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Black Country Core Strategy
Issues and Options Consultation
Minerals Background Paper
June 2007
1
Further Information
Black Country Minerals Policy Contacts
David Piper
Dudley MBC
Tel: 01384 814173
Email: [email protected]
Mohammed Salim
Sandwell MBC
Tel: 0121 569 4018
Email: [email protected]
Dawn Harris
Walsall Council
Tel: 01922 652482
Email: [email protected]
Katie Dickson
Wolverhampton City Council
Tel: 01902 552177
Email: [email protected]
Front cover illustrations: Brownhills Miner and Ibstock Quarry, Aldridge. Picture of
quarry taken by Walsall MBC with kind permission of Ibstock Brick Ltd.
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BLACK COUNTRY CORE STRATEGY
Minerals Background Paper
June 2007
Contents
Section
Pages
1. The Importance of Minerals
3 – 4
2. Key Policy Issues for Minerals
5 – 7
3. Baseline Evidence for Minerals
8 – 18
4. Consultation and Engagement
19 – 21
Bibliography
22 - 26
3
1. The Importance of Minerals
1.1 Mineral resources are vital to the regional and local economy and are a
major source of export revenue nationally. In 2002, it was estimated that
mining and quarrying contributed more than £25.5 million to UK Gross Value
Added (GVA). It is also estimated that in 2002, mining, quarrying and
associated industries (including construction) contributed around 16% of all
UK GVA.1
1.2 Minerals are also essential requirements for new development. For
example, builders need brick clay for making bricks and tiles, and builders
and engineers need aggregates (sands and gravels and crushed rock) for
hardcore, building roads and landscaping. Aspirations towards future housing
and economic growth within the Black Country will depend on maintaining
local supplies of building materials as well as importing materials that cannot
be sourced locally.
1.3 There are three types of minerals:
• Primary – minerals produced from quarrying or marine dredging
• Secondary – minerals produced as by-products of quarrying other
materials or from other industrial processes
• Recycled – minerals produced from construction, demolition or
excavation wastes
1.4 The Black Country is rich in mineral resources. The main minerals
present in the Black Country are: ironstone, fireclay, coal, limestone, sands
and gravels, hard rock and brick clay. The brick clay that occurs in parts of
Dudley and Walsall is Etruria marl, which is a rare mineral nationally. At the
present time only sand and brick clay are actively exploited. Until very
1 The Economic Importance of Minerals to the UK (2004), British Geological Survey/ ODPM, available on UK
Minerals website: http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html
4
recently, hard rock was also quarried, but the quarry producing this has
recently closed. The Black Country also produces significant quantities of
construction, demolition and excavation waste through redevelopment
schemes, which has the potential to be recycled.
1.5 Minerals are a finite resource. There is also limited flexibility over the
locations where working can take place, since minerals can only be worked
where they naturally occur. Much of the Black Country’s mineral resources are
already sterilised by development, and realistically, large-scale exploitation of
minerals is unlikely to take place within the built-up areas of the Black
Country. However, in some circumstances, it may be possible to extract
minerals in advance of redevelopment schemes.
1.6 Quarrying is currently concentrated in particular areas within the Black
Country where significant mineral resources are known to exist, such as
Stubbers Green, Aldridge and Stonnall in Walsall and Kingswinford in Dudley.
Most of the Black Country’s existing quarries are subject to permissions that
require them to be restored by landfill once quarrying ceases. This means that
in the longer-term, the Black Country will be able to provide additional landfill
capacity for the deposit of waste residues that cannot be re-used, recycled or
recovered for other uses.
5
2. Key Policy Issues for Minerals
2.1 National policy guidance on minerals is set out in Minerals Policy
Statement 1 (MPS1) and the associated Planning and Minerals: Practice
Guide (November 2006). The key policy requirements for development plan
policies are:
• To provide clear guide to mineral operators and the public about the
locations where mineral extraction may take place within the Black
Country, and
• To ensure that the Black Country will be able to contribute
appropriately towards national, regional and local mineral requirements
for the supply of minerals, in accordance with the principles of
sustainable development.
2.2 This means that as well as considering the demand for materials, the
Core Strategy must consider the other social, economic and environmental
effects of quarrying such as impacts on the local landscape, water resources,
and biodiversity and geodiversity, and impacts of the transportation of mineral
products on the highway network, local communities and air quality. It also
means that the extraction of primary minerals will be expected to be kept to a
minimum by promoting resource efficiency and making as much use of
secondary and recycled materials as possible.
2.3 The Core Strategy will be expected to make provision for the future
supply of aggregates and brick clay (and possibly other minerals) up to 2026,
in line with the current requirements set out in MPS1, as well as the regional
and sub-regional requirements set out in the National and Regional
Guidelines for Aggregates Provision in England 2001 – 2016 and the
Regional Spatial Strategy for the West Midlands (RSS)2. The national and
regional guidelines set out the aggregates supply requirements for each
2 Currently Regional Planning Guidance for the West Midlands (RPG11) (June 2004), Government Office for the
West Midlands, available on the WMRA website: http://www.wmra.gov.uk/page.asp?id=49
6
region, which should be apportioned to individual mineral planning authorities
or sub-regions through the RSS.
2.4 Within the West Midlands RSS there is a requirement for the West
Midlands Metropolitan area3 to provide 0.506 million tonnes of sand and
gravel per annum between 2001 and 2016. The Black Country currently
contributes towards this, and will be expected to continue to do so in the
future, until such time as the requirement changes. Recent reviews of the
National Guidelines propose no changes to the regional aggregates
apportionments and recommend that for the time being, mineral planning
authorities preparing long-term plans should roll-forward the existing
requirements beyond 2016.4 At present, the RSS does not require the Black
Country to make provision for any other minerals. However, MPS1 advises
that at well as maintaining 7 year landbanks (i.e. 7 year’s supply of permitted
reserves) of sand and gravel, authorities should maintain a minimum of 25
years’ supply of brick clay to brickworks.
2.5 The Core Strategy will also be expected to include policies aimed at
safeguarding the Black Country’s proven mineral resources against needless
sterilisation by non-mineral development, in line with the advice in MPS1 and
draft Guide to Mineral Safeguarding in England published by the British
Geological Survey in April 2007. The latter recommends a step-by-step
approach, involving firstly, assessing which is the best information available,
secondly, deciding which minerals are likely to become of economic
importance in the foreseeable future, thirdly, deciding which resources should
be safeguarded, and finally, deciding how to implement this through planning
policy.
2.6 The Core Strategy policy towards minerals will also have to take into
account the aspirations of the RSS Phase 1 and Phase 2 Revisions in terms
of housing and economic growth, tackling climate change and transforming
3 The West Midlands Metropolitan area is the whole of the former West Midlands County area, i.e. the metropolitan
authorities of Birmingham, Coventry, Dudley, Sandwell, Solihull, Walsall and Wolverhampton. However, the only authorities that currently contribute towards the sub-regional sand and gravel apportionment are Solihull and Walsall. 4 National and Regional Guidelines for Aggregates Provision in England 2001 – 2016: Third Monitoring Report
(September 2006), DCLG, available on DCLG website: http://www.communities.gov.uk/index.asp?id=1503133
7
the Black Country environment. In addition, it will be expected to embrace the
key themes of local community plans and strategies (e.g. environmental
improvement, reinforcing local pride, promoting economic growth and
prosperity), the emerging Black Country Geodiversity Action Plan, and
provision for minerals by neighbouring mineral planning authorities in their
emerging Minerals and Waste Development Frameworks/ Local Development
Frameworks.
2.7 The RSS minerals policies are now under review as part of the RSS
Phase 3 Revisions. At present too early to say what impact this is likely to
have on the Black Country’s future mineral supply requirements. It will be
necessary to review the emerging Core Strategy policy towards minerals
when the RSS review is at a more advanced stage and we have a clearer
idea of what the requirements may be, but in any event, the Core Strategy will
be expected to provide sufficient flexibility to accommodate future
requirements even if these should change.
8
3. Baseline Evidence for Minerals
3.1 In this section we have set out the latest available information on
minerals in the Black Country. This is a “snapshot” of the position at April
2007. It will be apparent that there are gaps and that caveats are attached to
some of the information. The authorities may undertake or commission further
work to address deficiencies in the evidence base, where necessary and
where this is realistic/ practicable within the timescale available. The Minerals
Background Paper will be reviewed and updated at later stages in the
development of the Core Strategy, to reflect any new information that
becomes available.
Mineral Resources
3.2 When planning for minerals, authorities are expected to use the best
available information on mineral resources within their area and to consider
the social, environmental and economic benefits and constraints of working
them (MPS1, paragraph 12). The best and most up-to-date information
available on the extent of mineral resources in the Black Country is the
geological maps, memoirs and Mineral Resource Information for
Development Plans – West Midlands: Resources and Constraints,
published by the British Geological Survey (BGS). The mineral resource
document is in the form of a written report and a mineral resource map.
3.3 These documents indicate that the following mineral resources are
present in the Black Country:
• Sand and Gravel – River deposits and glacial deposits in various
locations throughout the Black Country, also significant solid deposits
of Sherwood Sandstone (Triassic) outcrops on the western fringe of
Dudley (Wall Heath, Wordsley and Wollaston), in Sandwell (Warley,
Londonderry and West Smethwick), on the eastern side of Walsall
(Stonnall, Aldridge, Streetly and Great Barr) and in Wolverhampton
(Bushbury, Blakenhall and Penn)
9
• Limestone – Isolated outcrops of Much Wenlock (Silurian) Limestone
in Dudley (Castle Hill, Wren’s Nest and parts of Gornal) and Walsall
(parts of Walsall Town Centre and Cuckoo’s Nook, Aldridge)
• Dolerite – Isolated outcrops of Rowley Rag in Dudley (Tansley Hill,
south of Town Centre, Milking Bank and Cooper’s Bank) and Walsall
(Pouk Hill), with more extensive outcrops in Sandwell (Rowley Regis)
and Wolverhampton (Wednesfield)
• Coal Measures – Extensive deposits of shallow coal in Dudley
(Coseley, parts of Dudley Town Centre, Brierley Hill and Lye), Sandwell
(Wednesbury, Tipton and West Bromwich), western side of Walsall
(Brownhills, Bloxwich, Willenhall and Darlaston) and eastern side of
Wolverhampton (Wednesfield and Bilston)
• Clay – Extensive deposits of Etruria Formation Clay in Dudley
(Gornalwood, Kingswinford, Pensnett, Brierley Hill, Bumble Hole, Darby
End, Mousesweet, Quarry Bank, Cradley and part of Halesowen), the
western side of Sandwell (Tipton, West Bromwich, Oldbury, Old Hill,
Cradley Heath and Blackheath) and Walsall (Stubbers Green and
Aldridge).
3.4 Minerals are known to have been extracted in the Black Country since
the 16th century and possibly even before that. Exploitation of coal, ironstone,
fireclay and limestone fuelled the rapid expansion of industry during the 18th
and 19th centuries in Black Country and Birmingham. It is unlikely that the
BGS mineral resource map shows the full extent of mineral working in the
past, as early workings are unlikely to have been documented, as previously
unknown and unrecorded voids are still occasionally discovered. We are still
living with the legacy of previous mineral working, which has not only shaped
the overall pattern of development in the Black Country, such as the canal and
rail network, but has also led to localised problems of unstable and
contaminated land.
10
3.5 The Black Country’s dolerite and limestone resources are almost
certainly now exhausted. Limestone has not been worked for many years, and
the last dolerite quarry (Edwin Richards) closed early in 2007. Although
extensive areas of sand and gravel, shallow coal deposits (underlain by
fireclay) and Etruria Formation brick clay remain within the Black Country,
most of these are now sterilised by development. This is likely to be a major
constraint to future working, other than where it is feasible to extract the
minerals in advance of redevelopment schemes.
3.6 Although there is still potential to extract deposits of coal/ fireclay and
sands and gravels within areas of Green Belt on the fringes of the Black
Country, these may be subject to other significant constraints, such as:
• Groundwater Source Protection Zones, which underlie much of the
Black Country’s sand and gravel resources in Walsall and
Wolverhampton; and
• Natura 2000 Sites (European Sites), of which there are two in the
Black Country (Cannock Extension Canal SAC in Brownhills, Walsall,
and Fens Pools SAC in Dudley), both of which lie within areas of
mineral resources.
3.7 The Environment Agency will object to landfill proposals in
Groundwater Source Protection Zone I, and will require a risk assessment for
sites in Zones II or III.5 This has significant implications for the restoration of
former quarries within such areas, since at best the Agency is only likely to
permit filling with inert materials. This will inevitably limit the options for
restoring sites to safe and acceptable standards within a reasonable
timescale. Impacts on European Sites also cannot be ruled out, even on sites
that are some distance away. Any development that may affect a Special Area
5 See Landfill Directive Regulatory Guidance Note 3 (RGN3) – Groundwater Protection: Locational Aspects of
Landfills in Planning Consultation Responses & Permitting Decisions (December 2002), Environment Agency, published on Environment Agency website: http://www.environment-agency.gov.uk/business/1745440/444663/landfill/1764524/1693182/475339/?version=1&lang=_e
11
of Conservation (SAC) or Special Area of Protection (SPA) must be subject to
an “appropriate assessment” in accordance with the Habitats Directive,6 to
determine whether or not the proposal will affect the integrity or conservation
objectives of the site.
Existing Quarries and Mineral Safeguarding Areas
3.9 The BGS mineral resource map shows the location of active and
inactive mineral workings in 1999. However, several of the workings shown as
“active” in 1999 have since closed down. There are currently eight active
quarries in the Black Country. Two of these produce aggregates (sand), and
the others produce brick clay (Etruria Marl).
