Comment

Representation ID: 22455

Received: 11/10/2021

Respondent: Tarmac Trading Ltd (Sharne Sahajpal)

Agent: Heatons

Policy MIN3 of the emerging Black Country Plan identifies ‘Preferred Areas’ for mineral
development within the Black Country, as informed by the requirements for those minerals
outlined within MIN1 of the BCP, availability of resource and constraints. These ‘Preferred Areas’
for mineral development (remaining permitted reserves, site specific/preferred areas identified


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at Birch Lane and other resource within the MSA’s) are supported in principle within Policy MIN3,
subject to development complying with requirements of Policy MIN4 (managing the effects of
mineral development) and other policies contained within the BCP. ‘Significant weight’ will be
given to the contribution these sites would make towards the sand and gravel supply
requirements identified in Policy MIN1.

The approach within Policy MIN3 to sand and gravel supply suggests that there is no
preference/hierarchy to sites coming forward for mineral extraction – i.e those within MSA’s
hold equal weight to the identified preferred areas, as it is recognised they will be required to
sustain aggregate supply – and this is supported. The justification text for the ‘Preferred Area’
for sand and gravel extraction at Birch Lane (land around the former Aldridge Quarry) states
that “As this site remains unrestored, any new sand and gravel extraction proposals in this area
will be expected to help facilitate the restoration of this site.” This is considered to be overly
onerous on operators, not justified and could ultimately constrain much needed mineral supply
for the both the West Midlands and further afield. Seeing resource come forward within the
authority is extremely important, and only emphasised further by the potential need for the
Black Country to pick up some of the potential shortfall from Solihull as they could see mineral
sterilised by HS2; a point which the Council is clearly aware of as it is referred to within
paragraphs 12.14 through 12.21 of the consultation plan.

The Council needs to be clear on their reasoning for requiring minerals development to
facilitate restoration of another site. It is our view that this approach is not positively prepared
in supporting minerals development to meet identified need. The fact that the site has
remained unrestored does not justify a requirement upon another operator to restore
additional land or previous working areas, this could be viewed as cost prohibitive to new
mineral development coming forward which makes it an ineffective strategy. We question the
justification and soundness of this requirement within the plan as it places a restrictive element
to policy which should be prepared with the objective of contributing to achieving sustainable
development, in line with paragraph 16a of the NPPF.