighting information on building and roofing stone, welcoming the commitment to addressing the historic environment and highlighting further data sources for policy preparation. They stated their willingness to continue to input into the development of the Plan, its supporting evidence and policy framework. They also commented fully on the Sustainability Appraisal Scoping Report.
Natural England Contacted by direct mail Response received to First
52
regarding First Stage Consultation.
Stage Consultation. Natural England highlighted Green Infrastructure and Nature Improvement Areas as issues for consideration. They also commented fully on the Sustainability Appraisal Scoping Report.
The Mayor of London
Sent a copy of the "Get involved in Planning" leaflet but did not reply. No issues have been identified which require co-operation with the Mayor of London, therefore not consulted by direct mail regarding First Stage Consultation.
N/A
Civil Aviation Authority
Contacted by direct mail regarding First Stage Consultation.
No response received to First Stage Consultation.
The Homes and Communities Agency
Sent a copy of the "Get involved in Planning" leaflet but did not reply. No issues have been identified which require co-operation with the Homes and Communities Agency, therefore not consulted by direct mail regarding First Stage Consultation.
N/A
Primary Care Trusts
Worcestershire and Wyre Forest PCTs and West Midlands Strategic Health Authority were contacted by direct mail and sent a reminder letter asking if they would like to be added to our consultation database on 23
rd October 2012.
No response received to First Stage Consultation.
Office of Rail Regulation
Contacted by direct mail regarding First Stage Consultation.
No response received to First Stage Consultation from the Office of Rail Regulation. However, Network Rail provided additional consultee details for any proposals to work minerals near the railway.
Transport for London
No issues have been identified which require co-operation with Transport for London, therefore not consulted by direct mail regarding First Stage Consultation.
N/A
Integrated Transport Authority: Centro
Sent a copy of the "Get involved in Planning" leaflet but did not reply. Were contacted by email
N/A
53
and sent a reminder letter on 23
rd October 2012. Not
consulted on the First Stage Consultation.
Highways Agency Contacted by direct mail regarding First Stage Consultation.
Response received to First Stage Consultation highlighting the Highways Agency's responsibilities in Worcestershire, requesting to be consulted as policies are developed to ensure adequate consideration is given to impacts on the Strategic Road Network.
WCC Highway Authority
Sent a copy of the "Get involved in Planning" leaflet but did not reply. Not sent the First Consultation document.
N/A
The Marine Management Organisation
No issues identified which require co-operation with the Marine Management Organisation. The Marine Management Organisation (MMO) requested not to be consulted, stating that "the remit of the MMO’s work reaches up to the mean high water springs mark along the coast and within any stretches of tidal river. Our maps indicate that there are no rivers within Worcestershire that are under tidal influence and as such this area is outside of the MMO’s remit. We therefore do not feel it necessary to be consulted on any of the areas covered by the [Get Involved in Planning] questionnaire."
N/A
Worcestershire Local Enterprise Partnership
Contacted by direct mail regarding First Stage Consultation. Attended the First Stage Consultation workshop.
No response received to First Stage Consultation.
Greater Birmingham and Solihull Local Enterprise Partnership
Contacted by direct mail regarding First Stage Consultation.
No response received to First Stage Consultation.
54
55
4. Second Stage Consultation 4.1. The second formal stage of consultation on the Minerals Local Plan began on
11th November 2013 and ran until 31
st January 2014.
4.2. This consultation included:
A portrait of Worcestershire giving an overview of the minerals found in Worcestershire and identifying the key issues affecting the county
A draft vision and objectives for what the Minerals Local Plan should aim to achieve
A spatial strategy diagram which set out very broadly what type of development the County Council would like where
Details of how much of each mineral we need to provide and when, including alternative methods considered in making this calculation and options for when it should be provided
Ideas about how minerals should be worked, setting out the issues to be considered when developing criteria to manage working practices
Ideas about where minerals should be worked, setting out the issues to be considered when developing location criteria for all mineral workings and identifying 'areas of search' for aggregates and an 'opportunity area' for clay
Ideas about how mineral workings should be restored, setting out issues to be considered when developing principles for all workings and a proposed approach to identifying key considerations and restoration priorities for each individual 'area of search'
Details of how minerals should be safeguarded for future use including alternative options to consider
4.3. A variety of consultation and engagement methods were therefore used to meet
these different objectives:
Consultation document, summary document and questionnaire;
Open day drop-in sessions;
Stakeholder workshops offered; and
Online quiz. More details about these methods are outlined later in this section.
Publicity activities
Worcestershire County Council Website
4.4. All relevant documents were included in a dedicated section on the Council's website with the shortlink www.worcestershire.gov.uk/minerals. This link was included in all public notices, press releases, via social media posts, and in letters and emails.
4.5. The consultation was also listed on the Council's "consultation portal" and was publicised in two articles posted to the front-page news section of the Council's website during the consultation.
Public notices 4.6. Public notices were placed in newspapers covering the county:
Bromsgrove and Droitwich Advertiser (13th November 2013)
56
Evesham Journal (14th November 2013)
Kidderminster Shuttle/Times (14th November 2013)
Ludlow & Tenbury Wells Advertiser (14th November 2013)
Malvern Gazette and Ledbury Reporter (15th November 2013)
Redditch Advertiser and Alcester Chronicle (13th
November 2013)
Stourbridge News/County Express (14th November 2013)
Worcester News (14th November 2013)
Press releases 4.7. Two rounds of proactive media activity, tailored by news patch, were undertaken
during the consultation period with press releases being sent to all County newspapers and radio stations. 11 articles appeared in local media.
4.8. Press releases were also sent to other organisations and stories were carried in the following publications:
Worcestershire County Association of Local Councils, CALC Update, Issue 42 (8
th November 2013)
Wychavon's Strategic Partnership and LSPs newsletter, Communicate (December 2013)
NFU's weekly email newsletter to all members in the West Midlands (from 15
th November for several weeks) and the regional pages of
NFUOnline.com4.
Direct mail
4.9. On 11th November 2013, an email was sent to all contacts on the Council's
Minerals Planning Database who had opted to be contacted by email (394 email addresses) and all other contacts on the database were sent a letter (113 postal addresses). Both of these included details of and links to the summary and main consultation documents, questionnaire, open days, and background documents.
4.10. Following further consideration of the contacts who had registered an interest in the Minerals Local Plan, it was felt that there may be additional contacts who it would be desirable to inform about the consultation. All contacts on the SCI and Waste Core Strategy consultation database had previously been sent the "Get involved in Planning" Questionnaire but a number of contacts either did not respond, or responded but did not request to receive information on minerals policy. These contacts were considered and three groups were identified:
"white group" – this group were not considered essential to the development of the Minerals Local Plan and were not contacted again.
"blue group" – this group were considered important to be involved in the development of the plan. This group were added to the Minerals consultation database but given the option to be removed on request.
"pink group" – this group were considered to have a potential interest in the development of the Minerals Local Plan. This group were sent the "Get Involved with Planning" questionnaire again but not automatically added to the Minerals consultation database.
The "blue" and "pink" groups were sent letters or emails on 12th December
20135 which contained the same information as the 11
th November letters and
emails with additional details of why they were receiving the communication.
4 The NFU also sent an email about the consultation to all their members in Worcestershire.
5 In error, the letters send on 12 December were dated 11 November.
57
122 letters and 49 emails were sent to blue group, and 165 letters and 52 emails were sent to the pink group.
4.11. A full list of consultees is set out in Appendix C.
Social Media
4.12. Twitter: 7 social media messages were posted through the County Council Twitter channel over the consultation linking through to dedicated website section. The Council had approximately 9,000 followers at this time.
Methods used
Open days
4.13. Three open days were held near the beginning of the consultation period to give the public a chance to find out more about the second stage consultation, look at the background documents, and ask officers questions. The event was publicised in the consultation leaflet and in all publicity on the consultation in general.
4.14. A number of key pages from the consultation document were produced at
poster scale, and all of the Areas of Search were also printed at a large scale. Background documents, the Sustainability Appraisal and Habitats Regulations Assessment, and large-scale geological maps of the county were also available for the public to peruse during the events. Though we attempted to direct the public to the digital copies of the documents, a number of printed consultation documents, summary documents and paper questionnaires were available for the public to take away.
4.15. Worcester Open Day was held on Saturday 30 November 2013, 10:00 - 15:30, at Worcestershire Countryside Centre. There were 7 attendees. This event deliberately coincided with a well-attended fun run in the park, the Worcestershire Christmas Market (the County Council car park serves as a park and ride for Christmas shopping weekends) and a rugby match, all of which were expected to attract passing interest in the consultation.
4.16. The main interest on this day came from Longdon/Queenhill, with parish councillors and residents from the Longdon, Queenhill and Holdfast Parish expressing concern about an existing application on a site near Holdfast.
4.17. Bromsgrove Open Day was held on Wednesday 4 December 2013, 14:00 - 20:00, in the Spadesbourne Suite at Bromsgrove District Council Office. There were 21 attendees. This event was added to the schedule on the request of the Cabinet Member for Economy, Skills and Infrastructure and deputy leader of the council as there was local interest in the plan. Attendees at this event included Bromsgrove District Council, Gloucestershire County Council, local residents, and representatives from a number of parish councils (Bentley Pauncefoot, Belbroughton, Hagley). The main areas of interest were concerns about landfills in former quarries and potential links with housing proposals.
4.18. Kidderminster Open Day was held on Saturday 7 December 2013, 10:00 - 16:00, at Kidderminster Library. The Open Day was advertised on hoardings
58
outside and inside the Library. There were 3 attendees. All attendees at this event were members of the public.
4.19. The number of attendees in itself does not indicate the success of these open
days as many in-depth conversations were held about detailed aspects of the plan. People were primarily interested in learning about resources and sites in their areas, and some looked at Areas of Search maps in detail. Following specific questions, electronic links and detailed maps were emailed to answer individual queries. A number of attendees took full consultation or summary documents and questionnaires away with them. There were also a lot of general questions asked about the consultation and the minerals local plan.
Workshops
4.20. We proposed to hold two types of workshop during the consultation period:
An industry workshop aimed specifically at operators to get an industry perspective and to focus on technical issues and deliverability.
A green infrastructure workshop aimed at organisations involved in delivering and managing green infrastructure in and around the county to focus on the implementation and deliverability of our restoration aspirations.
4.21. These workshops did not take place as no expressions of interest were received
for either event.
Consultation Documents
4.22. We produced a main consultation document which set out the processes we had undertaken and options we had considered to arrive at the proposed approaches. The consultation document included:
A portrait of Worcestershire giving an overview of the minerals found in Worcestershire and identifying the key issues affecting the county
A draft vision and objectives for what we think the Minerals Local Plan should aim to achieve
A spatial strategy diagram which set out very broadly what type of development the County Council would like where
Details of how much of each mineral we need to provide and when, including alternative methods considered in making this calculation and options for when it should be provided
Ideas about how minerals should be worked, setting out the issues to be considered when developing criteria to manage working practices
Ideas about where minerals should be worked, setting out the issues to be considered when developing location criteria for all mineral workings and identifying 'areas of search' for aggregates and an 'opportunity area' for clay
Our ideas about how mineral workings should be restored, setting out issues to be considered when developing principles for all workings and a proposed approach to identifying key considerations and restoration priorities for each individual 'area of search'
Details of how minerals should be safeguarded for future use including alternative options to consider.