3.10 The Black Country’s active quarries/ clay pits are listed below.
Aggregates (Sand):
• Aldridge Quarry, Birch Lane, Stonnall, Walsall (Cemex)
• Branton Hill Quarry, Aldridge, Walsall (Bliss Sand & Gravel)
Brick Clay (Etruria Marl):
• Highfields South Quarry, Aldridge, Walsall (Cory)
• Sandown Quarry, Aldridge, Walsall (Wienerberger)
• Dumblederry Farm Quarry, Aldridge, Walsall (Ibstock)
• Oak Farm Clay Pit, Kingswinford, Dudley (Baggeridge)
• Himley Quarry, Kingswinford, Dudley (Cory/ Baggeridge)
• Ketley Quarry, Kingswinford, Dudley (Hinton, Perry & Davenhill/ Ketley
Brick/ Baggeridge)
3.11 The Black Country currently has five brick works, three of which are
associated with clay pits in Walsall and are operated by major brick producers
6 Articles 6 and 7, Directive EC/92/43/EEC on the conservation of natural habitats and of wild fauna and flora
(Habitats Directive): http://www.jncc.gov.uk/page-1374, see also Regulation 48, The Conservation (Natural Habitats &tc.) Regulations 1994 http://www.opsi.gov.uk/si/si1994/Uksi_19942716_en_1.htm (SI 1994 No. 2716)
12
(Aldridge Works and Atlas Works by Ibstock and Sandown Works by
Wienerberger). Oak Farm, Himley and Ketley Quarries supply the Fir Street
Works in South Staffordshire, which is operated by Baggeridge. The other two
brick works (Dreadnought Works – operated by Hinton, Perry & Davenhill and
Ketley Brick - and Cradley Special Brick) are operated by local companies
producing special tiles and bricks in relatively small quantities. Two clay pits
(Highfields South and Himley) are now nearing the end of their operational life
and Highfields South is no longer producing clay for brick making.
3.12 The adopted Dudley and Walsall UDPs have defined fairly generous
mineral safeguarding areas (MSAs) around each of the above quarries. These
are shown on the UDP Proposals Maps and are subject to in Dudley UDP
Policy M1 and Walsall UDP Strategic Policy Statement paragraph 9.2 and
Walsall UDP Policy M1. At present, no other mineral resources in the Black
Country are safeguarded against sterilisation by non-mineral development,
although in principle, the Dudley, Sandwell, Walsall and Wolverhampton
UDPs all allow for the extraction of minerals in advance of redevelopment to
prevent sterilisation.
Primary Minerals – Regional Requirements and Local Supplies
3.13 Permitted reserves of sand and gravel are declining, both nationally
and regionally. In England as a whole, reserves have declined from 897
million tonnes in 1993 to 648 million tonnes in 2004.7 The decline is
considered to be caused by the lack of planning permissions for extraction
between 1997 and 2002, and the consequent depletion of reserves through
sales.
3.14 Over the same period, there has been a corresponding, but less sharp,
decline in reserves in the West Midlands region: in 1993 the regional reserves
were estimated to be 202 million tonnes, compared to around 181 million
tonnes in 2004. Reserves have also steadily declined within the West
7 Section 3.1, Section 3.6 and Figure 16, Primary Aggregate Reserves in England 1990 – 2004 (2006), British
Geological Survey – published on UK Minerals website: http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html
13
Midlands Metropolitan area from around 3.7 million tonnes in 2001 to around
2.5 million tonnes in 2004. At present, the only authorities that contribute to
the sub-regional sand and gravel apportionment – and therefore to the stock
of reserves – are Solihull MBC and Walsall Council.
Table 1: Primary Aggregates (Sand) Supplies in the Black Country, March 2007
Current Annual
Requirement for
Black Country
(tonnes)
Permitted Reserves
@ March 2007
(tonnes)
Current Landbank
@ March 2007
Estimated Resource
in MSAs (not
permitted) @ March
2007 (tonnes)
50,0008 150,000
9 2-3 years
10 3,000,000
11
Table 2: Brick Clay Supplies in the Black Country, March 2007
Current Annual
Requirement for
Black Country
(tonnes)
Permitted Reserves
@ March 2007
(tonnes)*
Current Supplies to
Brickworks @
March 2007*
Estimated Resource
in MSAs (not
permitted) @ March
2007 (tonnes)
N/A 8,000,00012
5-30 years13
N/K
3.15 Early in 2007, Dudley MBC, Sandwell MBC and Walsall Council
commissioned Scott Wilson to undertake an up-to-date survey of mineral
reserves within active quarries and within the existing MSAs defined in the
Dudley and Walsall UDPs. The results of this are set out in A Survey of
Current Mineral Resources in the Black Country – Published Report
(March 2007), which is available on the Black Country Core Strategy website.
8 See Note 6 above
9 See Survey of Current Mineral Reserves in the Black Country: Published Report (March 2007), Scott Wilson -
published on Black Country Core Strategy website: http://blackcountrycorestrategy.dudley.gov.uk/. This shows that supplies to brickworks vary from less than 5 years’ worth of production to more than 30 years’ worth. 10
Ibid. 11
Ibid. There is a current application for an extension to Branton Hill Quarry, which covers most of the unexploited area within the MSA, to the south of the existing quarry/ recycling business. 12
See Note 8 above. 13
See Note 8 above.
14
The current position is summarised in Tables 1 and 2 above. This shows that
the Black Country’s current sand and gravel landbank falls short of what is
required by MPS1 and the RSS and that in some cases, the supply of clay to
Black Country brickworks also falls short of what is required by MPS1.
3.16 It is estimated that there are sufficient resources available within the
sand and gravel MSAs in Walsall to meet the Black Country’s share of the
current sub-regional apportionment up to 2026 and beyond.14 However, it is
not certain when or indeed if these resources will actually come forward
through acceptable planning applications. As has been noted above
(paragraphs 3.6 – 3.7), groundwater source protection zones may be a
significant constraint to future extraction of sands and gravels and/ or the
restoration of sites to safe and acceptable standards after working has
ceased. The recent survey of mineral reserves was unfortunately unable to
establish the extent of the remaining brick clay resources within the MSAs, as
operators could not be certain about the quality of the clay.
Primary Minerals – Production, Sales and Consumption
Sand and Gravel
3.17 The aggregates industry is currently dominated by a handful of key
players, of which only two - CEMEX and Tarmac – are currently represented
within the Black Country, although others, such as Lafarge, operate quarries
nearby. It is estimated that seven companies currently account for about 85%
of aggregate production in England and Wales. Other than these, there are
around 100 smaller, local operators, like Bliss Sand & Gravel who operate
Branton Hill Quarry in Aldridge, Walsall. Operators are represented by two
main trade bodies: the Quarry Products Association and the British
Aggregates Association.15
14
Based on the assumption that Solihull will continue to provide around 90% of the sub-regional apportionment for the West Midlands Metropolitan area (i.e. 0.506 million tonnes per annum) until 2011, as required by the current RSS. However, the position post-2011 is uncertain and will depend on resources coming forward through new permissions. 15
See 2.1.4, Planning 4 Minerals: A Guide on Aggregates (2006), Quarry Products Association, British Marine Aggregate Producers’ Association, British Geological Survey and Entec Ltd, available on Planning 4 Minerals website: http://www.bgs.ac.uk/planning4minerals/Downloads.htm
15
3.18 Information is available on sand and gravel production/ sales in the
Black Country during 2005, but unfortunately this cannot be published other
than in collated form, for reasons of commercial confidentiality. However,
figures are available for the UK as a whole, for the West Midlands region and
for the West Midlands Metropolitan area.
3.19 The amount of primary land-won sand and gravel produced annually in
the UK fell between 1999 and 2004, from around 80.3 million tonnes to
around 78.1 million tonnes.16 Although sales of sand and gravel within the
West Midlands region have declined significantly since the 1970s, between
1997 and 2005, annual sales appear to have levelled off at between 9 and 10
million tonnes. During the same period, the tonnages consumed appear to
have been slightly less than the amounts sold, between 8 and 9.5 million
tonnes.17 The latest published information for the West Midlands Metropolitan
area is for 2004, when it was estimated that around 0.5 million tonnes of sand
and gravel were sold, roughly equivalent to the annual sub-regional supply
requirement.18
Bricks and Clay
3.20 There is no published information on the demand for brick clay or sales
of bricks, blocks and tiles within the Black Country. Within the UK as a whole
(excluding Northern Ireland), between 1999 and 2004, production of clay and
shale has fluctuated between 10.3 and 11.4 million tonnes, and in 2005 was
estimated to be around 10 million tonnes.19 In 2004, the latest year for which
regional figures are available, around 2.6 million tonnes of clay and shale
were produced in the West Midlands region, of which 2.1 million tonnes was
16
See page 9, United Kingdom Minerals Yearbook 2005: Statistical Data to 2004 (2006), published on UK Minerals website: http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html 17
See Appendix D, Tables D1 and D2, Collation of the Results of the 2005 Aggregate Minerals Survey for England and Wales (May 2007), British Geological Survey, published on DCLG website: http://www.communities.gov.uk/index.asp?id=1510949 18
See West Midlands Regional Aggregates Working Party (RAWP) Annual Report 2004, published on DCLG website: http://www.communities.gov.uk/index.asp?id=1502818 19
See page 9, United Kingdom Minerals Yearbook 2005: Statistical Data to 2004 (2006), published on UK Minerals website: http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html. Also see page 32 for production of clay and shale by region.
16
used to make bricks, pipes and tiles. Future monitoring will show whether this
level of production can be sustained.
3.21 Production appears to fluctuate from year to year. Overall, production
appears to have declined nationally between 1995 and 2005. Within the UK
as a whole (excluding Northern Ireland), 2,601 million clay bricks were
produced in 2005, compared to 2,707 million in 2004 and 3,256 million in
1995. In 2004, the latest year for which regional figures are available, 624
million bricks were produced in the West Midlands, more than in any of the
other English regions, Scotland or Wales. The decline in brick production is
also less sharp in the West Midlands than anywhere else. Production appears
to have increased in 2004 compared to previous years, and appeared to
moving back towards the 1995 level of 649 million.20
3.22 There has been a considerable amount of consolidation within the brick
industry in recent years, and production of bricks, blocks and tiles is now
dominated by a handful of major national and international companies, of
which three – Baggeridge, Ibstock and Wienerberger – have a presence in the
Black Country. The pool of operators is about to shrink even further, as
Wienerberger are proposing to take over Baggeridge, following clearance by
the Competition Commission in May 2007.
3.23 The Commission’s provisional findings report, published in April 2007,
includes an Appendix which provides an up-to-date overview of the brick
industry, based on information provided by the major operators.21 This
confirms that there has been a slow decline in the demand for bricks over the
last 50 years, which does not seem to relate to the number of houses built. It
is not entirely clear why this is the case, but the suggestions offered by the
operators are that changes in the types of housing built and the materials
20
Ibid, page 27.
21 Provisional Findings Report, Wienerberger Finance Service BV / Baggeridge Brick plc (April 2007), Competition
Commission, published on their website: http://www.competition-commission.org.uk/inquiries/ref2006/wienerberger/provisional_findings.htm
17
used to build new homes (both structural and cladding materials) may be to
blame.
3.24 The influence of “the planners” in specifying particular building
materials and claddings was considered to be an important factor in the
demand – or lack of it – for bricks. Operators also expressed concern about
the difficulties of obtaining permission for new quarries.
Secondary and Recycled Aggregates
3.25 There are believed to be six producers of secondary/ recycled
aggregates in the Black Country, but it is not known how many mobile
crushers are operating within the area in addition to these. The following
processing facilities have been identified:
• Glenside Recycling, Smethwick, Sandwell
• Midland Quarry Products, Bescot, Walsall
• Bliss Sand & Gravel, Branton Hill Quarry, Aldridge, Walsall
• AB Skip Hire, Darlaston, Walsall
• Stichacre Ltd, Bilston, Wolverhampton
• Tarmac Recycling Services, Ettingshall, Wolverhampton
3.26 There is currently no information available on the amount of secondary
and recycled aggregate produced in the Black Country. However, a recent
national survey of alternatives to primary aggregates in England in 2005 by
Capita Symonds provides some indication of the quantities produced at the
regional and sub-regional level. Two separate reports have been published,
one on the production of aggregates from construction, demolition and
excavation wastes (recycled aggregates), and the other on the production of
aggregates from “other” materials, including quarry and colliery wastes,
bottom ash and glass (secondary aggregates).22
22
Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005: Construction, Demolition and Excavation Waste and Survey of Arisings and Use of Alternatives to Primary Aggregates in England 2005: Other Materials (February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG, published on DCLG website: http://www.communities.gov.uk/index.asp?id=1508123 and http://www.communities.gov.uk/index.asp?id=1508126.
18
3.27 The report on construction, demolition and excavation wastes
estimates that in 2005, there were 96 crushers in the West Midlands region,
and that during 2005 they produced 4.45 million tonnes of secondary/
recycled aggregate and 1.90 million tonnes of recycled soil from around 9.84
million tonnes of construction and demolition waste. The same survey
estimated that 33 of these crushers were located in Birmingham and the Black
Country, and that during 2005 they produced around 1.51 million tonnes of
secondary/ recycled aggregates and around 0.81 million tonnes of recycled
soil from around 2.88 million tonnes of construction and demolition waste.23
3.28 The report on other materials estimates that in 2005, 0.61 million
tonnes of these materials were used as aggregate in the West Midlands
region, out of a total 2.13 million tonnes of materials arising. The materials
used were: ceramic waste, colliery spoil, power station/ incinerator bottom
ash, pulverised fuel ash and used railway ballast. Of this, only 0.19 million
tonnes was used as aggregate in Birmingham and the Black Country, out of a
total of 0.36 million tonnes of material arising within the same area.24
3.29 This suggests that recycled construction and demolition waste is
currently making a significant contribution towards the supply of aggregates in
Birmingham and the Black Country – a conclusion that is also supported by
another recent study into the production of recycled and secondary
aggregates in the West Midlands Metropolitan area by the Waste and
Resources Action Programme (WRAP).25 Indeed, the WRAP survey suggests
that the recovery and recycling of construction, demolition and excavation
wastes for aggregate is already occurring at the optimum rate that is 23
Tables A10.4 and A11.12, Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005: Construction, Demolition and Excavation Waste (February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG, published on DCLG website: http://www.communities.gov.uk/index.asp?id=1508123. This relates to a survey of operators of crushers, screens and licensed landfill sites in 2005, and follows on from previous surveys carried out in 1999, 2001 and 2003. Although the national estimates in the report are considered to be robust, the regional and sub-regional estimates are considered to be less so, due to the response rates not being high enough. The report therefore warns that the sub-regional figures – including that for Birmingham and the Black Country - should not be relied upon other than as a “reasonable indication” of arisings and recycling of construction and demolition waste. 24
Annex 2, Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005: Other Materials (February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG, published on DCLG website: http://www.communities.gov.uk/index.asp?id=1508126. 25
The Sustainable Use of Resources for the Production of Aggregates in England (2006), WRAP, published on AggRegain website: http://www.aggregain.org.uk/templates/temp_agg_publication_details.rm?id=2298&publication=3337
19
economically viable, and that recovery rates are unlikely to improve much in
the future, other than in the case of soils.
3.30 However, the contribution made by secondary aggregates in the West
Midlands appears to be much less significant. The results of the Capita
Symonds survey suggest that as the amount of secondary material arising is
relatively small, this is unlikely to make a major contribution towards future
aggregates supply.
