Comment

Representation ID: 22453

Received: 11/10/2021

Respondent: Tarmac Trading Ltd (Sharne Sahajpal)

Agent: Heatons

Mineral Safeguarding

Policy MIN 2 sets out the Authority approach to mineral safeguarding. The identification of
mineral safeguarding areas defined by mineral resource is supported. We also welcome the
emphasis on safeguarding when assessing development which falls within a defined mineral
safeguarding area to ensure development does not compromise future or existing mineral
working (part 3 of Policy MIN2). However, the reference to economic value of mineral resource
(part 3b) should be removed. The NPPF paragraph 210d refers to prior extraction ‘where
practical and environmentally feasible’ if it is necessary for non-mineral development to take
place. There is no reference to the need to demonstrate economic value of mineral in national
policy or guidance as this will change over time dependent upon resource availability, markets
etc. It is essential that there is sufficient supply and therefore the best use of resource needs to be made to secure their long-term conservation.

Paragraph 12.32 in the justification text refers to mineral sterilisation only occurring in regard to
development sites in excess of 5 hectares in size and those developments being accompanied by
supporting information to demonstrate that mineral resources would be needlessly sterilised.
We do not agree with this view and that is contrary to the approach set out within Policy MIN2.
The criteria for supporting information where prior extraction is not considered feasible further
weakens the position. Again, reference to viability and economic value is not considered to be in
accordance with the NPPF approach. In addition, the judgement on mineral extraction having
detrimental impact on neighbouring uses predetermines the findings of environmental
assessment work that may accompany a mineral extraction scheme. The approach to
safeguarding needs to be consistent with the overall aims of securing indigenous supply of
resource.

As part of Policy MIN2 of the BCP, mineral infrastructure sites are identified, listed and included
on both the Minerals Key Diagram and Policies Map. These sites include Tarmacs operations
across the Black Country. Our client would like to express their support for Mineral Safeguarding,
particularly for paragraph 7 of Policy MIN2 protecting the Mineral Infrastructure Sites from
incompatible development, including a 150m buffer from the site.