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4.23. The consultation document included 44 questions some of which were technical in nature and others which were more general. The questionnaire could be completed online or returned to our dedicated email address or freepost mailing address.
4.24. As the main consultation document was lengthy (327 pages including Appendices), we also produced a summary document. The summary document was composed of extracts from the main consultation document and gave an overview of the issues the new Minerals Local Plan will address and how we used the comments made on the first consultation on the Minerals Local Plan to develop the approaches proposed.
4.25. The summary document was intended to give a good overview and enough
information to help readers decide which sections they might want to look at in more detail. It set out some of the consultation questions in full, and signposted the reader to the main consultation document where the detailed information was required to answer the questions.
4.26. Both documents were available in a "page turner" version, a downloadable PDF, or in printed form on request. 10 copies of the main document and 6 copies of the summary document were posted out on request. Printed documents were also made available in the county's libraries and at County Hall reception.
4.27. We received 30 questionnaire responses and 36 general responses by letter or email that did not use the questionnaire format for a total of 66 responses. This gives an overall response rate of 8.9%.
4.28. The comments received to the second stage consultation were broadly
constructive and positive. The restoration-led approach was especially lauded by conservation organisations, though the minerals industry expressed some reservations and we anticipate that some refinement of the areas of search and the methodology employed to determine them will be necessary. We received very useful feedback from industry respondents regarding ways in which we may strengthen our approach as we begin to draft policies. Local Authorities within and neighbouring Worcestershire also brought a number of important cross-boundary issues to our attention that will require further work. These include projected housing development and demand for aggregates, crushed rock provision, and sustainable transport. Individuals and parish councils expressed concern about particular sites, and ensuring that Worcestershire's local character is captured and expressed in the draft plan.
4.29. There was general agreement with the "issues that need to be addressed through policy criteria" which were identified in tables 5, 10 and 24. Some respondents identified issues that they would like to see strengthened or added, and these will be addressed as we develop the draft policies. Monitoring was identified as a cross-cutting issue in the responses we received, and we will be looking at how monitoring requirements could be incorporated into the draft policies at the next stage of consultation.
4.30. Below is a brief summary of the key issues that arose in each section of the consultation:
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Portrait of Worcestershire
Respondents broadly agreed with the Portrait of Worcestershire, but in this section and in others, respondents indicated that we could do a better job identifying the things that make Worcestershire unique. Some people recommended that specific sites or locations be included, and we realise that we will need to do a better job conveying Worcestershire's local character in the draft plan.
Vision and objectives
Most responses were in general agreement with the vision and objectives. We received a number of suggestions for amended wording to help clarify our intentions, especially around the historic environment, and some respondents would like to see the objectives become more locally specific.
How much mineral will we make provision for?
Respondents expressed a number of views regarding our proposed approach to meeting our landbank. Some consultees have suggested that we take different approaches to sand and gravel which will have some landbank at the start of the plan period and crushed rock which we currently have no landbank for. We are considering the comments we have received to establish the most appropriate way forward. Cross-boundary issues, crushed rock provision, and protection of AONBs all also figured heavily in responses to this section. There were also concerns expressed about the conversion factor we used to calculate the amount of mineral in resource areas, and about the reliability of information used for one particular resource area. We will undertake further work to refine these estimates and will produce a revised version of the Analysis of Mineral Resources in Worcestershire in due course.
When will minerals be worked and when will our reserves meet national targets?
Consultees clarified that national policy regarding landbanks does not set targets. We acknowledge that this is correct and we mis-used the term "targets", but as we have used this terminology throughout the second stage consultation, we continued to use it in the Consultation Response Document in order to remain consistent with the consultation documents and the questionnaire. We will refine our terminology for the draft plan.
How will minerals be worked?
Proximity of mineral workings to "sensitive receptors" caused some concern, along with the removal of the now-outdated "sieve test" approach. The rationale for the removal of the sieve test is outlined in Appendix 1 of the main consultation document, along with a detailed explanation of changes to the regulatory and national policy context since the adoption of the 1997 Hereford and Worcester Minerals Local Plan. These changes mean that we have had to re-think our approach to
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identifying constraints and establishing "buffer zones" as the policy context is substantially different than it was in 1997.
Where will minerals be worked?
Respondents expressed concerns about the protection of Worcestershire's AONBs and other landscapes, and concern that visual impact has not been addressed satisfactorily in the second stage consultation. There was also concern expressed from industry and the public about how any proposed sites outside of the areas of search will be handled. We will be refining the areas of search based on the comments received during this consultation, and we believe that some of our earlier assumptions will need to be revisited.
Respondents have also specifically asked that we consider Nitrate Protection Zones, agricultural land quality and source protection zones in preparing our draft policies.
How will mineral workings be restored?
Responses to the restoration-led approach were generally positive, and were met with special acclaim from conservation organisations. Industry respondents expressed more reservations, however, and a number of suggestions were received for ways to refine the approach as we develop the draft plan. We are considering several ways to further refine the areas of search and ensure delivery of the restoration priorities which may include spatial masterplanning, concept planning, or 'corridor plans' in order to better convey the restoration-led approach. This approach will be informed by the responses received, and we plan to explore these options further with the members of the Green Infrastructure Partnership working group which has helped inform the development of the Green Infrastructure aspect of the Minerals Local Plan to date. Several respondents suggested that further clarity is needed about how restoration priorities should be balanced or prioritised if more than one issue is identified for a particular area.
How will we safeguard minerals for the future?
There was general agreement with our proposed approach to safeguarding minerals and mineral infrastructure, but we expect that our approach will be further refined as we develop draft policies.
Next steps
We are planning a series of meetings to address respondents' requests and concerns before beginning to draft policies. Cross-boundary issues, including crushed rock provision, sustainable transport, demand forecasting linked to local development plans and potential AONB impacts all require further cooperation with surrounding authorities. A number of respondents have also offered their expertise and access to their data to help us to fill gaps in our knowledge, particularly around the Mercia Mudstone (clay) and building stone resources in the county. We are
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embarking on a phase of further information gathering to ensure our evidence base is as robust as possible, and to ensure we have fulfilled our duty to cooperate as we begin to prepare the draft wording for the next consultation.
Online Quiz
4.31. The interactive quiz which was developed for the first stage consultation remained active on our website during the second stage consultation. The quiz asked 'general knowledge' questions about what minerals are used for, how much is needed to build a house, how far minerals are transported, what activities are going on locally and which local recreation facilities were previously mineral workings, with an invitation to provide their contact details if they would like to be involved in participating in future Minerals Local Plan consultations.
Events with Partners
Worcestershire Green Infrastructure Partnership
4.32. A presentation about the consultation was made at the Worcestershire Green Infrastructure Partnership meeting on 29
th January 2014, highlighting the role of
Green Infrastructure in the emerging Minerals Local Plan. Although the meeting was close to the end of the consultation period, partner organisations were encouraged to make individual responses as soon as possible.
1000 years of building with stone
4.33. An Officer attended a meeting of the Steering Group for the project on 21st
November 2013, explained the Second Stage Consultation and discussed the part the project could contribute to the Plan and how, it, in return could enable demand for building stone to be met.
4.34. On 13th March 2014 an Officer met volunteers for the project, explained the
Minerals Local Plan and the council's support for the 1,000 years project and how the project would be used within it.
4.35. A brief update on the responses to the Second Stage Consultation on the Plan and reference to the continued commitment to encouraging building stone development in the county was reported to a further meeting of the Steering Group on 13th June 2014.
West Midlands Regional Technical Advisory Body for waste (RTAB) 24/01/14
4.36. The Minerals Local Plan and Second Stage Consultation were explained to the RTAB. Relevant Waste Core Strategy policies and the need for "urban quarries" and the free movement of Construction and Demolition waste through the Green Belt were discussed. The need for the Plan to emphasise the value of this waste and to ensure delivery of aggregates from recycled Construction and Demolition waste was stressed. The poor quality of data on this waste stream was agreed.
Worcestershire Planning Officers Group (WPOG) 04/02/2013 and 08/03/2013
4.37. Brief presentations and question and answer sessions about the MLP were made at the WPOG meeting of Development Management Officers on 4
th
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February 2013 and the WPOG meeting of Policy Officers on 8th March 2013;
discussions focussed on restoration considerations and the wider implications of and links between mineral and housing development. .
Consultation on relevant appraisals and assessments
Sustainability Appraisal (SA)
4.38. An Initial Sustainability Appraisal was prepared by the Council and was published for consultation alongside the Minerals Local Plan Second Stage Consultation. This exceeds the six week minimum period which is required for consultation on the Sustainability Appraisal. It was publicised through all direct mail correspondence, the public notices and the minerals pages in the council's website.
4.39. The three statutory consultees for Sustainability Appraisal were also informed specifically. These bodies are Natural England, Environment Agency and English Heritage.
4.40. Comments were received from two of the three statutory consultees: Natural
England and English Heritage. No specific comments were received from the Environment Agency on the SA itself but related issues were referred to in the Agency's response to the Consultation as a whole..
4.41. Natural England were supportive of the initial SA and did not give any detailed
comments for inclusion or further consideration. English Heritage were broadly supportive and highlighted some issues for continued or further inclusion, such as suggesting the inclusion of specific objectives and monitoring indicators for the historic environment within the SA.
4.42. A further response was received from a member of the public, stating that the
consultation was "too complex to comment on properly".
Habitats Regulations Assessment (HRA)
4.43. A Habitats Regulations Assessment Scoping Report was prepared by the Council and was published for consultation alongside the Minerals Local Plan Second Stage Consultation. It was publicised through all direct mail correspondence, the public notices and the minerals pages in the council's website.
4.44. The statutory consultee for Habitats Regulations Assessment was also informed specifically. This body is Natural England.
4.45. Comments were received from Natural England. Natural England was
supportive of the approach taken to the HRA, and gave further information about Natural England's project to make finalised Conservation Objectives for all European sites available online. They suggested that soil compaction should be recognised as an environmental impact which could occur as a result of the extraction of any materials. They advised that requirements for project-stage HRA highlighted in the Scoping Report should be written into the Minerals Local Plan.
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4.46. A further response was received from a member of the public, stating that the consultation was "too complex to comment on properly".
Equality Impact Assessment
4.47. An Equalities Impact Assessment desktop screening was prepared by the Council and was first published for consultation alongside the Minerals Local Plan First Stage Consultation. This was not revised for the Second Stage Consultation but remained available for comment.
4.48. No comments were received.
Consultation on the evidence base
4.49. It is essential that the Minerals Local Plan is based on robust evidence. To
develop this evidence base a suite of background documents will be developed to support and inform the emerging policy framework.
4.50. The background documents which were available for comment alongside the
Second Stage consultation were: What minerals are found in Worcestershire?
Background Document: Analysis of Mineral Resources in Worcestershire – which sets out the methodology for analysing the available information about the mineral resources which are present in the county in order to evaluate the likelihood of them being suitable and commercially attractive for exploitation during the lifetime of the plan.