20
4. Consultation Responses
4.1 Various people and organisations have commented on minerals and
related issues, both through individual responses, at the Launch Event on 6
December 2006, and at a Minerals and Waste Stakeholder Event on 29
March 2007.26 At the latter event stakeholders were invited to comment on an
earlier draft of the minerals issues and options.
4.2 Through these events and other meetings/ contacts, we have also
discussed the key issues relating to minerals with representatives from the
Environment Agency, British Geological Survey, West Midlands Regional
Aggregates Working Party, Black Country Geodiversity Partnership, quarry
operators and adjoining mineral planning authorities. The issues and options
in the consultation document reflect the outcome of these discussions.
4.3 The key issues identified by stakeholders are as follows:
a) Minerals are a key issue – not peripheral;
b) Minerals and waste need to be considered together to ensure
consistent approach towards overlapping issues e.g. resource
management, recycling, waste minimisation, restoration/landfill;
c) Public perception/ negative image of mineral extraction is an important
problem and a barrier to bringing forward new reserves - need for
better understanding of the importance of minerals to society and the
local economy;
d) Need to adopt a flexible approach towards planning for minerals in the
Black Country – cannot predict future needs of building industry with
certainty;
26
Event Reports published on Black Country Core Strategy website: http://blackcountrycorestrategy.dudley.gov.uk/
21
e) Should safeguard known mineral resources in the Black Country
against sterilisation by other development by identifying new MSAs
(including “buffer zones”) that cover all known mineral resources where
they exist/ identifying locations for future mineral extraction;
f) Should identify locations within the Black Country where extraction will
take place, to maintain regional self-sufficiency and local availability of
supplies in the longer-term and reduce dependence on importation of
materials/ the need to transport them long distances;
g) Where suitable opportunities exist, should encourage minerals and
other bulky materials to be transported by rail or inland waterways
rather than via the local highway network;
h) Where possible, extensions to existing sites/ permissions and mineral
safeguarding areas are preferable to new permissions for mineral
extraction in areas that are currently unaffected;
i) Should allow small-scale extraction of coal and other minerals prior to
redevelopment, within areas where reserves are known to be present,
to avoid sterilisation;
j) Should reflect the importance of secondary/ recycled aggregates in
meeting future requirements, by making provision for increased
production and restricting quantities of inert construction and demolition
waste sent to landfill;
k) Need to consider wider issues relating to use and conservation of
mineral resources, such as re-use and recycling of buildings and
building materials – suggestion that we include targets for re-used/
recycled materials in new developments;
l) Need to address implications of new housing/ economic development
proposed in the Black Country for minerals, such as likely need/
22
demand for primary mineral resources as well as alternatives, and
maximising recycling of construction and demolition waste;
m) Need to protect existing secondary and recycled aggregates production
facilities from other development where these are well located (e.g.
within strategic corridors);
n) Environmental quality is an important issue for the Black Country -
impacts of mineral extraction are long-term, therefore need to minimise
adverse effects and maximise benefits (e.g. opportunities for
recreation) and secure timely/ appropriate restoration and after-use;
o) Mineral extraction should respect wildlife corridors and other important
environmental assets, and restoration schemes should be designed to
be beneficial for biodiversity, geodiversity (e.g. maintaining exposures
of important geological features) and the local landscape;
p) Where mineral resources are within groundwater protection zones or
near to surface watercourses (including canals), need to have policies
in place that will prevent pollution from mineral extraction and
subsequent restoration, and possible damage to the canal network
arising from mineral extraction;
q) The need to restore former mineral workings by landfill may contribute
to climate change where the fill includes biodegradable waste – where
this is the case, landfill gas should be safely extracted and used to
generate energy;
r) Core Strategy should be followed-up by detailed policies set out in
another DPD (but no consensus on whether it should be a joint Black
Country Minerals and Waste DPD, or separate plans for each area).
23
Bibliography
Policy Documents
Title
URL
Directive EC/92/43/EEC on the conservation of natural habitats and of wild fauna and flora (Habitats Directive)
http://www.jncc.gov.uk/page-1374
The Conservation (Natural Habitats &tc.) Regulations 1994 (SI 1994 No. 2716)
http://www.opsi.gov.uk/si/si1994/Uksi_19942716_en_1.htm
Minerals Policy Statement 1 (MPS1): Planning and Minerals (November 2006), DCLG
http://www.communities.gov.uk/index.asp?id=1504275
Planning and Minerals: Practice Guide (November 2006), DCLG
http://www.communities.gov.uk/index.asp?id=1504283
National and Regional Guidelines for Aggregates Provision in England 2001 -2016 (June 2003), ODPM
http://www.communities.gov.uk/index.asp?id=1144267
National and Regional Guidelines for Aggregates Provision in England 2001 -2016: Third Monitoring Report (September 2006), DCLG
http://www.communities.gov.uk/index.asp?id=1503133
Landfill Directive Regulatory Guidance Note 3 (RGN3) - Groundwater Protection: Locational Aspects of Landfills in Planning Consultation Responses & Permitting Decisions (December 2002), Environment Agency
http://www.environment-agency.gov.uk/business/1745440/444663/landfill/1764524/1693182/475339/?version=1&lang=_e
Regional Planning Guidance for the West Midlands (RPG11) (June 2004), Government Office for the West Midlands
http://www.wmra.gov.uk/page.asp?id=49
Dudley Unitary Development Plan 2005 (October 2005), Dudley MBC
http://www.dudley.gov.uk/environment--planning/planning/unitary-development-plan
Sandwell Unitary Development Plan 2004 (April 2004), Sandwell MBC
http://sandwelludp.wisshost.net/
Solihull Unitary Development Plan 2006 (February 2006), Solihull MBC
http://www.solihull.gov.uk/section.asp?docid=813&catid=1949
Walsall Unitary Development Plan 2005 (April 2005), Walsall Council
http://www.walsall.gov.uk/index/environment/planning/unitary_development_plan.htm
Wolverhampton Unitary Development Plan 2006 (June 2006), Wolverhampton City Council
http://www.wolverhampton.gov.uk/environment/planning/policy/udp/
Dudley Borough Challenge: Community Strategy http://www.dudleylsp.org/c
24
2005 - 2020 (2006), Dudley Community Partnership
ommunity-strategy
The Sandwell Plan 2006 (May 2006), Sandwell Partnership
http://www.laws.sandwell.gov.uk/ccm/content/corporateservices/regeneration/sandwellplanfull.en
2005-2010 Walsall’s Community Plan: Working Together for a Stronger Future (2005), Walsall Borough Strategic Partnership
http://www.wbsp.org.uk/wbsp-index.htm/wbsp-community_plan.htm
Moving On: Wolverhampton’s Community Plan 2002-2012 (2002), Wolverhampton Partnership
http://www.wton-partnership.org.uk/inovem/inovem.ti/text?page=communityplan
The Black Country Geodiversity Action Plan - Leaflet (2006), Black Country Geodiversity Partnership
http://www.laws.sandwell.gov.uk/ccm/content/urbanform/planninganddevelopment/ldf/supplementary-planning-documents/black-country-geodiversity-action-plan.en
Sources of Baseline Information
Title
URL
The Economic Importance of Minerals to the UK (2004), British Geological Survey/ ODPM
http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html
Planning 4 Minerals: A Guide on Aggregates (2006), Quarry Products Association, British Marine Aggregate Producers’ Association, British Geological Survey and Entec Ltd
http://www.bgs.ac.uk/planning4minerals/Downloads.htm
United Kingdom Minerals Yearbook 2005: Statistical Data to 2004 (2006), British Geological Survey
http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html
Annex C, Provisional Findings Report, Wienerberger Finance Service BV / Baggeridge Brick plc (April 2007), Competition Commission
http://www.competition-commission.org.uk/inquiries/ref2006/wienerberger/provisional_findings.htm
Primary Aggregate Reserves in England 1990 – 2004 (2006), British Geological Survey
http://www.bgs.ac.uk/mineralsuk/free_downloads/home.html
The Sustainable Use of Resources for the Production of Aggregates in England (2006), WRAP
http://www.aggregain.org.uk/templates/temp_agg_publication_details.rm?id=2298&publication=3337
Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005: Construction, Demolition and Excavation Waste
http://www.communities.gov.uk/index.asp?id=1508123
25
(February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG Survey of Arisings and Use of Alternatives to Primary Aggregates in England 2005: Other Materials (February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG
http://www.communities.gov.uk/index.asp?id=1508126
Mineral Resource Information for Development Plans – West Midlands: Resources and Constraints (Birmingham, Coventry, Dudley, Sandwell, Solihull, Walsall and Wolverhampton) (1999), British Geological Survey
NOT AVAILABLE ONLINE
West Midlands Regional Aggregates Working Party (RAWP) Annual Report 2004
http://www.communities.gov.uk/index.asp?id=1502818
Survey of Current Mineral Reserves in the Black Country: Published Report (March 2007), Scott Wilson
http://blackcountrycorestrategy.dudley.gov.uk/
A Geological Background for Planning and Development in the Black Country: Technical Report WA/92/33 (1992), British Geological Survey - covers all of Dudley and Sandwell but only parts of Walsall and Wolverhampton
NOT AVAILABLE ONLINE
1:50,000 Solid and Drift Geology Maps and Memoirs covering Lichfield (E154) and Wolverhampton and Telford District (E153) covering the northern parts of Walsall and Wolverhampton (various dates), British Geological Survey
NOT AVAILABLE ONLINE
Dudley Annual Monitoring Reports 2005 and 2006
http://www.dudley.gov.uk/index.asp?pgid=15841
Sandwell Annual Monitoring Reports 2005 and 2006
http://www.laws.sandwell.gov.uk/ccm/content/urbanform/planninganddevelopment/unitary-development-plan/unitary-development-plan-review---annual-monitoring-report-2005-6.en
Walsall Annual Monitoring Report 2006 http://www.walsall.gov.uk/index/environment/planning/local_development_framework/ldf_annual_monitoring_report.htm
Wolverhampton Annual Monitoring Reports 2005 and 2006
http://www.wolverhampton.gov.uk/environment/planning/policy/ldf/AMR.htm
26
Consultation and Engagement
Title
URL
Black Country Core Strategy Launch Event, 6 December 2006 (January 2007), Black Country Authorities
http://blackcountrycorestrategy.dudley.gov.uk/how-can-i-get-involved/launch-event
Black Country Core Strategy Minerals & Waste Event, 29 March 2007 (April 2007), Black Country Authorities
http://blackcountrycorestrategy.dudley.gov.uk/how-can-i-get-involved/other-events/minerals-waste
Black Country Core Strategy
Submission Document
Minerals Background Paper Version 2 (Revised)
February 2010
1
Further Information
Black Country Minerals Policy Contacts
David Piper
Dudley MBC
Tel: 01384 814173
Email: [email protected]
Mohammed Salim
Sandwell MBC
Tel: 0121 569 4018
Email: [email protected]
Dawn Harris
Walsall Council
Tel: 01922 652482
Email: [email protected]
Craig Rowbottom
Wolverhampton City Council
Tel: 01902 552177
Email: [email protected]
Front cover illustrations: Brownhills Miner and Ibstock Quarry, Aldridge. Picture of quarry
taken by Walsall MBC with kind permission of Ibstock Brick Ltd.
2
BLACK COUNTRY CORE STRATEGY
SUBMISSION DOCUMENT
Minerals Background Paper - Version 2 (Revised)
February 2010
Contents Main Report – Sections Pages
1. Introduction 4 – 6
2. Policy MIN1: Managing and Safeguarding Mineral Resources 7 – 22
2.1 Mineral Safeguarding Area (MSA) 7 – 13
2.2 Mineral Safeguarding Policy 13 – 22
3. Policy MIN2: Production of Aggregate Minerals 23 – 45
3.1 Secondary and Recycled Aggregates 23 – 30
3.2 Primary Land Won Aggregates 31 – 45
4. Policy MIN3: Maintaining Supplies of Brick Clay 46 – 61
5. Policy MIN4: Exploitation of Other Mineral Resources 62 – 77
5.1 Coal and New Coal Based Energy Technologies 62 – 73
5.2 Natural Building Stone 73 – 77
6. Policy MIN5: New Proposals for Mineral Development 78 – 85
Bibliography 86 – 93
Glossary 94 – 104
3
Pages
List of Figures
Figure M1: Estimated Recycled Aggregate and Soil
Production in the Black Country 2001 - 2005
27
Figure M2: Primary Aggregates Apportionments and
Sales in the West Midlands County Area 1998 - 2007
35
Figure M3: Primary Aggregates Landbanks in the
West Midlands County Area 1998 - 2007
36
List of Tables
Table M1: Changes to Minerals Policy Areas following
Preferred Options
6
Table M2: Replacement of Existing MSAs by the Core
Strategy MSA
13
Table M3: Producers of Alternative Materials
(Secondary and Recycled Aggregates) in the Black
Country
25 – 26
Table M4: West Midlands County Area Sub-Regional
Sand and Gravel Apportionment – Assumed Provision
to 2011
35
Table M5: West Midlands County Sand and Gravel
Apportionment Review - Comparison of Remaining
WMRAWP and Land Use Consultants Options @
February 2010
38
Table M6: Resource Requirements for Sand & Gravel
Landbank to 2026
42
Appendices
For Appendices 1 – 4 see separate document
4
1. Introduction
1.1 This document explains the background to the development of the Core
Strategy minerals policies MIN1 – MIN5, and provides an overview of the
technical evidence underpinning the policies. An earlier version of this document
was produced at the publication stage (November 2009), and it has been
subsequently updated and revised where appropriate, for Submission (February
2010).
1.2 The main technical study on minerals is the Black Country Core Strategy
Minerals Study by RPS Planning and Development Ltd (Black Country Minerals
Study). The study included an analysis of geological and mineral resource
information, and provided a comprehensive summary of the complex geology of
the area and identified the mineral resources that are or may become of
economic importance in the future.
1.3 However, since the Study was published in March 2008, new national and
regional guidance has been published, new evidence has come forward on
certain issues, and stakeholder engagement has continued. This paper
summarises the key developments that have occurred since the Study was
published, which have had a bearing on the development of the minerals
policies. At Submission stage (February 2010) the authorities put forward number
of Proposed Changes to the minerals policies for clarification, to correct factual
inaccuracies, and/ or to address comments by stakeholders on the Publication
document. Significant Proposed Changes are summarised in blue text.