Background Document: Coal in Worcestershire
Background Document: Salt and Brine in Worcestershire
Background Document: Clay in Worcestershire
Background Document: Building Stone in Worcestershire How much of each mineral do we need to make provision for?
The Local Aggregates Assessment for Worcestershire – June 2013
The Draft Local Aggregates Assessment for Worcestershire – October 2012
Background Document: Ensuring adequate and steady supply of industrial and energy minerals
What are the other local issues?
Background Document: Contributing towards Worcestershire's priorities -which sets out how the minerals local plan could contribute towards the Council's corporate priorities and the priorities of the Sustainable Community Strategy.
Background Document: Minerals and Climate Change – which considers the contribution that the Minerals Local Plan could play to reducing Worcestershire’s climate change emissions and planning for and adapting to climate change.
Background Document: The Malvern Hills Acts - which sets out the unique legislative framework regarding mineral working in the Malvern Hills.
Profile documents for Environmental Character Areas – these detail the mineral and environmental context in the Environmental Character Areas
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which form the basis for the Worcestershire Green Infrastructure Framework. There are 30 Environmental Character Areas.
4.51. No comments were received on any of the background documents specifically,
although some responses to the main consultation referred to the Local Aggregates Assessment and the Analysis of Mineral Resources.
4.52. The background documents will be reviewed as necessary and further background documents will be produced during the development of the Minerals Local Plan.
Summary of activities under the duty to cooperate
4.53. A more detailed summary of the discussions held with each of the bodies we
have a duty to cooperate with is set out in the Annual Monitoring Report.
4.54. Following the close of the First Stage Consultation in January 2013, the following activities have been undertaken:
Body Method of engagement Outcomes
Worcestershire Local Authorities
Herefordshire and Worcestershire Planning Policy Officers Group Presentation and discussion on 8
th March 2013.
Awareness raised, broad issues of mutual interest identified, particularly with regard to the contribution mineral workings could make to recreation sites being proposed in district wide Local Plans. Informal links established.
Herefordshire and Worcestershire Development Management Officers Group Presentation and discussion on 4
th February 2013.
Awareness raised and broad issues of mutual interest raised, particularly with regard to liaison procedures over possible future mineral and housing development sites. Informal links established.
Bromsgrove District Council: Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation. Officers attended the open day held in Bromsgrove and subsequently asked for clarification of whether there were any minerals issues for any of the proposed development sites. WCC officers compared each site with known mineral resources and provided a commentary on each of the proposed development
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sites (10th December 2013). This
identified one site which would require further assessment and advised on what the assessment should address.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Redditch Borough Council: Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
Response received noting that there are no commercial or cruising waterways within Redditch Borough's boundary.
Wyre Forest District Council: Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation, supporting the restoration-led approach and close links with Green Infrastructure, and highlighting the District Council's Green Infrastructure Study and Strategy as an information source. WFDC supported the vision, objectives and strategic restoration priorities. It supported the approach to identifying areas of search and safeguarding minerals.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
South Worcestershire Authorities: Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. South Worcestershire made many comments, broadly focused on:
The need for policy criteria
Adequate and steady supply of minerals, impact of housing numbers on demand, phasing of
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working and delivery milestones, concern at lower target after 2016
Preference for identifying specific sites or preferred areas
Appropriateness of protecting and enhancing Worcestershire's key economic sectors
Need for references to sustainable transport and community engagement in the vision
Maximising use of secondary and recycled materials, acknowledging imports and exports and comprehensive working of permitted reserves
The need for high environmental standards throughout site life
Transport, traffic impacts and the use of sustainable modes of transport
Methodology for identifying areas of search,
Desire to input into restoration priorities and profiles
Implications of mineral overlap with South Worcestershire site allocations for housing or employment land
Potential impact on Malvern Hills, AONBs, Abberley Hills, Green Belt, landscape character
Appropriateness of "restoration-led" approach
Need for more information on safeguarding resources and infrastructure assets.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
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Surrounding Minerals Planning Authorities
Shropshire: Meeting held 11
th March 2013
– discussed proposed approaches by both counties to plan making, green infrastructure and environmental networks, Local Aggregates Assessments, building stone and waste.
No issues of conflict identified. Agreed to continue discussions as approaches develop, but no areas of concern or conflict at present. Agreed both counties are proposing appropriate levels of production. The only significant possible issue of cross-border supply is that Shropshire's high-quality roadstone may be supplying part of Worcestershire's need but this reflects normal workings of the market due to the special nature of the material.
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Herefordshire: April/May 2013 – Email discussion regarding the two counties' crushed-rock sales data which have been merged for many years, making it difficult to establish an average of past 10 years sales in the Local Aggregates Assessment.
Discussion regarding the methodology led to agreement to maintain the RAWP "apportionment" to 2016, followed by average of past 10-years sales on the assumption that 2/3 of crushed rock has been produced by Herefordshire and 1/3 by Worcestershire.
June 2013 – email exchange regarding mineral development in the Malvern Hills and Herefordshire's Core Strategy policies M3 and M4.
Discussion of wording and sharing data regarding the legislative context of the Malvern Hills led to minor amendments to policy wording and agreement that no conflict is anticipated between the emerging Worcestershire Minerals Local Plan and Herefordshire's emerging Core Strategy over mineral development in the Malvern Hills or the emerging plans and minerals issues generally.
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17th July 2013 – meeting with
an update on the status of Minerals Planning Policy preparation in both counties, status and principles of Local Aggregate Assessments, discussion of any complementary or conflicting issues or matters of concern, data availability and sharing.
Agreed that there are no conflicts or matters of concern between the councils' timetables or approaches, and that both counties would proceed on the basis of supplying the WMRAWP sub-regional apportionment up to 2016 followed by average of past 10-years sales. Agreed that WCC intends to plan for supplying its share of both sand and gravel and crushed rock, but reliant on industry to make applications. WCC does not seek to rely on other counties contributions to meet its LAA requirements, but if the market were to look to quarries in Herefordshire to meet some of this need, Herefordshire Council agrees that its landbanks and productive capacity are capable of supplying some of those needs without difficulty and it would not object to this. Agreed that WMRAWP's AMR is the best source of data. For crushed rock, agreed to maintain the principle that 2/3 crushed rock production from Herefordshire and 1/3 from Worcestershire as a realistic way to aim for future supply. In the long term, 10 years supply average will become meaningful and usable. Agreed that there were no conflicts between the 2 counties' approaches to the LAA. Agreed that future meetings would be useful to ensure compatibility between approaches and the use of data.
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Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Warwickshire: Contacted by direct mail regarding Second Stage Consultation. Informal discussions between officers about the content and progress of both counties' Plans were held at the WMRTAB meetings.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
Gloucestershire: February 2013 – email exchange confirming sites in Worcestershire to appear in maps in Gloucestershire's Minerals Local Plan.
WCC confirmed the sites shown were correct and that there were no longer any operational quarries producing crushed rock or building stone in Worcestershire.
17th June 2013 – see "Joint
meeting" section below.
See below
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Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. Gloucestershire suggested that preferred areas or specific sites may be required to provide certainty to both industry and communities, demonstrate deliverability and avoid putting pressure on neighbouring authorities. Gloucestershire highlighted that potential development near to the county boundary could have cross-boundary implications which need to be considered at the next stage of plan preparation.
Informally consulted on Water Transport Paper, Winter 2014.
Gloucestershire replied stating that they had no specific comments, but referred us to their Transport Evidence Paper background document.
Staffordshire: Contacted by direct mail regarding Second Stage Consultation. Informal discussions between officers about the content and progress of both counties' Plans were held at the POS Mineral and Waste Learning Project Meetings and WMRTAB meetings.
No response received to Second Stage Consultation.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
West Midlands conurbation "county" as Mineral Planning Authorities: Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation from any of the West Midlands Unitary Authorities.
Informally consulted on Water No response received.
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Transport Paper, Winter 2014.
Joint meeting: 17
th June 2013 – Hosted by
Worcestershire County Council and attended by:
Gloucestershire County Council (and South West RAWP representative),
Warwickshire County Council, and
Herefordshire Council Discussion of: status of MLP in each county (mineral types, timetable, broad principles, matters of mutual interest); status of Local Aggregate Assessment preparation and principles; any complementary or conflicting issues, matters of concern, and cross boundary initiatives; data sharing; working together effectively.
General discussion of these issues did not result in any specific actions. Agreed that ongoing dialogue is necessary.
West Midlands Resource Technical Advisory Body: A brief presentation was given to and discussion held with the WMRTAB meeting on 24
th January 2014.
Informal confirmation and re-assertion of RTAB support for earlier regional policy stance that C and D recycling made an important contribution to aggregate supply and that such facilities were appropriate in both urban and Green Belt locations.
West Midlands Aggregate Working Party: 18
th October 2013 - Meeting
of "West Midlands" Planning Authority officer representatives at Birmingham City Council Offices. Confirmed role of AWP in giving advice on Local Aggregate Assessment (LAA) production, compliance with guidelines and 'fair share of burdens'. Also discussed potential for establishing
Noted WCC's close working relationship with Herefordshire but separate LAAs produced. Noted that Worcestershire's LAA has gone to Cabinet. Other LAAs in the region may be produced jointly (i.e. Shropshire with Telford & Wrekin, Staffordshire with Stoke on Trent, West Midlands unitary authorities)
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non-aggregate minerals group.
Other Aggregate Working Parties: The following Aggregate Working Parties were contacted by direct mail regarding Second Stage Consultation:
East Midlands AWP
East of England AWP
Greater London Authority AWP
London AWP
North East AWP
North Wales AWP
North West AWP
South East AWP
South Wales AWP
South West AWP
Yorkshire and Humber AWP
Response to Second Stage Consultation received from East of England AWP. Notwithstanding any comments that individual members of the AWP may make on the Plan, the EEAWP does not believe that the content of this Plan will have any significant impact on the AWP area. No response received to Second Stage Consultation from other AWPs.
Other authorities Surrounding Authorities: All surrounding Local Planning Authorities were contacted by direct mail regarding Second Stage Consultation.
Response to Second Stage Consultation received from Tewkesbury Borough Council. Their comments focused on cross-boundary impacts from mineral working, such as flooding and surface water management, landscape impact, biodiversity and transport, and the need to make appropriate provision throughout the plan period to prevent undue pressure on surrounding authorities. They also highlighted potential demand from development in Gloucestershire. No response received to Second Stage Consultation from other surrounding Local Planning Authorities.
All surrounding Local Planning Authorities were
No responses received.
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informally consulted on the Water Transport Paper in Winter 2014.
The Planning Officers Society Mineral and Waste Learning Project (4 meetings p.a.): The content and progress of members' Mineral Plans is formally discussed at every meeting.
Bedfordshire Authorities (Central Bedfordshire, Bedford & Luton Boroughs),
Bradford, Derbyshire/Derby,
East Sussex/Brighton & Hove,
Essex,
Hampshire,
Hertfordshire,
Lincolnshire,
Northamptonshire,
Nottinghamshire, Oxfordshire,
Staffordshire,
Surrey,
West Berkshire,
West Sussex/South Downs NPA
Potential matters of mutual interest and concern are discussed at every meeting.