1.4 The main policy changes of relevance to minerals have been the issue of
the revised PPS12: Local Spatial Planning, new national and regional aggregates
guidelines, the RSS Phase 2 Revision Options, and the emergence of proposals
for a review of the sub-regional aggregates apportionments just before the Core
Strategy was published. The Core Strategy minerals policies have been
influenced by these recent policy developments.
5
1.5 New coal resource information has become available, as has information
on prior extraction of minerals. The evidence base for aggregates and brick clay
supply has also been updated, reflecting the latest WMRAWP surveys and
further discussions with brick manufacturers.
1.6 Throughout the Core Strategy preparation process, the authorities have
also been engaging with key stakeholders on key mineral issues. The
Consultation Report (November 2009) summarises the meetings, events and
correspondence which has taken place since the Core Strategy was first
launched at the end of 2006.
1.7 During the preparation of the minerals policies, a number of cross-cutting
issues were also identified. Some of these have been taken on board in other
technical work such as the Black Country Core Strategy Phase Two
Infrastructure and Deliverability Study by Mott MacDonald (November 2009), and
have fed through into other Core policy areas.
1.8 The spatial objective for minerals (Spatial Objective 10), and the overall
strategy for managing mineral resources in Policy MIN1 have developed out of
the vision and objectives for minerals identified during the Minerals & Waste
Stakeholder Event which took place in March 2007, and from the technical work
and ongoing stakeholder engagement which has taken place since then.
Sustainability Objective 12 embraces the prudent and efficient use of mineral
resources, and the emerging minerals policies have also been subjected to and
influenced by sustainability appraisal. The appraisal indicates that the published
minerals policies are likely to have either neutral or positive effects.
1.9 The mineral policies themselves have evolved since the Preferred
Options, and in some cases the core policy areas have changed in response to
stakeholder comments or new evidence. For example, the policies on mineral
safeguarding, aggregates and brick clay remain much the same, but CPA 24:
Prudent Use of Mineral Resources is now addressed in waste policy WM5. Table
M1 below shows how the Preferred Options Core Policy Areas have been
translated into Core Policies in the publication document.
6
1.10 The evidence and recommendations of the Black Country Minerals Study,
new information which has become available since the Study was published,
further stakeholder engagement, and the results of sustainability appraisal have
all helped to shape the final Core Strategy minerals policies. The following
sections explain the background to each policy and the evidence which has
informed its development.
Table M1: Changes to Minerals Policy Areas following Preferred Options
Core Strategy - Preferred Options Core Strategy - Publication
CPA19: Safeguarding the Black Country’s Minerals Resources
Policy MIN1, MIN5
CPA20: Maintaining a Continued Supply of Aggregate Minerals in the Black Country
Policies MIN2, MIN5, WM4, WM5
CPA21: Supply of Clay to Brickworks Policies MIN3, MIN5
CPA22: Energy Minerals Policies MIN4, MIN5
CPA23: Natural Building Stone Policies MIN4, MIN5
CPA24: Prudent Use of Mineral Resources
Policy WM5
7
2. Policy MIN1: Managing and Safeguarding Mineral
Resources
2.1 Mineral Safeguarding Areas (MSAs)
Black Country Minerals Study – Key Findings and Recommendations
2.1.1 Safeguarding and avoiding needless waste of mineral resources are of
particular importance in addressing Core Strategy Sustainability Objectives 3 and
12. The main source of evidence on the extent of mineral resources in the Black
Country is the Black Country Minerals Study by RPS Planning & Development
Ltd. The Study used the best and most up-to-date geological and mineral
resource data available at the time, and identified the following mineral resources
of potential economic importance:
• Sands and gravels (bedrock and superficial)
• Brick clays (in particular Etruria Marl)
• Dolerite
• Limestone
• Building stone (various)
• Coal Measures (and associated fireclay)
(See Sections 4.7 – 4.12 of the Study)
2.1.2 The Study recommended that options for mineral safeguarding should be
further developed by:
• Confirming that the appropriate resource types are included in the
proposed mineral safeguarding areas (MSAs),
• Further refining the MSAs proposed in the study, and
8
• Considering how the proposed MSAs may be incorporated into the Core
Strategy through the Key Diagram, safeguarding policy and identification
of areas for future mineral working (see paragraph 5.6.2)
It also recommended that existing mineral related infrastructure such as
recycling/ processing sites and transport infrastructure should be safeguarded
(see paragraphs 1.3.36 and 1.3.42).
Baseline Evidence - Update
2.1.3 The Black Country Minerals Study used the best evidence available at the
time it was prepared, which was principally the geological mapping and memoirs
and mineral resource information covering the Black Country published by the
British Geological Survey (BGS). However, since the publication of the Study,
there have been further developments in policy and evidence which had to be
taken on board in the development of MSAs:
• New surface coal resource information has become available1 from
the Coal Authority under a licence agreement which allows them to use it
for planning purposes.
• Options for the RSS Phase 3 Revision (June 2009)2 considered options
for defining regional MSAs. The consultation paper specifically identified
aggregates, brick clay and natural building stone as resources that could
be included.
2.1.4 The Black Country authorities did not ask RPS to define the mineral
commodity areas in detail in the Black Country Minerals Study, because at the
time the project was commissioned, they had been advised by the Government
Office for the West Midlands that they only had to define the “broad extent” of
MSAs in the Core Strategy. However, the requirement to publish submission
1 See paragraph 4.10.7 of the Black Country Minerals Study report
2 The RSS Phase 3 Revision has now been abandoned and the mineral safeguarding elements
are to be incorporated into the new single Regional Strategy – see WMRSS Update Phase 3 Special (November 2009).
9
Proposals Maps for each authority has meant that a detailed MSA boundary has
also had to be defined.
2.1.5 Due to time and resource constraints it was not possible to commission
further work on refining the boundaries of the mineral resource areas, or to
undertake further stakeholder consultation, which was originally planned. In
refining the MSAs for the Proposals Maps, the authorities have relied mainly on
the Proposed Mineral Safeguarding Areas recommended in the Black Country
Minerals Study, the surface coal resource mapping which has subsequently
become available from the Coal Authority, and the underlying BGS geological
mapping.
Stakeholder Engagement
2.1.6 There has been extensive engagement with stakeholders on the form and
extent of MSAs. During the engagement process, stakeholders made the
following comments:
• The BGS advised that all mineral resources should be safeguarded unless
there is clear evidence that they are not likely to be of economic
importance;
• The GO-WM advised that the “broad extent” of MSAs should be shown on
the Core Strategy Key Diagram or a supplementary Key Diagram, and that
detailed boundaries should be shown on the Proposals Maps for each
authority;
• The GO-WM, BGS and Coal Authority have all advised that MSAs should
not exclude urban areas if there is evidence that mineral resources are
present;
• The Planning Inspectorate (PINS) advised that the broad extent of MSAs
should be shown on the Key Diagram or a supplementary Key Diagram.
They also advised that if MSA boundaries are not defined in detail on the
10
Proposals Map accompanying the Core Strategy, the strategy should
explain how and where they will be defined;
• The BGS and Coal Authority have both expressed the view that the Core
Strategy should include separate MSAs (or at least separate illustrative
plans) showing different mineral types;
• Neighbouring MPAs appear to be uncertain about where MSAs should go,
although they have accepted the need to define detailed resource areas
for each mineral type;
• Some stakeholders commented that the MSAs proposed in the Preferred
Options (as recommended in the Black Country Minerals Study) were too
detailed and complicated for a Core Strategy;
• Mineral industry representatives felt there should be separate MSAs for
each mineral type or commodity and that these should be refined in
consultation with them.
Review of “Best Practice”
2.1.7 The authorities have reviewed current best practice as set out in the BGS
good practice guidance,3 and as reflected in “sound” minerals core strategies and
other emerging core strategies (including those prepared by Cumbria CC,
Lancashire CC, Suffolk CC and Coventry City Council).
2.1.8 They have noted that the MPAs concerned have generally defined a
single MSA on their Key Diagram and Proposals Map. However, in most cases
the mineral resources identified are far less extensive and complicated than they
are in the Black Country. The Black Country is probably unique in having
extensive and complex mineral resources underlying a major urban area.
3 A guide to mineral safeguarding in England (2007), BGS
11
Developing the Black Country MSA
2.1.9 As recommended by the Black Country Minerals Study, the authorities
considered possible options for defining MSAs in the Core Strategy. This took
into account evidence which became available following the Study, comments
made by stakeholders, and best practice in other MPA areas. The options
identified were as follows:
1. Define separate MSAs covering each mineral type;
2. Define a single MSA for the Black Country covering all mineral resources.
2.1.10 As the Black Country Minerals Study shows, the Black Country’s geology
is very complicated. The Black Country Geodiversity Action Plan has also
recognised that relative to its area, the Black Country has the most diverse
geology of anywhere in the world.4 There are mineral resources of one sort or
another underlying almost the whole of the area, including the Growth Network
where most of the non-mineral development is proposed to take place between
now and 2026.
2.1.11 In the light of the advice from PINS, it was decided to prepare a separate
Minerals Key Diagram showing MSAs and other minerals proposals. However,
having attempted to map separate MSAs for each mineral type, the Black
Country authorities came to the conclusion that this did not work, and that the
stakeholders who had commented on the complexity of the MSAs proposed in
the Preferred Options were right.
2.1.12 The Black Country’s mineral resources are too complex to show
separately and with clarity on a Key Diagram or Proposals Map alongside all the
other designations that have to be included on these maps. Furthermore, some
mineral resources are overlapping others, making it difficult to show everything
on a single plan even without the other designations.
4 See leaflet on the Black Country Geodiversity Action Plan 2006/07 (2007), Black Country
Geodiversity Partnership
12
2.1.13 In view of this, the authorities have decided that Option 2 is the most
appropriate approach for the Black Country. The broad extent of the MSA is
therefore shown on the Minerals Key Diagram and the detailed MSA boundary
(based on BGS mineral resource mapping) is shown on the Proposals Maps for
each authority. However, the need for separate illustrative maps showing the
extent of each mineral resource type or commodity is also accepted.
2.1.14 Options for mapping the mineral commodities were discussed with the
BGS and the Coal Authority. The following options for the location of these maps
were identified:
1. In an Appendix to the Core Strategy
2. In the Minerals Background Paper 2
3. In a separate LDD
2.1.15 The Coal Authority expressed a clear preference for Option 1. Option 3
was their second choice and Option 2 their least favourite, as it would carry less
weight in decision making and is less likely to be referred to when there are
multiple policy documents requiring consideration. For publication, three mineral
commodity maps (MC1 – MC3) were prepared showing the extent of the different
resources, and these are included in Appendix 7 of the publication document.
2.1.16 The Black Country MSA and mineral commodity areas are based largely
on BGS mineral resource linework and geological data. This is not ideal as there
are caveats about the accuracy and consistency of this data set. However, the
good practice guide on mineral safeguarding suggests that this is the best
starting point for identifying proven mineral resources and defining MSAs.5 Policy
MIN1 indicates that further refinement of the MSA boundary and mineral
commodity areas could be achieved through further technical work and other
DPDs. However, the Black Country authorities are currently not committed to
5 A guide to mineral safeguarding in England (2007), BGS, Executive Summary, page 6
13
undertaking further technical work on defining mineral safeguarding areas, and
may not have sufficient resources to do this.
Replacement of Existing MSAs
2.1.17 The new Black Country MSA will replace the existing MSAs defined in the
UDPs for Dudley and Walsall. Table M2 below shows which areas are currently
covered by MSAs and how they will be replaced.
M2: Replacement of Existing MSAs by the Core Strategy MSA
Existing MSA UDP Replaced By
Oak Farm/ Himley Dudley
Ketley Dudley
Proposal M1.i Branton Hill Lane, Aldridge Walsall
Proposal M1.ii Birch Lane, Aldridge Walsall
Proposal M1.iii Stubbers Green Road/
Dumblederry Lane
Walsall
Proposal M1.iv Highfields South Walsall
Black Country
MSA
2.2 Mineral Safeguarding Policy
Black Country Minerals Study – Key Findings and Recommendations
2.2.1 The Black Country Minerals Study recommended that consideration
should be given towards how MSAs might guide the development control
process and consideration of prior extraction of minerals in non-mineral
development. The desirability of securing mineral extraction prior to new
permanent non-mineral development is also supported by national policy
guidance (see MPS1 paragraph 13 and MPG3 paragraph 22).
14
Baseline Evidence - Update
2.2.2 The following new evidence has become available since the Study was
completed:
• The Black Country Core Strategy Stage Two Infrastructure &
Deliverability Study (November 2009) by Mott MacDonald has
reviewed the evidence for mineral resources within the Regeneration
Corridors.
• The Black Country Core Strategy Sample Sites Viability Study
(October 2009) by Mott MacDonald has considered the viability of a
number of “sample sites” across the Black Country, having regard to
various factors including geo-environmental issues.
• Evidence of the feasibility of mineral safeguarding through “prior
extraction” obtained from the Coal Authority. This relates to examples of
coal extraction within urban areas, and suggests that “prior extraction” is
only likely to be feasible in a limited number of cases.
• Options for the RSS Phase 3 Revision (June 2009) included options for
a regional safeguarding policy (including thresholds to be applied) and for
the safeguarding of mineral-related infrastructure.
2.2.3 As has been noted above, much of the Black Country – including the
Growth Network where most development will take place - will be included within
the MSA as there are hardly any parts of the area that do not contain mineral
resources of one sort or another. The Stage Two Infrastructure and Deliverability
Study by Mott MacDonald shows that much the Growth Network is underlain by
mineral resources and identifies the types of resources that occur within each
Regeneration Corridor.6
6 See Table 6 and Figure 11, Black Country Joint Core Strategy: Stage 2 Infrastructure and
Deliverability Study Technical Note 6: Ground Risk and Mineral Extraction (November 2006), Mott MacDonald.
15
2.2.4 The question then arises, to what extent can mineral safeguarding be
achieved in an area where a significant amount of non-mineral development is
expected to happen, and where there are also significant risks to the viability of
projects arising from poor ground conditions, contamination and other
geotechnical issues?7
2.2.5 Evidence for the feasibility of safeguarding mineral resources through
“prior extraction” is not easy to come by. The current good practice guidance on
mineral safeguarding indicates that instances of prior extraction are rare within
the urban areas of Staffordshire, suggesting that this is unlikely to be feasible in
most urban developments.8 The case studies in the guidance9 are of limited
value in understanding the potential for prior extraction, as they are all examples
of missed opportunities and no success stories are included.
2.2.6 There are only a few documented cases of prior extraction of minerals in
the Black Country, all involving the extraction of coal. The most significant
examples are the former Patent Shaft site in Sandwell, and the Reedswood site
in Walsall. Both of these developments occurred more than 10 years ago and
involved remediation of very large areas of land, with extraction of coal.
2.2.7 To supplement this evidence, the authorities have obtained information
from the Coal Authority on incidental coal licence agreements with developers in
urban areas in the UK between 1995 and 2008. There are 49 records in total in
the schedule provided, on sites ranging from less than 1ha to 28ha. Only three of
these records relate to Black Country sites. The Coal Authority has stressed that
this reflects only the schemes notified to them, and that there may be other
instances where prior extraction has happened without their knowledge.
7 See Black Country Joint Core Strategy Sample Sites Viability Study (October 2009), Mott
MacDonald, Section 5 8 “A guide to mineral safeguarding in England” (2007), BGS - see Part Three, Stage 4.
9 “A guide to mineral safeguarding in England” (2007), BGS - see Annex 1.
16
2.2.8 There is some anecdotal evidence that other mineral resources
(particularly aggregates) can be extracted in advance of development, but hard
evidence for this is lacking. During discussions with mineral operators, they have
indicated that this does happen. However, the authorities are not aware of any
documented examples of prior extraction of minerals other than coal, and there is
no body with responsibility for licensing the extraction of these minerals, which
would be able to provide information on this.
2.2.9 The examples provided by the Coal Authority suggest that the size of site
is not the only factor influencing the feasibility of prior extraction in advance of
redevelopment. However, the limited number of recorded examples of prior
extraction of coal in the UK over a 13-14 year period does suggest that it is only
likely to be feasible in a minority of cases.
2.2.10 When drafting the safeguarding policy, the authorities also had regard to
proposals in the RSS Phase 3 Revision Options for mineral safeguarding at a
regional level. The final version of MIN1 reflects the authorities’ responses to the
Options consultation on mineral safeguarding issues, and related discussions
with WMRA and neighbouring MPAs.
Stakeholder Engagement
2.2.11 The main feedback received from stakeholders on mineral safeguarding
issues is summarised below:
• The GO-WM has clarified that the MPS1 requirement not to allocate sites
within MSAs only applies to Districts within two-tier areas and does not
apply to unitary authorities;
• There appears to be general agreement that non-mineral development
proposals within a MSA should be accompanied by evidence
demonstrating that mineral resources have not been needlessly sterilised,
although there is less certainty about the level of detail of the information
or what exclusions should apply;
17
• Whilst the overriding need for regeneration of urban areas/ essential non-
mineral development is acknowledged by some stakeholders, others
appear to consider that the national policy requirement to safeguard
mineral resources outweighs all other material considerations;
• Development management officers have expressed concern about
applying mineral safeguarding requirements to planning applications, and
have suggested that within the urban areas, a threshold based on sites of
5 – 10ha would be more realistic than a threshold based on “major”
developments;
• Network Rail and other stakeholders have identified a limited number of
key facilities and potential facilities for transportation of minerals by rail
which should be protected in the JCS;
• The Inland Waterways Association has expressed the view that there is
potential to transport minerals by canal, but neither British Waterways nor
any other stakeholder has identified existing wharves or other specific
locations within the Black Country which could be used for this purpose;
• Whilst British Waterways supports the transportation of minerals by canal
in principle, they consider it is only likely to be feasible on a small-scale
and in a limited number of cases, due to the constraints of the canal
network and other potentially conflicting objectives.
2.2.12 Efforts were made to engage with the development industry through a
workshop organised by the Core Strategy Employment Group, but no feedback
was received on mineral safeguarding. In developing the policy, the authorities
were aware of the additional burden that the requirements may place upon
applicants for non-mineral developments, when the cost of land remediation is
high. They have sought to address this by highlighting the economic potential of
exploiting minerals through the development process (see Delivery section), and
18
by specifically targeting the types of projects where prior extraction of minerals is
most likely to be feasible.
Developing the Mineral Safeguarding Policy
2.2.13 As recommended by the Black Country Minerals Study, the authorities
have considered how the MSA should be applied through the development
management process, and to what extent the safeguarding of minerals through
prior extraction or other means should be a policy requirement. The following
options for a safeguarding policy have been considered:
1. Adopt the same policy requirements and thresholds for non-mineral
development throughout the Black Country MSA, or
2. Adopt different policy requirements and thresholds in different parts of the
MSA, such as the urban areas, the Green Belt, mineral extraction sites
and the Areas of Search.
2.2.14 Some stakeholders appear to have adopted a very rigid interpretation of
national policy guidance, and do not accept the need for non-mineral
development within a MSA. However, national policy guidance does not preclude
non-mineral development within MSAs. The GO-WM advice also indicates that
sites can be allocated for non-mineral developments in MSAs within unitary
authority areas.
2.2.15 It is accepted that non-mineral development should not be permitted
where this would compromise an existing mineral working site or an Area of
Search for mineral extraction, in line with national policy guidance (MPS2,
paragraph 13). These are the areas which are expected to provide the Black
Country’s essential supplies of aggregates and brick clays, so it is very important
to safeguard them against incompatible non-mineral development. Policy MIN1
addresses this issue.
19
2.2.16 It is also agreed that as a general principle mineral safeguarding through
“prior extraction” should be encouraged where it is feasible. Indeed, the UDPs
for all four authorities already acknowledge the potential for this and contain
enabling policies for this. This also has the potential to support other elements of
the strategy, for example, the spatial objectives for transport, the environment
and waste through use of extracted material on-site and the delivery strategy
through assisting site remediation and helping to offset the development costs.
2.2.17 However, an overly rigid approach towards mineral safeguarding is not a
reasonable option in the urban areas of the Black Country, given that almost all
of the Growth Network is within the MSA and the delivery of the spatial strategy
depends on significant amounts of non-mineral development taking place within
these areas between now and 2026. It is acknowledged in the good practice
guide on mineral safeguarding that the overriding need for other development
can be a material consideration.10
2.2.18 A mineral safeguarding policy cannot ignore the overriding need for non-
mineral development within the Growth Network, or the fact that mineral
resources in this area are already sterilised. Redevelopment with new non-
mineral uses will not make the situation any worse for the mineral resources
present, and opportunities to realise the value of these minerals by extracting
them are only likely to occur through redevelopment anyway. Nevertheless, the
evidence on prior extraction suggests that this will not always be feasible.
2.2.19 As the Sample Sites Viability Study shows, many sites in the Black
Country are likely to have abnormal development costs associated with them due
to poor ground conditions and/ or contamination.11 Although the exploitation of
mineral resources has the potential to help offset development costs, this will not
always be the case. If minerals are difficult or expensive to extract they could be
an additional constraint to development, potentially affecting the viability and
deliverability of some projects.
10
“A guide to mineral safeguarding in England” (2007), BGS – see Part 1, Step Five. 11
See Black Country Joint Core Strategy Sample Sites Viability Study (October 2009), Mott MacDonald, Section 5.
20
2.2.20 Within the Green Belt there are fewer constraints to mineral working, and
greater constraints on non-mineral development, than there are in the urban
areas. Only “appropriate” developments are allowed in the Green Belt, which are
generally developments which maintain openness and involve only limited
amounts of construction, although they can involve significant landscaping and
engineering. Non-mineral developments in the Green Belt are therefore more
likely to provide opportunities for mineral safeguarding in situ or for prior
extraction of minerals as part of the development process.
2.2.21 The good practice guide on mineral safeguarding advises that minor
developments and developments unlikely to affect mineral resources should be
excluded or exempted.12 This suggests that a safeguarding policy should not be
applied indiscriminately to all non-mineral developments within a MSA. Policy
thresholds were proposed in the Preferred Options.
2.2.22 As stakeholders have pointed out, if policy thresholds are set at too low a
level very many proposals would be caught by the requirements, but as we have
seen, prior extraction is unlikely to be feasible in all cases. The benefits of the
policy may therefore be outweighed by the amount of abortive work required from
both developers and MPAs in demonstrating this.
2.2.23 The evidence points towards the following conclusions:
• As a general principle, the safeguarding of mineral resources through prior
extraction should be encouraged on any site where it is feasible;
• Prior extraction of mineral resources should be particularly encouraged
where the material will be used on-site, where this can help address
“legacy” issues or provide opportunities for geological conservation;
12
“A guide to mineral safeguarding in England” (2007), BGS – see Figure 5.
21
• Strict policy requirements should apply to non-mineral developments
affecting existing mineral working areas and Areas of Search for mineral
extraction;
• The safeguarding policy should not prevent non-mineral development
within the Growth Network which is essential to the delivery of the overall
spatial strategy;
• Within the Growth Network and other urban areas, very large sites and
area regeneration proposals are most likely to offer genuine opportunities
for prior extraction of minerals;
• Proposals for non-mineral development in the Green Belt are more likely
to offer opportunities for mineral safeguarding than proposals in the urban
areas.
2.2.24 In the light of this, the authorities have decided that Option 2 (different
policy requirements in different areas) is most appropriate. Policy MIN1 therefore
sets different thresholds for the urban and Green Belt areas of the MSA, and
does not permit non-mineral development which would compromise existing
mineral working sites or Areas of Search. The thresholds for non-mineral
development within the MSA are as follows:
• Urban areas – developments on sites of 5ha and over
• Green Belt areas - all “major” developments (as in GPDO).
The threshold for the urban area is not arbitrary and is based on discussions with
development management officers and on the threshold used in the Dudley UDP
(see Policy M1).
2.2.25 Policy MIN1 therefore requires planning applications for developments
falling within the above thresholds to include supporting information justifying the
non-mineral development, and to demonstrate that mineral resources will not be
22
needlessly sterilised. The question of what type of supporting information should
be provided has also been discussed with neighbouring authorities, the BGS and
development management officers.
2.2.26 So that information provided with an application would be robust enough
to base a decision on, it was felt that MPAs should be requesting mineral
assessments or geotechnical reports produced by a qualified mineral surveyor or
geologist. Applicants could also be advised to consult the Coal Authority where
appropriate and to approach the Coal Authority, BGS and MPA geotechnical
teams for detailed mineral resource/ geotechnical information for the site. This is
the approach recommended in the Justification to Policy MIN1.
2.2.27 In addition to safeguarding mineral resources, MPS1 advises that key
mineral infrastructure sites (mineral processing sites as well as existing and
potential transport infrastructure) should be safeguarded. The Core Strategy
therefore identifies such sites on the Minerals Key Diagram and they are also
listed in Appendix 7. Policy MIN1 seeks to safeguard these sites against non-
mineral development.
2.2.28 There are some overlaps between safeguarding mineral infrastructure,
safeguarding existing/ potential rail freight sites and protecting waste
management capacity, as some sites fulfil multiple roles. Where relevant, mineral
infrastructure sites have also been identified as rail freight sites and/ or strategic
waste management sites (see Policy TRAN3, Policy WM2 and Appendix 6).
23
3. Policy MIN2: Production of Aggregate Minerals
3.1 Secondary and Recycled Aggregates
Black Country Minerals Study – Key Findings and Recommendations
3.1.1 The main source of evidence for secondary and recycled aggregates -
sometimes referred to as “alternative materials” - in the Black Country (and
elsewhere) is national surveys commissioned from Capita Symonds and WRc
Ltd by CLG and its predecessors. The Black Country Minerals Study focused
mainly on the evidence base for primary mineral resources and did not include
any new research into secondary and recycled aggregates production.
3.1.2 The Black Country Minerals Study identified waste as the main source
material likely to be available in the Black Country to produce secondary and
recycled aggregates, and recommended the following action:
• Spatial approach – supply needs to be linked to other spatial issues
including regeneration and growth (1.4.1);
• Existing secondary and recycled aggregate production sites should
be safeguarded and additional sites allocated as part of an
integrated network of waste management facilities within the Black
Country (1.3.36);
• The Core Strategy should include policies requiring new
developments (including mineral operations) to minimise waste
(1.3.37 – 1.3.39);
• Site Waste Management Plans (SWMP) should be required with
“major” planning applications to provide a better evidence base for
secondary and recycled aggregates (section 6.4).
24
Baseline Evidence - Update 3.1.3 Since the Study was published, there have been the following
developments in policy and evidence:
• New national and regional guidelines for aggregates have been
issued (June 2009).13 These cover the period 2005 – 2020 and
include increased assumptions about the contribution that alternatives
to primary aggregates will make within the region.
• The RSS Phase 3 Revision Options (June 2009) considered options
for aggregates provision including the potential contribution of
secondary and recycled aggregates towards supply;
• The evidence for secondary aggregates production has been
reviewed as part of the 2008 WMRAWP secondary aggregates
survey;
• Estimates of recycled aggregate production in the Black Country
have been produced by the Black Country authorities, based on
the best evidence currently available.
3.1.4 The new national and regional guidelines assume that the West Midlands
region will produce around 247 million tonnes of primary land won aggregates
per annum between 2005 and 2020. It is assumed that a further 100 million
tonnes will come from alternative materials (secondary and recycled aggregates).
This is an increase on the assumption in the previous guidelines which assumed
that alternatives would contribute around 88 million tonnes per annum.
3.1.5 The RSS Phase 3 Revision Options consultation came out around the
same time as the new aggregates guidelines, but used the same assumptions for
alternatives as these had not changed since the previous draft of the guidelines.
Although the RSS Phase 3 Revision has now been abandoned, the sub-regional
13
National and Regional Guidelines for Aggregates Provision in England 2005 – 2020 (June 2009), CLG
25
aggregates apportionments review is continuing and an Interim Policy Statement
on this will be produced in March 2010.14 It is possible, but unlikely, that this will
include revised assumptions on the contribution from alternatives.
3.1.6 Local information on production of alternatives to primary aggregates is
limited. Recycled aggregates can be produced either on-site (using mobile plant)
or at a recycling facility. There are also other facilities processing secondary
aggregates into mineral products. There are not many secondary aggregate
processing facilities in the Black Country at the present time. The facilities
referred to in the Black Country Minerals Study were based on those identified in
previous WMRAWP secondary aggregate surveys.
3.1.7 However, to inform the 2008 WMRAWP secondary aggregate survey, the
authorities reviewed the facilities listed in previous reports, and as result of this a
number of them have been found not to be producers. The facilities in the Black
Country which are believed to be producing alternative materials (secondary or
recycled aggregates) are listed in Table M3 below.