The Environment Agency
Member of the Minerals Green Infrastructure Steering Group (see below)
See below.
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. The Environment Agency supported the draft spatial portrait, suggesting greater reference to the Water Framework Directive and Flood Risk betterment, and supported the vision as being progressive and positively worded. They also supported the draft objectives, but suggested that explicit reference to 'Flood Risk' and 'betterment opportunities' would highlight
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their importance. Similarly, they supported the proposed policy issues, suggesting that future policy wording should commit to 'betterment opportunities'. They also highlighted that the 'sequential test' would need consideration and guidance in emerging policy, but that a balance will be needed between locating workings in low flood risk areas and providing opportunities for meaningful flood alleviation. They supported the progressive approach to assigning restoration priorities to areas of search, but suggested flexibility would be needed to take account of site-level conditions which may not align with strategic priorities.
Informally consulted on Water Transport Paper, Winter 2014.
No response received.
English Heritage Member of the Minerals Green Infrastructure Steering Group (see below)
See below.
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. English Heritage welcomed references to background data. They noted that traditional building and roofing stone is fundamental to maintaining built heritage. They welcomed references to the historic environment throughout and particularly the specific objective, but suggested that a reference could be included within the vision. They highlighted that clarity will be needed to show how appropriate areas/sites have been identified ensuring the protection, conservation and enhancement of the historic environment. They welcomed the opportunity to work with us to ensure a positive legacy for
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the historic environment as a result of minerals development and restoration, and encouraged consideration of the historic environment as an overarching restoration principle. They also commented fully on the Sustainability Appraisal.
Informally consulted on Water Transport Paper, Winter 2014.
No response received
Natural England Member of the Minerals Green Infrastructure Steering Group (see below)
See below.
Contacted by direct mail regarding Second Stage Consultation.
Response received to Second Stage Consultation. Natural England supported the section on the Environment in the Portrait of Worcestershire, particularly the inclusion of green infrastructure, and welcomed the environmental aspects of the draft vision and draft Objective 6. Natural England particularly supported the inclusion of policy criteria on the natural and historic environment, but suggested that Green Infrastructure and soils could also be included. They fully supported the GI-led approach to restoration. They also commented fully on the Sustainability Appraisal and Habitats Regulations Assessment.
Informally consulted on Water Transport Paper, Winter 2014.
Natural England responded to say that "As a general principle the use of any waterways for transporting minerals should ensure protection and enhancement of the environment".
The Mayor of London
Did not respond to the "Get involved in Planning" leaflet. No issues have been identified which require
N/A
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co-operation with the Mayor of London, therefore not consulted by direct mail regarding Second Stage Consultation.
Civil Aviation Authority
Contacted by direct mail regarding Second Stage Consultation.
Responded to Second Stage Consultation setting out CAA's areas of interest. No issues of conflict identified.
The Homes and Communities Agency
No issues have been identified which require co-operation with the Homes and Communities Agency. However, added to "blue group" and contacted by direct mail for Second Stage Consultation.
No response received to Second Stage Consultation.
Clinical Commissioning Groups (CCGs)
The Primary Care Trusts have been disbanded and new Clinical Commissioning Groups set up. These are:
South Worcestershire CCG
Redditch and Bromsgrove CCG
Wyre Forest CCG
New single point of contact established to act as conduit for all liaison over health matters.
National Health Service Commissioning Board
See above See above
Office of Rail Regulation
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Transport for London No issues have been identified which require co-operation with Transport for London. Not consulted.
N/A
Integrated Transport Authority: Centro
Added to "blue group" for Second Stage Consultation and contacted by direct mail.
No response received to Second Stage Consultation.
Highways Agency Contacted by direct mail regarding Second Stage Consultation.
Responded to Second Stage Consultation highlighting the Highways Agency's responsibilities in Worcestershire, requesting to be consulted as policies are developed to ensure adequate consideration is given to impacts on the Strategic Road Network.
WCC Highway Authority
WCC Highways were not sent the Second Stage Consultation in error.
No response received at time of publication.
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Subsequent discussion led to an individual contact being identified and the consultation material was forwarded on 12
th June 2014 for comment.
Informally consulted on the Water Transport Paper in Winter 2014.
No response received.
The Marine Management Organisation
No issues identified which require co-operation with the Marine Management Organisation. Following the "Get Involved in Planning" questionnaire, the Marine Management Organisation (MMO) requested not to be consulted, stating that "the remit of the MMO’s work reaches up to the mean high water springs mark along the coast and within any stretches of tidal river. Our maps indicate that there are no rivers within Worcestershire that are under tidal influence and as such this area is outside of the MMO’s remit. We therefore do not feel it necessary to be consulted on any of the areas covered by the questionnaire." On 12
th December 2013 we
wrote again to the MMO, highlighting the Duty to Cooperate and setting out that although we do not anticipate the plan affecting marine and tidal issues, there may be areas of interest for the MMO such as imports from marine dredged sand and gravel or aspects of our Habitats Regulations Assessment.
Response received to consultation, recommending reference to marine aggregates be included within the Plan and highlighting information sources.
Worcestershire Local Enterprise Partnership
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
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Informally consulted on the Water Transport Paper in Winter 2014.
No response received.
Greater Birmingham and Solihull Local Enterprise Partnership
Contacted by direct mail regarding Second Stage Consultation.
No response received to Second Stage Consultation.
Informally consulted on the Water Transport Paper in Winter 2014.
No response received.
Worcestershire Local Nature Partnership
The Worcestershire Partnership was remodelled into a wider range of groups during this time. One of the most relevant to the MLP is the newly formed Local Nature Partnership. Contacted via LNP secretary (listed as one of the Worcestershire County Council contacts in Appendix C) regarding Second Stage Consultation.
No response received to Second Stage Consultation from LNP itself, although many of its members are represented in the Minerals Green Infrastructure Steering Group (see below).
Minerals Green Infrastructure Steering Group
4.55. A steering group was established to assist with embedding the Green
Infrastructure approach in the Minerals Local Plan. The group consists of:
English Heritage
Environment Agency
Forestry Commission
Natural England
Nature After Minerals/RSPB
Worcestershire Wildlife Trust
Worcestershire County Council: o Strategic Planning & Environmental Policy o Ecology o Landscape o Development Management o Water/flooding o Countryside Access & Recreation o Historic Environment
Not all participants have been able to attend all meetings, but all have been included on email circulations with agendas, minutes and draft documents for comment.
4.56. A number of meetings were held between the First Stage and Second Stage
consultations to develop the Green Infrastructure approach:
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Meeting of 30th January 2013:
Exploratory meeting to discuss the pros, cons and practicalities of using GI principles and restoration potential to drive the development of the Minerals Local Plan. The group supported taking an innovative GI approach to minerals.
Meeting of 10th April 2013:
Group members had contributed information to inform "Environmental Character Area Profiles". Officers had also been developing Areas of Search, and were using the issues and priorities from the Environmental Character Area profiles to establish the strategic priorities for each Area of Search.
Two mock-examples were presented to the group to critique. An early draft of the vision and objectives was given to the group alongside a table setting out considerations under each objective showing which were likely to be addressed through policy criteria and which might be strategic priorities for areas of search. These were then looked at as a "primary", "secondary" or "tertiary" priorities (working terms) for each of the areas. The group helped make amendments to the strategic priority groupings and suggested ways in which priority levels could be established.
The group agreed that a habitat approach would be better than a species approach, and that landscape changes need to either be consistent with existing landscape character or be wholly different, not piece-meal degradation.
Officers were to commence work on developing the areas of search and profiles. The group asked to be sent drafts and to meet to discuss and refine them in batches, preferably covering diverse areas of search in the first batch to try and iron out most of the major issues up front.
Meeting of 28th May 2013 and 11th June 2013:
A method statement setting out how strategic priorities, secondary priorities and tertiary priorities had been derived and a method for applying these to the Areas of Search were provided for group discussion:
o Each aspect was discussed and the group made suggestions for refining the methods or the data used.
Draft examples of Area of Search profiles were provided for group discussion:
o The group agreed that the level of detail was appropriate. o The group discussed the interplay of the priorities, whether it was
appropriate if the method resulted in some areas having lots of primary priorities, whether there was potential for conflict between priorities, whether minerals sites could deliver the priorities, and the need to bring out important issues in each Area of Search.
o Further discussion looking at the examples raised points which needed to be refined in the method or data used, as well as individual points of interest for individual areas of search.
The group agreed that a sub-group would meet to discuss landscape and heritage issues and methodology and report back.
The group agreed that minerals officers would liaise with water interests to finalise methodology for water aspects.
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The group agreed that WCC's Environmental Policy team would consider the biodiversity aspect to finalise the methodology.
The group agreed that WCC Minerals officers would pick up on the advice from these subgroups and consult the whole group on final methodology and worked examples through email and file sharing.
Discussion with Minerals Industry
Cemex and Tarmac
4.57. A meeting was held on 16th July 2013 with representatives from Cemex and
Tarmac. This gave a brief introduction to the Minerals Local Plan, the minerals covered, timetable and next consultation stage, and broad principles.
4.58. Discussions looked at:
the nature of and any likely changes to the minerals industry which could affect Worcestershire;
the nature of and likely changes at mineral site level, such as minimum size of workings, new production methods, plant, campaign working and water transport;
what Worcestershire-specific issues should be addressed in the Minerals Local Plan;
what other issues should be taken into account from other Mineral Planning Authorities;
issues which should be addressed regarding sand and gravel, crushed rock and other minerals;
any complementary or conflicting issues, matters of concern and cross boundary issues to be aware of;
data availability and sharing;
ways to work together effectively and appropriately; and
competition commission investigations.
4.59. Outcomes and actions included agreement to discuss:
possible pre-application proposals with the Development Management section and operator's agents in parallel with the Plan process,
The proposed emphasis on a restoration led approach further, if necessary, following the next consultation,
specific matters raised by individual companies individually if requested,
matters of concern to minerals operators as a group at a specific seminar.
Tarmac
4.60. A meeting was held on 7th February 2014 between Worcestershire County
Council's Minerals and Waste Policy team, Development Management team and PleydellSmithyman Ltd (representing Tarmac). This meeting looked at the relationship between the emerging Minerals Local Plan and future site development at Clifton Gravel Pit.
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4.61. Discussions looked at:
Tarmac's existing operations in Worcestershire, likely lifetime left at those sites and plans for future extraction;
Site investigations already undertaken and likely to be required;
Ground water, particularly relating to a nearby SSSI and private water supplies;
Access arrangements, amenity and restoration issues;
Potential for restoration of the Clifton site for recreation purposes;
Likely timescale of an application in relation to submission or adoption of the Minerals Local Plan.
Salop Sand and Gravel
4.62. A meeting was arranged with Salop Sand and Gravel including a site visit at Chadwich Lane Pit for 18
th September 2013. The agenda for this meeting was
the same as for the meeting with Cemex and Tarmac.
4.63. Worcestershire County Council officers attended the meeting, but representatives from Salop Sand and Gravel did not arrive and the meeting was not held.
4.64. A meeting was held at Worcestershire County Council's offices on 7
th February
2014 between Worcestershire County Council's Minerals and Waste Policy team, Development Management team, Mr Parton of Salop Sand and Gravel and PleydellSmithyman Ltd (Salop Sand and Gravel's agent). This meeting looked at the relationship between Mr Parton's operations and potential future plans, the requirement for restoration plans and restrictions to infilling as a restoration option in the future.
Coal Authority and CoalPro
4.65. A meeting was held on 13th August 2013 with representatives from the Coal
Authority and CoalPro. This gave a brief introduction to the Minerals Local Plan, the minerals covered, timetable and next consultation stage, and broad principles.
4.66. Discussions looked at:
the nature of and any likely changes to the minerals industry which could affect Worcestershire;
the nature of and likely changes at mineral site level, such as minimum size of workings, new production methods, plant, campaign working and water transport;
what Worcestershire-specific issues should be addressed in the Minerals Local Plan;
what other issues should be taken into account from other Mineral Planning Authorities;
issues which should be addressed regarding coal;
issues which should be addressed regarding other minerals associated with coal;
any complementary or conflicting issues, matters of concern and cross boundary issues to be aware of;
data availability;
ways to work together effectively and appropriately; and
83
competition commission investigations.
4.67. Outcomes and actions included:
Only surface working of coal is conceivable in Worcestershire at present. Alternative hydrocarbon extraction techniques are theoretically possible but likely to be unviable;
Although some coal strata are geologically present, at best the deposits are very thin, in practice all commercial surface deposits may have already been worked out, meaning that there is no coal resource for future extraction in the county;
Coal hazards however are important and have been mapped in Worcestershire. The areas affected should be "safeguarded" to ensure that the ground conditions can be assessed and any remedial action undertaken before other development is permitted;
Policies should be included to enable coal and related minerals to be developed if applications come forward, subject to the provisos in the NPPF.
84
Appendix A: A summary of the legislative and regulatory requirements
The Minerals Local Plan (MLP) for Worcestershire is a statutory Development Plan Document (“DPD”) within the meaning of the Town and Country Planning (Local Plan) (England) Regulations 2012 (“the Regulations”). Before the Council can adopt the Minerals Local Plan it has to be submitted it to the Secretary of State for independent examination.
Duty to co-operate in relation to planning of sustainable development: The Planning and Compulsory Purchase Act 2004 (local development) (as amended by the Localism Act 2012) 33A and The Town and Country Planning (Local Planning) (England) Regulations 2012 Part 2 require local planning authorities to cooperate with the following bodies in the preparation of development plan documents, other local development documents and any activities that relate to strategic matters and support the preparation of these development documents:
Local Planning Authorities,
The Environment Agency,
English Heritage,
Natural England,
The Mayor of London,
Civil Aviation Authority,
The Homes and Communities Agency,
Each Primary Care Trust,
Office of Rail Regulation,
Transport for London,
Each Integrated Transport Authority, in the case of the West Midlands this is Centro,
Each Highway Authority
The Marine Management Organisation
Local Enterprise Partnerships The duty to co-operate requires constructive and active engagement on an ongoing basis. In doing this the local planning authority must also have regard to the development plan documents, other local development documents and marine plans of these organisations, as well as any activities that relate to strategic matters
6 and
support the preparation of these development documents. Co-operation may include considering the preparation of agreement on joint approaches or preparing joint local development documents. Preparation of the Minerals Local Plan Regulation 18 The Town and County Planning (Local Planning) (England) Regulations 2012 requires the Council to notify the following groups that it proposes to prepare a Minerals Local Plan and invite then to make representations on what it ought to contain:
6 A 'Strategic Matter' is a sustainable development or use of land that has or would have a significant
impact on at least two planning areas. This includes infrastructure and 'county matters' such as minerals and waste development (defined in the Town and Country Planning Act 1990).
85
Specific consultation bodies which the Council considers may be interested. These are the Coal Authority, the Environment Agency, English Heritage, the Marine Management Organisation, Natural England, Network Rail Infrastructure Limited, the Highways Agency, relevant authorities that are in or adjoining Worcestershire, Primary Care Trusts, Homes and Communities Agency, sewerage undertakers, water undertakers and any persons licensed under the electricity act, gas act or to whom the electronic communications code applies.
General consultation bodies which the Council considers appropriate. These include voluntary bodies and bodies which represent the interests of different racial, ethnic, national or religious groups, disabled persons or persons carrying on business in the area.
Residents or others carrying out business in Worcestershire which the Council considers appropriate.
Submission of documents and information to the Secretary of State Section 20(3) of the Planning and Compulsory Purchase Act 2004 and Regulation 22(1)c of The Town and County Planning (Local Planning) (England) Regulations 2012 require a statement setting out the following to be submitted to the Secretary of State alongside the Minerals Local Plan:
Which bodies and persons the LPA invited to make representations under regulation 18 (see above)
How they were invited to make representations
A summary of the main issues raised
How these issues were taken into account It also requires the council to identify the number of representations made on the local plan which the Council proposes to submit to the Secretary of State and to provide a summary of the main issues raised.
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Appendix B: Direct mail/e-mail distribution list: first stage consultation
Specific Consultees
Abberley Parish Council
Abberton Parish Meeting
Abbots Morton Parish Council
Acton Beauchamp Group Parish Council
Alcester Town Council
Alfrick & Lulsley Parish Council
Alvechurch Parish Council
Alveley & Romsley Parish Council
Arrow with Weethley Parish Council
Ashton-under-Hill Parish Council
Astley & Dunley Parish Council
Badsey & Aldington Parish Council
Barnt Green Parish Council (3)
Bayton Parish Council (2)
Beckford Parish Council
Belbroughton Parish Council (2)
Bentley Pauncefoot Parish Council
Beoley Parish Council
Berrow Parish Council
Bewdley Town Council
Bickmarsh Parish Council
Bidford on Avon Parish Council
Birlingham Parish Council
Birmingham City Council
Birtsmorton Parish Council
Bishampton & Throckmorton Parish Council
Blaby District Council
Boraston Parish Meeting
Bournheath Parish Council (2)
Brecon Beacons National Park Authority
Bredicott Parish Meeting
Bredon & Bredon's Norton Parish Council
Bretforton Parish Council
Broadheath Parish Council
Broadwas & Cotheridge Parish Council
Broadway Parish Council
Bromsgrove District Council (3)
Bromsgrove District Council & Redditch Borough Council
Broome Parish Council
Broughton Hackett Parish Meeting
Bushley Parish Council
Cannock Chase Council
Castlemorton Parish Council
Catshill and North Marlbrook Parish Council (2)
Chaceley Parish Council
Chaddesley Corbett Parish Council
Charlton Parish Council
Cheltenham Borough Council
Cherwell District Council
Childswickham Parish Council
Chipping Campden Town Council
Church Lench Parish Council
Churchill & Blakedown Parish Council
Churchill Parish Council
Cleeve Prior Parish Council
Clent Parish Council
Clifton-on-Teme Parish Council
Coal Authority
Cofton Hackett Parish Council
Cookhill Parish Council
Cotswolds District Council (3)
Coventry City Council
Cropthorne Parish Council
Crowle Parish Council
Daventry District Council
Defford & Besford Parish Council
Derbyshire County Council
Dodderhill Parish Council
Dodford with Grafton Parish Council
Dorsington Parish Council
Drakes Broughton & Wadborough with Pirton Parish Council
Droitwich Spa Town Council
Dudley MBC
Dumbleton Parish Council
Earls Croome Parish Council
East Staffordshire Borough Council
Eastham Parish Council
Eckington Parish Council
Eldersfield Parish Council
Elmbridge Parish Council
Elmley Castle Parish Council
Elmley Castle, Bricklehampton & Netherton Parish Council
Elmley Lovett Parish Council
English Heritage
Environment Agency (2)
Essex County Council
Evesham Town Council
Far Forest Parish Council
Feckenham Parish Council
Fladbury Parish Council
Flyford Flavell Grafton Flyford North Piddle Parish Council
Forest of Dean District Council
Frankley Parish Council
Gloucester City Council
Gloucestershire County Council (2)
Great Comberton Parish Council
Great Witley & Hill Hampton Parish Council
Grimley Parish Council
Guarlford Parish Council
Hagley Parish Council
Hallow Parish Council
Hampton Lovett & Westwood Parish Council
Hanbury Parish Council
Hanley Castle Parish Council (2)
Hanley Parish Council
Harborough District Council
Hartlebury Parish Council
87
Harvington Parish Council
Hatfield & District Group Parish Council
Heaton Planning
Herefordshire Council
Highways Agency
Hill and Moor Parish Council
Hill Croome Parish Council
Hinckley & Bosworth Borough Council
Hindlip, Martin Hussingtree and Salwarpe Parish Council
Hinton-on-the Green & Somerville Parish Council
Holt Parish Council
Honeybourne Parish Council
Hunnington Parish Council
Inkberrow Parish Council
Kemerton Parish Council (2)
Kempsey Parish Council
Kenswick & Wichenford Parish Council
Kidderminster Foreign Parish Council
Kington & Dormston Parish Council
Knighton-on-Teme Parish Council
Knightwick & Doddenham Parish Council
Leicester City Council
Leicestershire County Council
Leigh and Bransford Parish Council
Lichfield District Council
Lickey and Blackwell Parish Council
Lindridge Parish Council
Little Comberton Parish Council
Little Malvern & Welland Parish Council (2)
Little Witley Parish Council
Longdon Queenhill and Holdfast Parish Council
Lower Broadheath Parish Council
Lower Sapey Parish Meeting
Madresfield Parish Council
Malvern Hills District Council (5)
Malvern Town Council
Malvern Wells Parish Council
Mamble Parish Council
Marston Sicca (Long Marston) Parish Council
Martley Parish Council
Mathon Parish Council
Milson and Neen Sollars Parish Council
Monmouthshire County Council
Natural England (2)
Naunton Beauchamp Parish Council
Network Rail (1)
Network Rail Commercial Property
Newland Parish Council
North and Middle Littleton Parish Council
North Claines Parish Council
North Warwickshire Borough Council
North West Leicestershire District Council
Northamptonshire County Council
Northway Parish Council
Norton and Lenchwick Parish Council
Norton-Juxta-Kempsey Parish Council
Nuneaton and Bedworth Borough Council
Oadby and Wigston Borough Council
Offenham Parish Council
Office of Rail Regulation
Ombersley & Doverdale Parish Council
Overbury & Conderton Parish Council
Oxford City Council
Oxfordshire County Council
Pebworth Parish Council