Table M3: Producers of Alternative Materials (Secondary and Recycled
Aggregates) in the Black Country
Core Strategy Ref
Site Name/ Location
MPA Operator Type
Operator
WSWa1MI1
Bace Groundworks Walsall Demolition contractor
Bace Groundworks
WSWa2 MI2
Branton Hill Quarry Walsall Mineral Operator
Bliss Aggregates.com Ltd
WSWo4 MI3
Dismantling & Engineering Services Ltd
W’ton Demolition contractor
Dismantling & Engineering Services Ltd
WSWo5 MI5
Ettingshall Asphalt Plant
W’ton Mineral operator
Acemix West Midlands (MQP/Tarmac)
WSS10 MI6
Glenside Recycling Sandwell Waste operator
Glenside Recycling
WSS1 MI7
Network Rail, Bescot Sidings
Sandwell Transport operator
Network Rail
14
See WMRSS Update: Phase 3 Special (November 2009), WMRA
26
WSS2 MI8
Tarmac, Bescot Sidings
Sandwell Mineral operator
Tarmac
WSS19 MI10
Wednesbury Asphalt Plant
Sandwell Mineral operator
MQP/ Tarmac
3.1.8 As recommended by the Black Country Minerals Study, these have been
identified as key mineral related infrastructure sites to be safeguarded through
Policy MIN1. The role of waste in the production of alternatives is also reflected
in the Core Strategy waste policies. Facilities recycling CD&EW into aggregates
are also identified as strategic waste sites whose capability will be protected
under Policy WM2, and locations suitable for the development of new facilities
are identified in Policy WM4, although it has not been possible to allocate specific
sites.
3.1.9 Recent WMRAWP surveys of secondary aggregate production for 2006
and 2008 have not yielded useful results for the Black Country, as some
operators have failed to return survey forms. The Black Country authorities
currently have no systems in place for monitoring on-site production of recycled
aggregates using mobile plant, and indeed, planning applications do not include
this information as a matter of course as there are no requirements in UDPs for
them to do so.
3.1.10 This remains as a significant gap in the evidence base, so in accordance
with the Black Country Minerals Planning Study recommendations, Policy WM5
requires applications for “major” development to provide supporting information
about on-site recycling and usage of recycled materials. Local monitoring
systems will also need to be set up to collate the data collected from these
applications. The authorities are proposing to put such systems in place during
2009/10 – 2010/11, so that this can be monitored effectively. In the meantime,
the evidence base for secondary and recycled aggregates uses the best data
available at the moment, which is set out below.
3.1.11 The Black Country Core Strategy Waste Planning Study by Atkins Ltd
(Black Country Waste Planning Study) includes analyses of construction,
demolition and excavation waste (CD&EW) arisings and recycled aggregates
27
production, based on the findings of the national surveys. The data and
methodology used in this study has been used by the authorities to produce
estimates of recycled aggregates and recycled soil production in the Black
Country between 2001 and 2005. These estimates are set out in Table A1a of
Appendix 1 and are illustrated by Figure M1 below.
Figure M1
Estimated Recycled Aggregate and Soil Production in
the Black Country 2001 - 2005
0
100,000
200,000
300,000
400,000
500,000
600,000
700,000
800,000
900,000
2001 Black
Country
Total
2003 Black
Country
Total
2005 Black
Country
Total
Year
To
nn
es Recycled
Aggregate
RecycledSoil
Source: National Surveys of CD&EW Arisings and Use as Aggregate 2001 – 2005 by Capita
Symonds/ WRc Plc; based on assumption that 17.82% of production in the West Midlands region
2001 – 2003 was in the Black Country, and 50.20% of production in Birmingham and the Black
Country 2005 was in the Black Country
3.1.12 Total recycled aggregates production in the Black Country appears to be
around 730,000 tonnes per annum and recycled soil production around 100,000
tonnes per annum (a total of around 830,000 tonnes per annum).15 The data
shows significant variations between the authorities, with Sandwell having the
highest annual production rate (about 300,000 tonnes of recycled aggregate and
40,000 tonnes of recycled soil) and Walsall the lowest (about 120,000 tonnes of
recycled aggregate and 17,000 tonnes of recycled soil).
15
These are based on average (mean) production in 2001, 2003 and 2005. The figures quoted in Policy MIN2 Justification differ as they are based on 2005 data – see Appendix 1.
28
Stakeholder Engagement
3.1.13 Stakeholders commented as follows:
• The Regional Conformity Panel commented that the Core Strategy
should more clearly reflect the “hierarchical approach” towards mineral
supply in national policy guidance (MPS1, paragraph 1);
• Environmental bodies and members of the public have commented on
the need for the Core Strategy to minimise waste, maximise production
of secondary and recycled aggregates and minimise extraction of
primary aggregates;
• Several stakeholders have commented that the prudent use of mineral
resources/ production of secondary and recycled aggregates should be
addressed through waste policies instead of minerals.
Developing the Policy for Secondary and Recycled Aggregates
3.1.13 Adopting a “hierarchical approach” means firstly reducing the quantity of
material used and waste generated, secondly using as much secondary and
recycled material as possible, before finally securing the balance of what is
needed through primary mineral extraction. As far as possible, the hierarchical
approach has been followed in the development of the spatial objectives for
minerals and waste (Spatial Objectives 9 and 10) and the minerals and waste
policies. This approach is also consistent with Core Strategy Sustainability
Objectives 3 and 12.
3.1.14 The Core Strategy discourages needless waste of mineral resources and
encourages waste minimisation through mineral safeguarding policy (Policy
MIN1) and policy requirements for mineral working (MIN5). Assumptions are also
built into the national and regional aggregates guidelines about the quantity of
alternatives to primary aggregates which will be produced in each region. Thus,
29
the overall regional targets for primary aggregates production already take this
into account.
3.1.15 Recycling of CD&EW also supports the national waste strategy objective
of halving the amount going to landfill by 2012.16 The main source of supply of
alternatives in the West Midlands appears to be material recycled from CD&EW
rather than other materials.17 Although some secondary aggregates are
produced and processed in the Black Country and we have information on
production at a couple of sites, we are unable to estimate total secondary
aggregates production across the Black Country at present. Stakeholders are
therefore right to say that this is predominantly a waste and resource
management issue, even though the end product is aggregate minerals.
3.1.16 Accordingly, the authorities have sought to minimise waste and encourage
production and use of alternatives through the Core Strategy waste policies, in
particular WM4 which identifies suitable locations for recycling facilities, and
WM5 which encourages waste reduction, on-site recycling of CD&EW into
aggregates and the use of recycled construction materials. Policy WM5 replaces
Core Policy Areas 17 and 24 proposed in the Preferred Options.
3.1.17 However, it is also accepted that the policy on aggregates should highlight
the contribution that alternative materials make towards overall supply. This has
been addressed in Policy MIN2. In the case of the Black Country the contribution
of alternatives is likely to be very significant. The “weighted shares” used in
regional technical work on CD&EW arisings and in the estimates in this report,
are based projected housing growth rates. They assume that the Black Country
is producing a high proportion (nearly 18%) of the region’s recycled aggregate.
3.1.18 When the estimated average annual production rate for recycled
aggregate (around 730,000 tonnes per annum) is compared to average annual
production (sales) of primary aggregates (around 50,000 tonnes per annum), it
16
Waste Strategy for England 2007 (May 2007), Defra, Chapter 4, 73 – 78 and Chapter 8, 18 17
Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005 (2007), Capita Symonds / WRc for CLG
30
also suggests that more than 90% of the aggregates produced in the Black
Country is from alternative sources. The national survey results suggest that
recycling of this material is already happening on a significant scale. This is also
borne out by research by WRAP which suggests that in the West Midlands
Metropolitan area we are close to achieving maximum recovery of useful material
from secondary and recycled sources.18
3.1.19 However, there are caveats attached to the data. The estimates of
recycled aggregates and soils for the Black Country as a whole and for the
individual authorities can only be regarded as very approximate, as they are
based on “weighted shares” of estimated production in the region in 2001 and
2003, and estimated production in the Birmingham and the Black Country sub-
region in 2005. The weightings are the same as those used in a regional waste
requirements study to calculate construction, demolition and excavation waste
(CD&EW) arisings.19
3.1.20 The authorities feel that it would be unsafe to set targets for production of
secondary and recycled aggregates based on this data as although it is the best
available, it is not very robust. The Justification to Policy MIN2 explains that
production targets will be developed once locally obtained data becomes
available through future improvements to monitoring.
3.1.21 Options for the location of secondary and recycled aggregates production
facilities were considered through the Black Country Waste Planning Study and
as part of the development of the waste policies, as these are also CD&EW
processing sites and have the same characteristics/ locational requirements. As
is mentioned above, this is addressed in waste policy WM4 which identifies
suitable locations for recycling facilities.
18
The Sustainable Use of Resources for the Production of Aggregates in England (2006), WRAP 19
West Midlands Waste Facilities – Phase 2: Future Capacity Requirements (2004), Shropshire County Council for WMRA
31
3.2 Primary Land Won Aggregates
Black Country Minerals Study – Key Findings and Recommendations
3.2.1 The main sources of evidence for primary aggregates supply (permitted
reserves), production (sales) and potential future supplies are the Survey of
Mineral Resources in the Black Country (March 2007) by Scott Wilson, the Black
Country Minerals Planning Study and the most recent annual surveys by the
West Midlands Regional Aggregates Working Party (WMRAWP).
3.2.2 With regard to primary aggregates, the Black Country Minerals Study
found that permitted reserves of sand and gravel in the Black Country were not
sufficient to demonstrate a 7-year landbank to 2026 even assuming that the
Black Country was only expected to contribute a 10% share of the sub-regional
apportionment. The Study recommended the following action:
• Spatial approach – supply needs to be linked to other spatial issues
including regeneration and growth (1.4.1);
• Further evidence should be sought from operators on the amounts
of sand and gravel which could be exploited within the lifetime of
the plan (4.14.2);
• In the absence of a landbank of permitted reserves, the JCS should
identify preferred areas or areas of search where mineral working
might take place (1.3.14);
• Preferred areas and areas of search for future mineral working
should be informed by the proposed MSAs and constraints
mapping undertaken as part of the study (5.6.2);
• Provision should also be made for “borrow pits” related to specific
construction or development projects (4.13.49).
32
3.2.3 Since the Black Country Minerals Study was published, there have been
the following developments in policy and evidence:
• New national and regional guidelines for aggregates have been
issued (June 2009). These cover the period 2005 – 2020 and have
increased the overall requirement for primary aggregates production in
the West Midlands region;
• The RSS Phase 3 Revision (June 2009) considered options for
aggregates provision including sub-regional apportionments and
possible changes to the sub-regional areas. Although this has now
been abandoned, the sub-regional aggregates apportionment review is
continuing;
• WMRAWP has carried out surveys of aggregates sales and
permitted reserves in 2007 and 2008 (see Appendix 1) and Walsall
Council has used this to update the evidence base for primary
aggregates.
3.2.4 Following the Black Country Minerals Study we now have more up-to-date
information on production and permitted reserves. However, the overall level of
activity has not changed. There are still only two active sand and gravel quarries
in the Black Country, both in Walsall:
• Aldridge Quarry (operated by Cemex)
• Branton Hill Quarry (operated by Bliss Aggregates.com)
There is also still only one current application for sand and gravel working,
relating to an extension to Branton Hill Quarry.
3.2.5 Nationally, the aggregates industry is currently dominated by a limited
number of large companies, and as with many other industries there has been
recent consolidation.20 The main aggregate companies represented in the Black
20
Planning 4 Minerals: A Guide on Aggregates (2006), QPA, BMAPA, BGS and Entec, 2.1.4
33
Country are Cemex (see above) and Tarmac, who have a head office at
Ettingshall in Wolverhampton and a number of processing facilities. Tarmac
currently has no quarries in the Black Country but operates Shire Oak Quarry,
just outside the Walsall Borough boundary in Staffordshire.
3.2.6 Although they are used as raw materials for building and engineering, the
main use of primary aggregates is to create other value-added products such as
concrete, cement, mortar and coated products (roadstone and asphalt).21 There
are a number of facilities in the Black Country processing aggregates to make
these products and they have been identified as key mineral infrastructure sites
to be safeguarded under Policy MIN1 (see Section 2.1 above). Although new-
build construction projects are expected to use more than half of the virgin
aggregate materials produced in the region, refurbishments and extensions are
also expected to use a significant proportion.22
Aggregates Guidelines and Sub-Regional Apportionments
3.2.7 The national and regional aggregates guidelines set the framework for
planning future aggregates supply and include targets or “guidelines” for primary
aggregate production for each region. These targets are then expected to be
developed into sub-regional apportionments (annual supply targets), to be
incorporated in the RSS by regional planning bodies assisted by Regional
Aggregates Working Parties (RAWPs). The national and regional aggregates
guidelines were revised in June 2008. The sub-regional aggregates
apportionments for the West Midlands Region are now being reviewed in the light
of this (see paragraphs 3.2.15 – 3.2.20 and Table M5 below).
3.2.8 However, this review has come too late for the Core Strategy, since at the
time of Submission revised sub-regional apportionments had not been published.
The Core Strategy has therefore been prepared in the context of the existing
21
Mineral Planning Factsheet: Construction Aggregates (February 2007), BGS 22
In developing options for the sub-regional aggregates apportionments it was assumed that around 60% of aggregates produced in the West Midlands region would be used in future new-build housing/ infrastructure development, and around 40% would be used in refurbishment/ redevelopment. This is based on information supplied by the industry members of the WMRAWP.
34
sub-regional aggregates apportionments set out in Policy M2 of the current RSS
(January 2008). The Black Country does not have any sub-regional
apportionments of its own as it is part of the West Midlands County sub-region.
The current sub-regional apportionment requires the West Midlands County to
produce 0.506 million tonnes of sand and gravel per annum up to 2016.
3.2.9 There is currently only a sub-regional apportionment for sands and gravels
for the West Midlands County. The apportionment for crushed rock ended in
2005, and the last quarry in the sub-region which was producing this material (in
Sandwell) ceased production shortly after that. This situation is not expected to
change as a result of the current review of sub-regional apportionments, as none
of the options under consideration include any sub-regional apportionment for
crushed rock for the West Midlands County.
Aggregates Production 1998 - 2007
3.2.10 Permitted reserves and sales of aggregates are surveyed annually by
WMRAWP, and the latest surveys cover the calendar years 2007 and 2008 (the
latter is not yet published), post-dating the information in the Scott Wilson study
and the Black Country Minerals Planning Study. Figure M2 below shows details
of sales (production) of aggregates in the West Midlands County Area between
1998 and 2007, compared to the sub-regional apportionments (see also Table
A1b in Appendix 1). The apportionments changed in 2002.