Pendock Parish Council
Pensax Parish Council
Peopleton Parish Council
Pershore Town Council
Pinvin Parish Council (3)
Powick Parish Council
Powys County Council
Redditch Borough Council (3)
Redmarley D'Abitot Parish Council
Ripple Parish Council
Rochford Parish Council
Rock Parish Council
Romsley Parish Council
Rous Lench Parish Council (2)
Rugby Borough Council
Rushock Parish Council
Rushwick Parish Council
Saleway Group (Himbleton, Hadzor, Oddingly, Huddington)
Salford Priors Parish Council
Sandwell MBC
Sedgeberrow Parish Council
Severn Stoke & Croome d'Abitot Parish Council
Severn Stoke and Croome d'Abitot Parish Council
Severn Trent Water Ltd (3)
Shrawley Parish Council
Shropshire Council
Snowshill Parish Meeting
Solihull MBC
South Derbyshire District Council
South Littleton Parish Council
South Northamptonshire Council
South Oxfordshire District Council
South Staffordshire Council
Spetchley Parish Council
St Peter's the Great County Parish Council
Stafford Borough Council
Staffordshire County Council (2)
Stanford with Orleton Parish Meeting
Stock and Bradley Green Parish Council
Stockton Parish Meeting
Stockton-on-Teme Parish Meeting
Stoke Bliss, Kyre and Bockleton Parish Council
Stoke on Trent City Council
Stoke Prior Parish Council
Stone Parish Council
Stoulton Parish Council
Stourport-on-Severn Town Council
Stratford-on-Avon District Council
Strensham Parish Council
Stroud District Council
Suckley Parish Council
Suffolk County Council
88
Swindon Borough Council
Tamworth Borough Council
Tanworth-in-Arden Parish Council
Telford and Wrekin Council
Tenbury Town Council
Tewkesbury Borough Council
The Coal Authority
The Shelsleys Parish Council (2)
Tibberton Parish Council
Tutnall & Cobley Parish Council
Twyning Parish Council
Upper Arley Parish Council
Upton on Severn Town Council
Upton Snodsbury Parish Council
Upton Warren Parish Council
Vale of White Horse District Council
Walsall Council
Walsall MBC
Warndon Parish Council (2)
Warwick District Council
Warwickshire County Council (3)
West Malvern Parish Council
West Oxfordshire District Council
White Ladies Aston Parish Meeting
Whittington Parish Council
Wick Parish Council
Wickhamford Parish Council
Wiltshire Council
Wolverhampton City Council
Wolverley & Cookley Parish Council
Worcester City Council
Worcestershire County Council (26)
Worcestershire Regulatory Services (2)
Wychavon District Council (1)
Wyre Forest District Council (4)
Wyre Piddle Parish Council
Wythall Parish Council
General Consultees
Abberley & Malvern Hills Geopark
Avon Navigation Trust
Avoncroft Museum
Beckford Nature Reserve
Belbroughton History Society
British Aggregates Association
British Ceramic Confederation
British Horse Society
British Ready-mixed Concrete Association
Bromsgrove Society
Canal and River Trust
Charter Trustees of Kidderminster
Civil Aviation Authority
Communities First Herefordshire and Worcestershire
Confederation of British Industry
Confederation of UK Coal Producers (2)
Cotswold Drainage Ltd
Cotswolds Conservation Board
Country Land and Business
CPRE (Worcestershire) (2)
Department for Communities and Local Government
Diocesan of Worcester (2)
Droitwich History & Archaeology Society (2)
Duckworth Worcestershire Trust
East Midlands Aggregates Working Party
East of England Aggregates Working Party
Friends of the Earth (Redditch)
Greater Solihull and Birmingham Local Economic Partnership
Herefordshire & Worcestershire Earth Heritage Trust
Herefordshire and Worcestershire Chamber of Commerce
Kidderminster Charter Trustees
Lickey Hills Society (2)
London Aggregates Working Party
Malvern Civic Society
Malvern Hills AONB Partnership
Malvern Hills Conservators
Mineral Products Association
Mr Peter Luff MP
Mrs Nicole Sinclair MEP
National Planning Casework Unit
National Trust
Nature After Minerals
NFU West Midlands
North East Aggregates Working Party (2)
North Wales Aggregates Working Party
North West Aggregates Working Party
Older People's Forum in Evesham
Older People's Forum in Pershore
Older People's Forum in Redditch
Pershore Civic Society
Ramblers Association
Robin Walker MP
Romsley & Hunnington History Society
RSPB (Midlands Region)
Severn Rivers Trust
South East of England Aggregates Working Party
South Wales Aggregates Working Party
South Wales Aggregates Working Party
South West Aggregates Working Party
South Worcestershire Archaeological Group
South Worcestershire Land Drainage Partnership
Sport England
The Inland Waterways Association
The Mining Association of the UK
The Stone Federation of Great Britain
The Woodland Trust
Vale of Evesham Civic Society
West Mercia Police (3)
West Midlands Aggregates Working Party
West Midlands Conservative MEP Team
West Midlands Regional Aggregate Working Party
Worcester Wychavon Rotary Club
Worcestershire County Association of Local Councils
89
Worcestershire Historical Society
Worcestershire Local Nature Partnership
Worcestershire Wildlife Trust (2)
Worcestershire Local Economic Partnership
Yorkshire and the Humber Aggregates Working Party
Other interested parties
Accurate Cutting Services Ltd.
AMEC
Asda Stores Limited (2)
Atkins Global
Barton Willmore Partnership
BE Group
Berkley Contract Services Ltd
Betts Ecology
BNP Paribas Real Estate (2)
Brett Group
Carter Jonas LLP (2)
Cemex UK (2)
Charcon Construction Solutions
Co-operative Group Ltd
Costain
Crest Strategic Projects Ltd
Croome Estate Trust
David L Walker Ltd
DK Symes Associates
Dr A Judge
Drivers Jonas Deloitte
Eden Hall
Entec UK Ltd
Foley Gardens
Framptons
Frank P. Matthews Ltd.
George Law Ltd.
Go Greener Ltd (T/A Mailes Waste Management)
Grafton Barn
Gregory Gray Associates
Hanson UK
Harris Lamb
Hickman Stanmore
Hills Group
Hutton Stone
J Cullen Thermals Ltd
Kim MacDonald
Land & Mineral Management Limited
Land & Mineral Resource Consultants Ltd (3)
Lawrence Recycling
M & M Timber Co. Ltd.
M Biddle
M Victory
Mercia Waste Management
Micro Hydro Association
Morgan Technical Ceramics Ltd
Mr & Mrs Knowles
Mr C Narrainen
Mr D MacDonald
Mr E Duke
Mr Heath
Mr P Bladon
Mr P Knott
Mr Peter Spalton
Mr R Latham
Mr S Field
Mr S Wyatt
Mrs C Boughton-Thomas
Mrs Dell
Mrs E Morgan
Mrs EM Jones
Mrs G Sanderson
Mrs L Bryan
Myers Group
N K Reader
Overbury Estate
Peter Morgan
Profin Protective Finishing Limited
RA Watkins
Recycle 91
Robert Hitchins Ltd.
Royal Mail Group Legal (Real Estate)
RPS Planning (2)
RWE npower
Savills (3)
Smiths Concrete Ltd
Smiths Gore
Smiths of Bletchington
Somerfield
Sparc Systems Ltd.
SSG Quarries
Stansgate Planning Consultants Ltd
Tarmac Ltd (2)
Terence O'Rourke Ltd
The Concrete Centre
Tweedale Ltd
University of Derby Corporate
Wall, James, Chappell
Whiting Landscape Ltd.
Wienerberger Ltd
Wildmoor Quarry (Cinetic Sand) Ltd
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Appendix C: Direct mail/e-mail distribution list: second stage consultation
Key:
Unmarked = Sent consultation information on 11th November 2013.
Marked = "blue group" sent consultation information on 12th December 2013 – this group were considered
important to be involved in the development of the plan and were added to the Minerals consultation database but given the option to be removed on request.
Marked = "pink group" sent consultation information on 12th December 2013 – this group were considered to
have a potential interest in the development of the Minerals Local Plan and were sent the "Get Involved with Planning" questionnaire again but not automatically added to the Minerals consultation database.
Specific consultees:
Abberley Parish Council
Abberton Parish Meeting
Abbots Morton Parish Council
Acton Beauchamp Group Parish Council
Alcester Town Council
Alfrick & Lulsley Parish Council
Alvechurch Parish Council
Alveley & Romsley Parish Council
Arrow with Weethley Parish Council
Ashton-under-Hill Parish Council
Astley & Dunley Parish Council
Aston Subedge Parish Meeting
Badsey & Aldington Parish Council
Barnt Green Parish Council
Barnt Green Youth Parish Council
Bayton Parish Council
Beckford Parish Council
Belbroughton Parish Council
Bentley Pauncefoot Parish Council
Beoley Parish Council
Berrow Parish Council
Bewdley Town Council
Bickmarsh Parish Council
Bidford on Avon Parish Council
Birlingham Parish Council
Birmingham City Council
Birmingham City Council (Planning)
Birtsmorton Parish Council
Bishampton & Throckmorton Parish Council
Boraston Parish Meeting
Bournheath Parish Council
Bredicott Parish Meeting
Bredon & Bredon's Norton Parish Council
Bretforton Parish Council
Bridgnorth District Council (Director of Planning)
Broadheath Parish Council
Broadwas & Cotheridge Parish Council
Broadway Parish Council
Bromsberrow Parish Council
Bromsgrove District Council (6, including 1 and 2 )
Broome Parish Council
Broughton Hackett Parish Meeting
Buckland Parish Council
Burford Parish Council
Bushley Parish Council
Castlemorton Parish Council
Catshill and North Marlbrook Parish Council
Chaceley Parish Council
Chaddesley Corbett Parish Council
Charlton Parish Council
Childswickham Parish Council
Chipping Campden Town Council
Churchill & Blakedown Parish Council
Churchill Parish Council
Cleeve Prior Parish Council
Clent Parish Council
Cleobury Mortimer Parish Council
Clifton-on-Teme Parish Council
Coal Authority (3, including 1 )
Cofton Hackett Parish Council
Collington Parish Council
Colwall Parish Council
Cookhill Parish Council
Corse Parish Council
Cotswold District Council
Cradley Parish Council
Cropthorne Parish Council
Crowle Parish Council
Defford & Besford Parish Council
Dodderhill Parish Council (2)
Dodford with Grafton Parish Council
Dorsington Parish Council
Drakes Broughton & Wadborough with Pirton Parish Council
Droitwich Spa Town Council
Dudley Metropolitan Borough Council
Dumbleton Parish Council
Earls Croome Parish Council
Eastham Parish Council
Eastnor & Donnington Parish Council
91
Eckington Parish Council
Eldersfield Parish Council
Elmbridge Parish Council
Elmley Castle Parish Council
Elmley Castle, Bricklehampton & Netherton Parish Council
Elmley Lovett Parish Council
English Heritage
English Heritage (West Midlands)
Environment Agency (3, including 1 )
Evesham Town Council
Far Forest Parish Council
Feckenham Parish Council
Finstall Parish Council
Fladbury Parish Council
Flyford Flavell, Grafton Flyford & North Piddle Parish Council
Forest of Dean District Council
Forthampton Parish Council
Frankley Parish Council
Gloucestershire County Council (2)
Great Comberton Parish Council
Great Witley & Hill Hampton Parish Council
Grimley Parish Council
Guarlford Parish Council
Hagley Parish Council
Hallow Parish Council
Hampton Charles Parish Council
Hampton Lovett & Westwood Parish Council
Hanbury Parish Council
Hanley Castle Parish Council
Hanley Parish Council
Hartlebury Parish Council
Harvington Parish Council
Hatfield & District Group Parish Council
Herefordshire Council (2, including 1 )
Highley Parish Council
Hill and Moor Parish Council
Highways Agency
Hinckley & Bosworth Borough Council (Planning Policy and Regeneration)
Hindlip, Martin Hussingtree and Salwarpe Parish Council
Hinton-on-the Green & Somerville Parish Council
Holt Parish Council
Homes and Communities Agency (1, including 1 )
Honeybourne Parish Council
Inkberrow Parish Council
Kemerton Parish Council
Kempsey Parish Council
Kenswick & Wichenford Parish Council
Kidderminster Foreign Parish Council
Kington & Dormston Parish Council
Kinlet Parish Council
Kinver Parish Council
Knighton-on-Teme Parish Council
Knightwick & Doddenham Parish Council
Leigh and Bransford Parish Council
Leysters and Middleton-on-the-Hill Parish Council
Lickey and Blackwell Parish Council
Lindridge Parish Council
Linton Parish Council
Little Comberton Parish Council
Little Hereford Parish Council
Little Malvern & Welland Parish Council
Little Witley Parish Council
Longdon Queenhill and Holdfast Parish Council
Lower Broadheath Parish Council
Lower Sapey Parish Meeting
Madresfield Parish Council
Malvern Hills District Council (6, including 2 and 1 )
Malvern Town Council
Malvern Wells Parish Council
Mamble Parish Council
Marston Sicca (Long Marston) Parish Council
Martley Parish Council
Mathon Parish Council
Mickleton Parish Council
Milson and Neen Sollars Parish Council
National Air Traffic Services Ltd (2, including 1 )
National Grid (2)
Natural England (2, including 1 )
Naunton Beauchamp Parish Council
Network Rail (3, including 1 )
Newland Parish Council
North and Middle Littleton Parish Council
North Claines Parish Council
Northway Parish Council
Norton and Lenchwick Parish Council
Norton-Juxta-Kempsey Parish Council
Offenham Parish Council
Ombersley & Doverdale Parish Council
Overbury & Conderton Parish Council
Pebworth Parish Council
Pendock Parish Council
Pensax Parish Council
Peopleton Parish Council
Pershore Town Council
Pinvin Parish Council (2)
Powick Parish Council
Quinton Parish Council
Redditch Borough Council (6, including 2 and 2 )
Redmarley D'Abitot Parish Council
Ripple Parish Council
Rochford Parish Council
Rock Parish Council
Romsley Parish Council
Rous Lench Parish Council (2)
Rushock Parish Council
Rushwick Parish Council
Saleway Group (Himbleton, Hadzor, Oddingly, Huddington)
Saintbury Parish Meeting
Salford Priors Parish Council
Sambourne Parish Council
Sedgeberrow Parish Council
Severn Stoke and Croome d'Abitot Parish Council
92
Severn Trent Water (4, including 2 )
Shrawley Parish Council
Shropshire Council
Shropshire Council (Director of Development Services)
Snowshill Parish Meeting
Solihull Metropolitan Borough Council (2, including 1 )
South Lenches Parish Council
South Littleton Parish Council
South Staffordshire Council (2, including 1)
Spetchley Parish Council
St Peter's the Great County Parish Council
Staffordshire County Council (3, including 1)
Stanford with Orleton Parish Meeting
Staunton Parish Council
Stock and Bradley Green Parish Council
Stockton-on-Teme Parish Meeting
Stoke Bliss, Kyre and Bockleton Parish Council
Stoke on Trent City Council (Planning Policy)
Stoke Prior Parish Council
Stone Parish Council
Stoulton Parish Council
Stourport-on-Severn Town Council
Stratford-on-Avon District Council
Strensham Parish Council
Studley Parish Council
Suckley Parish Council
Tanworth-in-Arden Parish Council
Teddington Parish Council
Tenbury Town Council
Tewkesbury Borough Council
Tewkesbury Borough Council (Environmental Health and Housing)
The Shelsleys Parish Council
Thornbury Parish Council
Tibberton Parish Council
Tirley Parish Council
Tutnall & Cobley Parish Council
Twyning Parish Council
Upper Arley Parish Council
Upton on Severn Town Council
Upton Snodsbury Parish Council
Upton Town Council
Warndon Parish Council (2)
Warwickshire County Council
West Malvern Parish Council
West Mercia Police (Malvern, Worcester and Wychavon)
West Mercia Police (Redditch, Bromsgrove and Wyre Forest)
West Mercia Police Estates Service
West Mercia Police Headquarters
Western Power Distribution
Weston Sub Edge Parish Council
Whitbourne Parish Council
White Ladies Aston Parish Meeting
Whittington Parish Council
Wick Parish Council
Wickhamford Parish Council
Willersey Parish Council
Wolverley & Cookley Parish Council
Worcester City Council (3, including 2 and 1 )
Worcestershire County Council (Chief Executive)
Worcestershire County Council (Conservation & Landscape Officer)
Worcestershire County Council (Countryside and Access)
Worcestershire County Council (Countryside Business Manager)
Worcestershire County Council (Countryside Greenspace Manager)
Worcestershire County Council (28, including 4 and 4 )
Wychavon District Council (3, including 1 )
Wyre Forest District Council (9, including 6 and 2)
Wyre Piddle Parish Council
Wythall Parish Council
General consultees:
Agricultural Lime Association
Al Madina Islamic Centre
Avon Navigation Trust
Beckford Nature Reserve
Belbroughton History Society
Bewdley Civic Society
Brecon Beacons National Park Authority (Planning Policy)
Bredon Hill Rotary Club
British Aggregates Association
British Association for Shooting and Conservation
British Cement Association
British Ceramic Confederation
British Geological Survey
British Gliding Association
British Horse Society
British Lime Association
British Marine Aggregate Producers Association
British Ready-mixed Concrete Association
British Stone
British Telecom
British Waterways (4, including 4 )
Bromsgrove Society
Canal and River Trust
Charter Trustees of Kidderminster
Chartered Institution of Waste Management
Communities First Herefordshire and Worcestershire
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Community First
Community Forum
Confederation of British Industry, West Midlands Region
Confederation of British Industry, Minerals Group
Confederation of UK Coal Producers
Construction Industry Research & Information Association
Cotswolds Conservation Board
CPRE
CPRE (Redditch Group)
CPRE (Worcestershire)
Crown Estate Commissioners
Cyclists' Touring Club of Great Britain
Deaf Direct
Defence Estates (Defence Infrastructure Organisation)
Defra, Rural Development Service
Department of Communities and Local Government (National Planning Casework Unit)
Department for Communities and Local Government (Policy Advisor)
Department of Energy and Climate Change
Department of Trade and Industry
Department of Transport
Diocesan Board (Worcester Church of England)
Disability Action
Droitwich History & Archaeology Society
Droitwich Spa Rotary Club
Duckworth Worcestershire Trust
East Midlands Aggregates Working Party (2, including 1 )
East of England Aggregates Working Party (2, including 1 )
Ethnic Elders Luncheon Club
European Aggregates Association
Federation of Small Businesses
Forestry Commission (2, including 2 )
Freight Transport Association (Midlands)
Friends of the Earth (Redditch)
Friends of the Earth (UK)
Greater Birmingham and Solihull LEP Executive
Greater London Authority Aggregates Working Party
Health and Safety Executive
Health Protection Agency
Hereford & Worcester Fire & Rescue Service
Hereford and Worcester Fire Brigade
Herefordshire & Worcestershire Earth Heritage Trust
Herefordshire and Worcestershire Chamber of Commerce
HSE Linewatch
Industrial Minerals Association - Europe
Institute of Quarrying
Kaolin & Ball Clay Association UK
Kemerton Conservation Trust
Land Access and Recreation Association
Lickey Hills Society
London Aggregates Working Party
Longdon and Eldersfield Marsh Conservation Trust
Madinatul Uloom-Ai-Islamiya
Malvern Civic Society
Malvern Hills AONB Joint Advisory Committee
Malvern Hills Conservators
Malvern Rotary Club
Micro Hydro Association
Mineral Products Association (3, including 2 )
Ministry of Defence (2, including 2 )
Mobile Operators Association
Muslim Welfare Association
National Federation of Demolition Contractors
National Stone Sand & Gravel Association
Negotiating Platform for Silica
NFU West Midlands
North East Aggregates Working Party
North Wales Aggregates Working Party
North West Aggregates Working Party
Office of Government Commerce
Older People's Forum in Droitwich Spa
Older People's Forum in Evesham
Older People's Forum in Kidderminster
Older People's Forum in Pershore
Older People's Forum in Redditch
Older People's Forum in Worcester
Open Spaces Society
Over 55's (Malvern)
Pershore Civic Society
Planning Inspectorate
Redditch Irish Society
Romsley & Hunnington History Society
Rowney Green Association
Royal Institute of Chartered Surveyors
Rural Hub (Chair)
Rural Hub (Director)
Salt Association (2, including 1 )
Severn Rivers Trust (2, including 1 )
Silica & Moulding Sands Association (2 including 2 )
Severn Navigation Restoration Trust
South Droitwich Residents Group
South East Aggregates Working Party
South Wales Aggregates Working Party (2)
South West Aggregates Working Party
South West Aggregates Working Party (2, including 1 )
South Worcestershire Archaeological Group
South Worcestershire Land Drainage Partnership
South Worcestershire Land Drainage Partnership (Malvern & Worcester City Area)
94
South Worcestershire Land Drainage Partnership (Wychavon Area)
Sport England (3, including 3 )
Stone Federation Great Britain
Teme Valley Biodiversity Group
Teme Valley Geological Society
The Central Mosque and Community Centre
The Ethnic Minority Redditch Group
The Inland Waterways Association (2, including 1 )
The Mining Association of the UK
The Polish Roman Catholic Community in Redditch
The Redditch Chinese Association
The Redditch Indian Association
The Rotary Club of Worcester
The Stone Federation of Great Britain
Upton-upon-Severn Civic Society
Upton-upon-Severn Rotary Club
Vale Landscape Heritage Trust
Vale of Evesham Civic Society
West Midlands Aggregates Working Party
Wildmoor Residents Association
Worcestershire Coalition of Independent Living
Worcestershire Council for Voluntary Youth Services
Worcestershire County Council (Progress in Sight Group)
Worcestershire Federation of Women's Intitutes
Worcestershire Federation of Young Farmers Clubs
Worcestershire FWAG
Worcestershire Greenpeace Network
Worcestershire Historical Society
Worcestershire LEP
Worcestershire Partnership
Worcestershire Waterways
Worcestershire Wildlife Trust
Yorkshire and the Humber Aggregates Working Party
Other interested parties:
A Judge (member of the public)
A.E. Oscroft & Son
Accurate Cutting Services Ltd
Adams Hendry Consulting Ltd
ADAS Consulting
Adstone Construction Ltd
AECOM
Aggregate Industries UK Ltd
Allen Newport Ltd
AMEC
Armchair
Asda (Pershore)
Asda Stores Limited (Bromsgrove)
Associated Concrete Solutions Ltd
ATE Wales
Atkins Consultants
Avoncroft Museum
B Carter (member of the public)
Ballast Phoenix
Barton Willmore Partnership
Bathgate Silica Sand Ltd
BBT Thermotechnology UK Ltd
BE Group
Benniman Ltd
Berkeley Strategic Land
Berkley Contract Services Ltd
Bestco Surfacing Ltd
Betts Ecology
BIFFA Waste Services
Blaby District Council (Planning Policy)
Bloor Homes, J.S. Bloor (Services) Ltd
BNP Paribas Real Estate (2)
Borough Green Sandpits Ltd
Bovis Homes Ltd
Boyer Planning
Breedon Aggregates
Brett Group
Brian Hill Haulage & Plant Hire Ltd
Britannia Aggregates Ltd
British Library
Cannock Chase Council (Planning Policy)
C Boughton-Thomas (member of the public)
Carter Jonas
Carver Knowles
CB Richard Ellis
Cemex UK
Central Trains
Centre for Radiation Chemicals and the Environment
CENTRO
Chadwich Lane Quarry
Chadwich Lane Quarry Limited
Chambers Runfold
Charcon Construction Solutions
Cheltenham Borough Council (Planning Policy)
Cherwell District Council (Planning Policy)
Civil Aviation Authority
Cleanaway
Colas Ltd
Co-operative Group Ltd (Ombersley Road, Worcester)
Costain Infrastructure Support Services
Cotswold Drainage Ltd
Country Land and Business
Coventry City Council (Planning Policy)
CPI Mortars
Crest Strategic Projects Ltd
Croome Estate Trust
David L Walker Ltd
David Walker Chartered Surveyors
Daventry District Council (Planning Policy)
Day Aggregates Ltd
Deme Building Materials Ltd
Derbyshire County Council (Development Plan Team)
95
Development Land & Planning Consultants Ltd
DK Symes Associates
Docklow and Hampton Wafre Parish Council
DPDS Consulting Group
Drivers Jonas Deloitte (2, including 1 )
DTZ Pieda Consulting
Dunhouse Quarry Co Ltd
E Duke (member of the public)
E Roberts (member of the public)
East Staffordshire Borough Council (Planning Policy)
EATON - Aerospace Division
Entec UK Ltd
Erith Haulage Company Ltd
Essex County Council
Eurovia Roadstone
Eutectic Co. Ltd
F Fawcett (member of the public)
F M Conway Ltd
First City, The Property Consultancy
Foxley Tagg Planning Ltd
Framptons Planning
Francis Flower
Frank P. Matthews Ltd.