3.2.11 Production in the Black Country accounted for all of the crushed rock
sales in the West Midlands County Area up to 2005, and for around 10% of the
sand and gravel sales 1998 - 2007. Sales of sands and gravels in the West
Midlands County area as a whole have been slightly above the apportionment
(annual production target) set out in Policy M2 of the RSS, which is 0.506 million
tonnes per annum.
35
Figure M2
West Midlands County Area:
Sub-Regional Aggregates Apportionments and Sales 1998 - 2007
0
100,000
200,000
300,000
400,000
500,000
600,000
700,000
800,000
900,000
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Year
To
nn
es
Crushed Rock
Sales
Sand & Gravel
Sales
Crushed Rock
Apportionment
Sand & Gravel
Apportionment
Source: West Midlands Regional Aggregates Working Party Annual Reports 1998 – 2007
3.2.12 In the West Midlands County area only two mineral planning authorities
(MPAs) are contributing to sand and gravel supplies: Solihull and Walsall. The
“share” of the apportionment assumed to be provided by each authority (based
on recent production rates) is summarised in Table M4 below.
Table M4: West Midlands County Area Sub-Regional Sand and Gravel
Apportionment – Assumed Provision to 2011
Solihull UDP Walsall UDP Total West Midlands County Area
Apportionment
% Tonnes per
annum
% Tonnes per
annum
% Tonnes per
annum
90 455,400 10 50,600 100 506,000
Source: WMRAWP Annual Surveys, Walsall UDP 2005, Solihull UDP 2006
3.2.13 Assumptions are based on past rates of sale and the provision made in
the adopted UDPs, which cover the period up to 2011. However, there are
concerns that Solihull and Walsall will not be able to sustain production of sand
and gravel at current rates into the long-term (see paragraph 3.2.17 below). As
Figure 3 below shows, permitted reserves have been falling since 1998 (see also
36
Table A1c in Appendix 1), although there was a slight increase in 2007 as a
result of a new permission to extend one of the quarries in Solihull.
Figure M3
West Midlands County Area:
Sand and Gravel Supplies - Landbanks 1998 - 2007
0
500,000
1,000,000
1,500,000
2,000,000
2,500,000
3,000,000
3,500,000
4,000,000
4,500,000
5,000,000
1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
Year
Su
pp
ly (
ton
nes
)
Landbank -
Permitted
Reserves @ 31
December
(tonnes)
Permitted
Reserves
Required for 7-
year Landbank
(tonnes)
Source: West Midlands Regional Aggregates Working Party Annual Reports 1998 – 2007
3.2.14 It is only possible to give a broad estimate of permitted sand and gravel
reserves in Walsall in this paper, as there are only two quarries in the area, and
more detailed information would be regarded by the operators as confidential.
The provisional results of the latest (2008) WMRAWP survey suggest that at
December 2008, permitted reserves of sand and gravel in Walsall were just
under 250,000 tonnes. Whilst this is very low, it is not quite as low as the Scott
Wilson survey suggests. Walsall Council considers that the latest WMRAWP
surveys provide the best and most up-to-date information on permitted reserves,
and that the above estimate is preferable to that given in the Scott Wilson survey.
Review of Sub-Regional Aggregates Apportionments
3.2.15 We cannot assume that the West Midlands County sand and gravel
apportionment will remain the same as it is now, because the sub-regional
apportionments are under review. The West Midlands Regional Assembly
(WMRA) will shortly produce an Interim Policy Statement on Sub-Regional
37
Aggregates Apportionments, which will have the same status as the RSS
Preferred Option. This will be published at the end of March 2010, together with
Policy Recommendations on Mineral Safeguarding, Construction Aggregates and
Future Brick Clay Provision, which will have less weight.
3.2.16 The review has taken into account comments received during the previous
consultation on the RSS Phase 3 Revision Options. During this consultation
some stakeholders expressed concern about the imbalance between supply and
demand across the region. Currently, the West Midlands County is the main user
of aggregate minerals but contributes very little in the way of primary aggregates
(only 5% of the regional sand and gravel guideline). The bulk of the regional sand
and gravel guideline - around 65% - is met by the Staffordshire sub-region, which
comprises Staffordshire County and the city of Stoke-on-Trent.
3.2.17 In reviewing the apportionments, the potential for a more even distribution
of sand and gravel supply across the region has been an important
consideration. However, minerals can only be worked where they are found, and
where working is feasible and economically viable. It is therefore unlikely that the
West Midlands County sub-region can significantly increase its contribution
towards regional sand and gravel requirements, and the contribution made by the
Black Country (i.e. Walsall) is likely to remain very limited. Comments to this
effect were submitted at the RSS Phase 3 Revision Options stage (August 2009)
by the West Midlands Planning & Transportation Sub-Committee (on behalf of
the West Midlands County authorities), and by Walsall Council. No evidence has
since come to light to contradict this view.
3.2.18 The review of the sub-regional aggregates apportionments has involved
“technical” consultation with WMRAWP members, including mineral planning
authorities, on a number of options. Each option has been subjected to a
sustainability appraisal and Habitats Regulations Assessment. The evidence
underpinning the Black Country Core Strategy minerals policy has informed the
review. The Black Country authorities have provided technical information
(including an earlier version of this Background Paper) to the WMRAWP and to
Land Use Consultants who have been preparing the options on behalf of WMRA.
38
The review process to date and the options considered are summarised in an
interim report to the West Midlands Regional Assembly Regional Planning and
Environment Executive Board.23
3.2.19 At the time of writing the WMRAWP had still not made its final
recommendations to WMRA on the preferred options. Following a technical
consultation during December 2009 and January 2010, and a subsequent
meeting of the WMRAWP on 4 February 2010, three potential options were left
“on the table” for consideration. These options would all result in slightly higher
sub-regional sand and gravel apportionments for the West Midlands County.
Table M5 below summarises what the apportionment would be under each
option.
Table M5: West Midlands County Sand and Gravel Apportionment Review -
Comparison of Remaining WMRAWP and Land Use Consultants Options @
February 2010
West Midlands County Requirement
Existing Apportionment
RAWP
Option 1c*
LUC
Option F
LUC
Option Refined F**
% of Regional Guideline
5.00% 5.33% 5.39% 5.00% (2005-10)
5.72% (2011-12)
5.61% (2013-15)
5.39% (2016-20)
Total Apportionment 2005 – 2020 (over 16 years)
8.25 MT 8.80 MT 8.80 MT 9.35 MT
Annual
Production Requirement
0.506 MT 0.550 MT 0.550 MT 0.506 MT (2005-10)
0.654 MT (2011-12)
0.642 MT (2013-15)
0.616 MT (2016-20)
Source: Report to West Midlands Regional Assembly RPEE Board, 23.02.10, Tables 1, 3 and 5
* WMRAWP has agreed that this Option will be recommended to WMRA
** This option involves phasing
23
West Midlands Regional Assembly - Regional Planning and Environment Executive Meeting 23 February 2010 - Agenda Item 5b: Interim Policy Statement – Sub-Regional Apportionment of Aggregates
39
3.2.20 It should be noted that, whereas the annual production target under
Options 1c and F would remain the same throughout the guideline period (2005 –
2020), Refined F involves phasing. Under this option, the annual production
target would increase from 0.506 million tonnes in the baseline year 2005 to
0.616 million tonnes by 2020.
Stakeholder Engagement
3.2.21 Stakeholders have made the following comments on primary aggregates
production and supply:
• The GO-WM, WMRA (Regional Conformity Panel) and several
neighbouring MPAs have commented that the Core Strategy should
contribute appropriately towards sub-regional apportionments;
• AWM has commented that it is more sustainable to use local materials
where possible;
• A number of stakeholders have commented that the Core Strategy
should set targets for primary aggregates production;
• Mineral industry representatives expressed concern that there should
be greater certainty in the Core Strategy about where mineral
extraction can take place;
• A potential site allocation for sand and gravel extraction has been put
forward on land adjacent to Aldridge Quarry;
• Stakeholders have also commented on the need to clarify where
“borrow pits” may be located;
• Environmental bodies have expressed concern about the impact of
sand and gravel extraction on environmentally sensitive areas and on
how potential detrimental impacts can be mitigated;
40
• Councillors representing Aldridge and Walsall Wood have objected to
further quarrying and landfilling in the Aldridge and Stonnall areas of
Walsall, due to impacts on the amenity of local communities and the
local highway network.
Developing the Policy for Primary Aggregate Supply
Primary Aggregate Production/ Supplies
3.2.22 Adequate and steady supplies of aggregate minerals will need to be
provided in the Black Country in accordance with national policy guidance
(MPS1, paragraph 1), and to support the levels of development proposed within
the Growth Network.
3.2.23 The Black Country’s aggregates supply requirements are expected to be
met through a combination of primary, secondary and recycled sources, with the
highest proportion being met from recycling of CD&EW and other waste (see
Section 3.1 above). However, Walsall also has viable primary sand and gravel
resources which will contribute towards both regional requirements and local
needs, albeit on a limited scale. There is a Proposed Change (February 2010) to
Policy MIN2 to clarify that the Black Country is committed towards contributing to
the sub-regional apportionment, in response to a comment by the GO-WM at the
Publication stage. Small contributions towards primary aggregates supply could
also be made through prior extraction (see MIN1) and “borrow pits.”
3.2.24 Although a significant amount of aggregate minerals are expected to be
produced in the Black Country up to 2026 (mostly recycled), there will be
importation and exportation of minerals and mineral products to and from
adjoining areas, although these bulky materials do not tend to travel long
distances.24 The Core Strategy needs to address the amenity, environmental and
transport impacts of importing and exporting aggregate minerals and related
24
The evidence used to develop options for the sub-regional aggregates apportionments assumes that materials are unlikely to travel more than 38 km. This is based on information provided by WMRAWP industry members.
41
products, by encouraging haulage by rail or inland waterway where feasible, and
where it is not feasible, by steering haulage routes onto major roads rather than
through residential areas. Policy MIN5 addresses this issue and Policy MIN1
identifies existing and potential rail freight sites.
3.2.25 National policy guidance requires mineral policies to be based on the best
and most up-to-date evidence available (MPS1, paragraph 12). This includes
evidence on past rates of production and current permitted reserves (as outlined
above), as well as evidence of the resources likely to come forward in the
foreseeable future, and where other viable resources might exist, as indicated by
the Black Country Minerals Study and engagement with relevant stakeholders.
Table A1d in Appendix 1 summarises existing permitted reserves of sand and
gravel in the Black Country and other potential resources which could contribute
towards future supplies.
3.2.26 Mineral resources can only be worked where they are found, so the
options for identifying potential new sand and gravel extraction are limited to the
areas where they occur. The Black Country Minerals Study shows that most of
the Black Country’s sand and gravel resources (bedrock) are sterilised by urban
development, but significant resources remain on the eastern fringes of Walsall.
The extent of the resource is shown on Map MC1 in Appendix 7 of the Core
Strategy. However, we cannot assume that all of these resources can be worked,
as this depends on the quality of the resources and the feasibility of working
them, taking into account any environmental and other constraints that may be
present.
3.2.27 Engagement with the aggregates industry has been through a
combination of events, such as the Minerals & Waste event in March 2007, one-
to-one discussions with some operators, and feedback from formal consultation
on the Core Strategy, for example, the QPA (now the MPA) and Tarmac
commented on the Preferred Options. A proposal for sand and gravel working
near to Aldridge Quarry was put forward by Cemex. Walsall Council has also
been engaging with Bliss Aggregates concerning their recent/ current planning
applications.
42
3.2.28 The only specific sand and gravel extraction proposals to come out of the
consultation and engagement process are proposals for an extension to Branton
Hill Quarry (a current application) and for working areas in the vicinity of Aldridge
Quarry. These proposals lie within the existing MSAs (Proposals M1i and M1ii)
defined in the Walsall UDP, and these areas were suggested as potential
working areas in the Preferred Options. A description of the sites and the key
issues and constraints affecting them is provided in Table A1e of Appendix 1 (for
constraints see Figure 005 of Black Country Minerals Study and Appendix 3 of
Core Strategy Sustainability Appraisal).25
3.2.29 As both proposals would involve the same companies who are operating
the existing quarries and would effectively “take over” from the existing quarries
when they are worked out, they are unlikely to increase production rates
significantly over and above existing levels of around 50,000 – 60,000 tonnes per
annum. Policy MIN2 therefore proposes to maintain production at current levels,
with a production target of 50,000 tonnes of sand and gravel per annum. Table
M6 below summarises the resources that need to be identified in Walsall to
demonstrate a minimum 7-year landbank as required by national policy guidance
(MPS1, Appendix 1) assuming a production target of 50,000 tonnes per annum.
Table M6: Resource Requirements for Sand & Gravel Landbank to 2026
Annual Production
Target (tonnes)
Residual Requirement 2009 – 2026
(Years)
Requirement Beyond 2026
(Years)
Total Requirement to Maintain Landbank
(Years)
Total Supply Requirement to Maintain 7-Year Rolling Landbank
(tonnes)
50,000 17 7 24 1,200,000
3.2.30 The locations identified in the Preferred Options for future sand and
gravel working are Aldridge and Stonnall. These areas have been the main focus
for sand and gravel working in recent years, and there is no evidence at the
moment that working in other parts of Walsall is viable. No representations have
25
Note: Figure B-1 of the Black Country Strategic Flood Risk Assessment (SFRA) (February 2009), Jacobs supersedes the areas of flood risk shown on Figure 005 of the Black Country Minerals Study.
43
been received from the industry or from landowners seeking to extract sand and
gravel in other parts of the resource area.
3.2.31 However, other stakeholders have expressed concern about further sand
and gravel working in Aldridge and Stonnall. In response to this, the Ward
Members for Aldridge and Walsall Wood were briefed on the mineral policy
issues that the Core Strategy must address, such as the requirement to maintain
supplies of aggregate minerals. Their concerns have been reflected in policies
MIN2 and MIN5, which should ensure that any future mineral working in the area
addresses water quality issues, impacts on the local highway network, visual
effects and other potential impacts on local communities.
3.2.32 Even though there are understandable local concerns about working in
these areas, the evidence clearly points towards Aldridge and Stonnall as the
areas most likely to meet requirements for primary land-won sand and gravel in
the foreseeable future. In the absence of any other proposals in the pipeline,
Policy WM2 identifies the following areas of search, based on the areas where
working is proposed:
• MA1: Birch Lane (Walsall)
• MA3: Branton Hill Lane (Walsall)
3.2.33 Following the Preferred Options, Walsall Council officers considered
defining a wider area of search, including land between Aldridge Quarry and
Branton Hill Quarry. However, no formal representations were made in support of
working in this area through the consultation and engagement process. It was
considered inappropriate to include this area within an area of search, in the
absence of any evidence on the extent and quality of the resources, or that the
resources could be worked economically, and without unacceptable impacts on
neighbouring uses or the environment.