Fusion Online Ltd
George Law Ltd
Gerald Eve Chartered Surveyors and Property Consultants
GL Hearn Planning
Gloucester City Council (Planning Policy)
Gloucestershire Sand and Gravel Co. Ltd
Gregory Gray Associates
GRS Roadstone Ltd
Grundon Sand & Gravel Ltd
H Tuckwell & Sons Ltd
Hadley Recycling & Waste Management
Halcrow Group Ltd
Hallam Land Management
Hallmark Hulme
Hanson UK (2, including 1 )
Harborough District Council (Planning Policy)
Harleyford Aggregates Ltd
Harriet Baldwin, MP
Harris Lamb
Harris Lamb Planning Consultancy
Harsco Metals Group Ltd
Hartlebury Quarry
Heaton Planning
Hills Group
Hills Minerals and Waste Ltd
Hills Mineral & Waste
HM Prison Service
Home Builders Federation
Home Office PL (Sites and Planning Section)
Hope Conservation Trust
Hugh King & Co
Humberts
Huntsmans Quarries Ltd
Hutton Stone Co Ltd (2, including 1 )
J & J Franks Ltd
J Clubb Ltd
J Cullen Thermals Ltd
J Wainwright & Co Ltd
John Carr (Liverpool) Ltd
Joy Mining Machinery Ltd (Worcester)
JPE Holdings Ltd
K MacDonald (member of the public)
Karen Lumley, MP
Kendall Brothers (Portsmouth) Ltd
Kent Jones and Done
L Bryan (member of the public)
L.G. Harris & Co Ltd
Lafarge Aggregates Limited (2, including 1 and 1 )
Lambert Smith Hampton
Land & Mineral Management Ltd (2, including 1 )
Land & Mineral Resource Consultants Ltd
Landscape Design Associates
Lawrence Recycling
Leicester City Council (Planning Policy)
Leicestershire County Council (Minerals Developments & Policy)
Leominster Reclamation and Architectural Salvage
Lhoist UK Ltd
Lichfield District Council (Planning Policy)
Liz Lynne, MEP
Lovell Johns Ltd
Lower Severn Drainage Board
Lucas Land and Planning
M & M Timber Co. Ltd
M Biddle (member of the public)
M V Kelly Ltd
M Victory (member of the public)
Maile Skips
Malcolm Harbour, MEP
Manby & Steward
Mansfield Sand Co Ltd
Marchington Stone
Mark Garnier, MP
Marrons Solicitors
Marshalls Plc
Marwalk Developments Ltd
Mason Richards Planning
Mercia Waste Management
MetNet
MFG Solicitors
MHF UK Ltd
Mid-Essex Gravel Pits (Chelmsford) Ltd
Midland Portable Buildings
Midland Quarry Products
Mike Nattrass, MEP
Miller Homes Limited
Mineral Industry Research Organisation
Minerals Valuers Office
Monier Redland
Montagu Evans
Moorhouse Sand & Gravel Pits
Moreton C Cullimore (Gravels) Ltd
Morgan Technical Ceramics Ltd
Morris & Perry (Gurney Slade) Ltd
96
MPA Cement
Mr & Mrs GR Knowles (members of the public)
Mr Clive Narrainen (member of the public)
Mr Hickman (member of the public)
Mr P Bladon (member of the public)
Mr S Wyatt (member of the public)
Mr Shiftit
Mrs Dell (member of the public)
Mrs E Morgan (member of the public)
Mrs EM Jones (member of the public)
Mrs G Sanderson (member of the public)
Myers Group
N Inchbald (member of the public)
Nathanial Lichfield & Partners
National Trust (S Barker)
National Trust (West Midlands Regional Office)
Nature After Minerals
Needham Chalks Ltd
Nicole Sinclair, MEP (2, including 1 )
Northamptonshire County Council
North Bromyard Group Parish Council
North Tewkesbury Land Consortium
North Warwickshire Borough Council (Planning Policy)
North West Leicestershire District Council (Planning Policy)
North Worcestershire Land Drainage Partnership (Wyre Forest, Redditch & Bromsgrove Area)
Northumberland Quarries
Northwood (Fareham) Ltd
Nuclear Legacy Advisory Forum
Nuneaton and Bedworth Borough Council (Planning Policy)
Oadby and Wigston Borough Council (Planning Policy)
Oakfield Farm Products Ltd
Oakland Ecology
Office of Rail Regulation
Overbury Estate
Oxford City Council (Planning Policy)
Oxfordshire County Council (Minerals and Waste Planning Policy)
P D Edenhall Ltd
P Knott (member of the public)
P Spalton (member of the public)
Pencroft Ltd
Peter Luff, MP
Philip Bradbourn, MEP
Phillips Planning Services Ltd
Phipps & Pritchard
Planning Issues
Powys County Council (Local Development Plan Team)
Profin Protective Finishing Limited
R C A Regeneration
R Collard Ltd
R Jenkins (member of the public)
R Latham (member of the public)
R Watkins (member of the public)
R.J.D Ltd
Rail Freight (Users & Suppliers) Group Ltd
Ramblers Association (2, including 1 )
Recycle 91
Recycling Solutions
Refined Bitumen Association
Remix Dry Mortars Ltd
Roadstone Dublin Ltd
Robert Hitchins Ltd (2, including 1 )
Robert Turley Associates Ltd
Robin Walker, MP
Rotherham Sand & Gravel Supply Co Ltd
Rowberry Group Ltd
Royal Mail
RPS Group PLC
RPS Planning
RSPB (Midlands Region)
Rugby Borough Council (Planning Policy)
RWE npower
Sandwell Metropolitan Borough Council (2, including 1 )
S Field (member of the public)
Safeguarding, DE Operations - North
Sajid Javid, MP
Salop Sand & Gravel Supply Co Ltd
Savills
SB Heath (member of the public)
Sea Aggregates Ltd
Sewells Reservoir Construction Ltd
Sibelco UK
Singleton Birch Ltd
Smith & Sons (Bletchington) Ltd
Smiths Concrete Ltd
Smiths Gore
Social Enterprises in Waste and Recycling (SEWAR) Herefordshire & Worcestershire
Somerfield (Malvern)
Somerset Wildlife Trust
South Derbyshire District Council (Planning Services)
South Gloucestershire Council (Planning Policy)
South Northamptonshire Council (Planning Policy)
South Oxfordshire District Council (Planning Policy)
Sparc Systems Ltd
Springfield Farm Ltd
SSG Quarries
St. Modwen Developments
Stafford Borough Council (Forward Planning)
Stansgate Planning Consultants Ltd
Steetley Dolomite Ltd
Stewart Vick Associates
Strong Farms Ltd
Stroud District Council (Planning Strategy)
Strutt and Parker
Suffolk County Council (Strategic Environmental Assessment Officer)
Swindon Borough Council (Planning Policy)
97
Tamworth Borough Council (Development Plan Team)
Tarmac Group
Tarmac Ltd (3, including 1 )
Telford and Wrekin Council (Planning Policy)
Terence O'Rourke Ltd
The Bengali Group
The Bennie Group
The Bird Group of Companies Ltd
The Concrete Centre
The Cotswold Reclamation Company
The Land Trust
The National Trust
The Woodland Trust
Three Counties Planning Consultancy
Tony Rowley Associates Ltd on behalf of Lechmere Estate
Trefigin Quarries Ltd
Tudor Griffiths Group
Tweedale Ltd
United Asphalt
University of Derby Corporate
Vale of White Horse District Council (Planning Policy)
Veolia Environmental Services (UK) Plc
Vinci Construction UK
Volker Dredging Ltd
Volker Laser
W Clifford Watts Ltd
Wall James Chappell
Walsall Council (Planning Policy)
Walsall Metropolitan Borough Council
Wardell Armstrong
Warwick District Council (Planning Policy)
Warwickshire Wildlife Trust
Webbs of Wychbold
Weights Farm
Welsh Assembly Government
West Midlands Conservative MEP Team
West Midlands Labour European Office
West Midlands Planning and Transportation Sub-Committee
West Oxfordshire District Council (Planning Policy)
White Young Green Planning
Whiting Landscape Ltd
Wienerberger Ltd
Wildmoor Quarry (Cinetic Sand) Ltd
Wilson Bowden PLC
Wiltshire Council (Spatial Planning)
Winchcombe Reclamation
Wolverhampton City Council (Planning Policy)
Wolverhampton City Council (Planning Services)
Woodkirk Stone
Woodland Trust
Worcester Environmental Federation
Worcester Muslim Welfare Association
Worcester Reclamation Ltd
Worcester Wildlife Trust
Worcestershire Association of Local Councils
Worcestershire Biological Records Centre
Worcestershire County Association of Local Councils
Worcestershire Regulatory Services (4, including 3 )
Worcestershire Residents Against Incineration and Landfill Committee
Wye Valley Reclamation
Wyre Forest Recycling Services Limited