3.2.34 The identified areas of search essentially carry forward the policy and
proposals of the adopted Walsall UDP, as they are based on MSAs surrounding
the Birch Lane and Branton Hill quarries identified in the UDP (Proposals M1.i
44
and M1.ii). As is noted above they have already been put forward by operators
as potential working areas, and are therefore believed to contain viable
resources.
3.2.35 The evidence provided by operators indicates that these areas contain
around 4 million tonnes of sand and gravel (Table A1d of Appendix 1), which is
more than sufficient to maintain a landbank up to and beyond 2026. It may also
be enough to allow an increase in production beyond the target rate (the current
application at Branton Hill Lane suggests this), although this cannot be
guaranteed and will depend on the operators. The level of sand and gravel sales
and permitted reserves will be kept under review. If future monitoring shows that
production in Walsall is increasing or decreasing, or that there is potential to
increase production without unacceptable harm to other spatial planning
objectives, the target can be revised accordingly.
3.2.36 Although the areas of search contain sufficient resources to maintain a
landbank, some flexibility is needed, as they are not without constraints so there
is a potential risk to delivery. If permitted reserves within the areas of search do
not materialise within a reasonable timescale, the landbank will continue to
decline and the production target – modest though it is - will not be met. Policy
MIN2 therefore allows proposals to be brought forward in suitable locations
outside the areas of search if there is evidence of a significant deficiency in
supply. To minimise harm to the environment, local communities and the
highway network, all such proposals will be expected to comply with the
guidance in Policy MIN5.
3.2.37 At several stages in the process, WMRA and neighbouring mineral
planning authorities have questioned the adequacy of the target and whether it
represents an appropriate contribution towards the West Midlands County sub-
regional apportionment, bearing in mind this is likely to change as a result of the
current review. There is a Proposed Change (February 2010) to the Policy
Justification to MIN2, to acknowledge that the sub-regional apportionment may
change, in response to comments by WMRA, Staffordshire County Council,
Warwickshire County Council and Solihull MBC at the Publication stage.
45
3.2.38 When the Core Strategy was published (November 2009) it was not
possible to predict how the sub-regional apportionment might change as a result
of the current review. We now know that the apportionments in the Interim Policy
Statement are likely to be based on one of the three options indicated in Table
M5 above. However, even if the sub-regional apportionment is increased slightly
in line with these options, this does not mean that the Black Country can increase
its contribution. The evidence suggests otherwise.
Borrow Pits
3.2.39 The Black Country Minerals Study highlighted the possible need for
“borrow pits” linked to specific engineering projects, and the Preferred Options
proposed that the Core Strategy should include an enabling policy. In the light of
comments received at the Preferred Options stage, there was a need to give
clear guidance on where borrow pits could be located.
3.2.40 The main purpose of “borrow pits” is to source material for specific
development and engineering projects. It would therefore be unreasonable to
them to the areas of search for sand and gravel, because they may be required
to source materials other than sand and gravel such as soils, and because they
would be small-scale, temporary operations which could in theory be
accommodated anywhere in the Black Country with suitable resources. The
approach towards borrow pits and the circumstances where they will be
permitted has been clarified in Policy MIN2.
46
4. Policy MIN3: Maintaining Supplies of Brick Clay
Black Country Minerals Study – Key Findings and Recommendations
4.1 The Black Country Minerals Study confirmed that the approach adopted in
the Survey of Mineral Resources in the Black Country (March 2007) by Scott
Wilson, which aggregated supply data to MPA level, was not appropriate and that
supply should be related to individual plants in accordance with national policy
guidance (MPS1, Annex 2).
4.2 The Study identified significant brick clay resources in the Black Country,
the most important of which are clays from the Etruria Formation. Although other
clay resources are present in the area, with the exception of fireclay, these are
not regarded as having potential economic importance for brick manufacture.
Etruria Marl and fireclay are both identified as important, nationally scarce
resources, used for brick manufacture. The main clay resource areas not
sterilised by urban development are in Dudley and Walsall (see Map MC2 and
MC3 in Appendix 7 of the Core Strategy). 26
4.3 The role of locally made bricks in shaping local character and
distinctiveness is also highlighted.27 In the Black Country, buildings and
structures made of brick are an important and distinctive feature of local
character (see Policy ENV2). Many of these bricks were made from local clays,
as is reflected in the colours, which are mainly red or orange. Blue “Staffordshire”
or engineering bricks (created by reducing the iron present in red clays) were
also widely used, particularly in bridges and walls, and were also used as paving
bricks. Etruria Formation clays are particularly suited to the production of blue
bricks as they contain a significant proportion of iron. In some important
26
Note: the brick clay resources shown on Map MC2 include clays from the Keele and Enville Formations as well as clays from the Etruria Formation. Fireclay resources are not shown on Map MC2. Map MC3 shows the extent of coal resources, which include seams of fireclay. 27
The Role of Brick in the Environment (November 2001), Michael Hammett for Brick Development Association
47
buildings, “polychromatic” (different coloured) bricks were used to create
decorative effects.28
4.4 The Study found that current supplies of Etruria Formation clays and
fireclay are insufficient to provide a 25-year supply to each brick manufacturing
plant in the Black Country, and that in some cases the supply situation was very
serious. It recommended the following action:
• Spatial approach – supply should be linked to other spatial issues
including regeneration and growth and there is a need to establish
linkages between strategy for brick clay and planned growth and
regeneration (1.3.23, 1.4.1);
• Where possible the Core Strategy should plan to maintain a
stockpile of reserves which will allow 25 years production at each
brick making plant (1.3.23);
• Consider the allocation of areas of search or preferred areas for
future mineral working which should be informed by the proposed
MSAs and constraints mapping undertaken as part of the study
(1.3.23, 5.6.2);
• Consider the location of suitable areas for stockpiling material
which is well related to where it will be processed (1.3.23);
• Address inter-relationship between coal extraction and supply of
fireclay (1.3.27).
Baseline Evidence - Update
4.5 Following the Study the following developments have occurred:
28
See examples in The Buildings of Walsall (2000), P. A. Arnold, Tempus Publishing
48
• The RSS Phase 3 Revision Options (June 2009) considered options
for future brick clay provision and cross-boundary supply issues;
• Further engagement with brick manufacturers on supply issues at
individual sites in Dudley and Walsall – this has provided
opportunities to update the evidence base for supply.
4.6 The Black Country Core Strategy Stage Two Infrastructure and
Deliverability Study (November 2009) by Mott MacDonald has not identified any
concerns about the supply of bricks or identified this as a barrier to delivery of the
strategy. Nationally, the demand for bricks is still falling and brick production has
declined since 2001, but in the West Midlands region production has remained
reasonably buoyant and the region produces more bricks than any other region
in England (around 22% of total UK production).29 Discussions with local
operators suggest that there may be an over-supply of bricks, and no need to
cater for any increase in production.
4.7 The main use of bricks (around 60%) is in house-building, the remainder
being mainly used in commercial buildings and in repair and maintenance. Most
bricks produced today are “facing” bricks, as the inner leaves of cavity walls tend
to be made of concrete blocks, and internal walls tend to be made of blocks or
timber and plasterboard, reducing the amount of bricks required. Higher density
housing schemes, which use less bricks per unit, and the trend towards using
alternative materials, have contributed towards the continued decline in demand
for bricks.30 The evidence on the “sustainability” of new bricks does not appear to
be conclusive. Some sources suggest that new bricks are environmentally
sustainable whereas others suggest that refurbishing old buildings is better.31
29
UK Minerals Yearbook 2008: Statistical Data to 2007 (2009), BGS, page 29, also Minerals Planning Factsheet: Brick Clay (February 2007), BGS 30
Minerals Planning Factsheet: Brick Clay (February 2007), BGS 31
Brick – The Case for Sustainability (undated), BDA, and New Tricks with Old Bricks (2008), EHA & BSHF
49
4.8 The brick market is currently dominated by a few large players and there
has been recent consolidation in the industry.32 The main brick manufacturers
represented in the Black Country are Ibstock and Wienerberger. There is also an
independent company in Dudley (Hinton, Perry & Davenhill) which makes both
bricks and tiles. All of the main Black Country brickworks are based in or
adjacent to the main sources of supply of Etruria Formation clays, in Pensnett
and Kingswinford in Dudley and in Stubbers Green in Walsall.
4.9 Ibstock have two operational plants in Walsall (Atlas and Aldridge Works)
and Wienerberger have one (Sandown Works). An independent manufacturer,
Hinton Perry and Davenhill, has a plant in Dudley (Dreadnought Works) making
both bricks and tiles. There is also a small manufacturer of special bricks based
in Sandwell (Cradley Special Brick) which relies on imported clays, and a
supplier of pot clay blends based in Walsall (Swan Works).
4.10 Two brick manufacturing plants, Stourbridge Works in Dudley belonging to
Ibstock and Sedgley Works (just outside the boundary in South Staffordshire)
belonging to Wienerberger, have been “mothballed” as a result of the economic
recession, and their future is uncertain. However, they have been included in the
supply assessment, because they could re-open again once the recession is
over and the demand for bricks picks up again.
4.11 Most brickworks use a variety of types of clays which are blended to
create bricks of different colours and textures. There are two basic colours of clay
used in brick manufacture, red clays (e.g. Etruria Marl, Mercia mudstones) and
buff clays (fireclays). Currently, the only type of clay being produced in the Black
Country is Etruria Marl. This means that all of the other clays used by Black
Country brickworks have to be imported. Some works are also importing Etruria
Marl to supplement local supplies.
4.12 Operators have confirmed the importance of Etruria Marl to their business,
as it is a high quality but nationally scarce material. Some works are now
experiencing deficiencies in supply as permitted reserves in some Black Country 32
Wienerberger Finance Service BV / Baggeridge Brick plc: Final Report (10.05.07), Competition Commission, Appendix C
50
clay pits are running low. The number of years’ supply at each works can be
calculated from annual consumption rates and from estimates of the amount of
permitted reserves of clay remaining, where known.
4.13 Table A1a of Appendix 2 summarises the current supply of Etruria Marl to
each works at April 2009, compared to the Core Strategy plan period (i.e. 17
years 2010 - 2026). For reasons of commercial confidentiality, some information
has been excluded. The national policy requirement is for a 25-year supply (see
MPS1, Annex 2, paragraph 3.4). This would cover the period 2010 – 2035,
extending beyond the plan period. However, the lack of a complete data set and
non-disclosure of some information does not make it easy to plan for future
supplies.
4.14 The Black Country Minerals Study confirms that the Black Country Coal
Measures include seams of fireclay (see Map MC3 in Appendix 7 of the Core
Strategy), which is also an important raw material for brick manufacture. In the
past, fireclay was used for a variety of purposes including the manufacture of
refractories to line kilns and furnaces (this was once an important industry in the
Black Country), but it is now mainly used to make high quality facing bricks.33 In
the past bricks made from fireclay were occasionally used as a construction
material,34 and the Black Country Minerals Study notes that this may contribute
towards local distinctiveness.
4.15 Some Black Country brickworks use fireclay. The last site in the Black
Country to produce fireclay (Birch Coppice in Walsall) ceased operating several
years ago. There is a stockpile of fireclay from this site which is owned and
managed by a local supplier of pottery clay blends, Potters Clay & Coal
Company Ltd. This is used by the company to create pottery clay blends and
also for other uses, including export. However, the main sources of fireclay for
use in brick manufacture are the strategic stockpiles or “virtual quarries” at
33
Mineral Planning Factsheet: Fireclay (October 2006), BGS 34
A notable example of this is the Harris & Pearson Building at Silver End in Dudley, the former offices of a company which used to produce refractories. See website: http://www.harrisandpearson.info/
51
Caughley (Telford & Wrekin), Kingsbury (Warwickshire) and Donnington
(Leicestershire).
4.16 Some works also use other red clays which do not occur within the Black
Country, and these also have to be imported from outside the area.
Manufacturers have confirmed that red clays which do not occur locally (e.g. from
Mercia Mudstone) are “widely available” in other parts of the West Midlands
region.
4.17 As fireclay is only likely to be extracted in the Black Country as a by-
product of surface coal working, stockpiling has been suggested by the industry
as a means of providing long-term supplies of fireclay to Black Country brick
works. This would therefore need to be addressed in both clay and coal policies,
as the Black Country Minerals Study recommends.
4.19 The need to allow for importation of clays has also been identified as an
important issue as most brick works use a variety of clays and not all of them
occur locally/ are produced locally at the present time. They also use aggregates
as well as clays. All works import at least some material, although conditions on
planning permissions restrict the amount of material that some of them can
import. Table A2a of Appendix 2 summarises the proportion of imported material
permitted at each works.
Stakeholder Engagement
4.20 The following comments have been received from stakeholders in relation
to supply of brick clays:
• The Regional Conformity Panel commented that the JCS should more
clearly reflect the “hierarchical approach” towards mineral supply
advocated in national policy guidance (MPS1, paragraph 1);
52
• The British Ceramics Confederation has commented that the 25-year
supply requirement relates to each existing or proposed manufacturing
plant, not to aggregated supplies across the MPA area;
• The Regional Conformity Panel and neighbouring authorities have
sought clarification on which brickworks will be supplied and on how
cross-boundary supply issues (such as importation of materials
required for blending) will be addressed;
• Stakeholders have sought clarification on how supply deficiencies will
be addressed;
• The Regional Conformity Panel has commented on the need to identify
suitable locations for “strategic stockpiles” – this has also been
debated with neighbouring authorities;
• Environmental bodies have expressed concern about the impact of
clay extraction on environmentally sensitive areas and on how
potential detrimental impacts can be mitigated;
• Stakeholders have commented on the need to explore options for
sustainable transport of clay and bricks such as rail and inland
waterways.
Developing a Policy for Brick Clay Supply
4.21 There have been ongoing discussions between Dudley and Walsall
Councils, neighbouring MPAs, the regional planning body, the brick industry and
other users of local clays on the types of materials used in local brickworks,
where they come from, the current state of supply, and the potential to increase
supplies.
4.22 Direct one-to-one meetings and discussions with manufacturers have
been very important in developing the policy towards brick clay. For example, we
53
have learned from this that there are limits to how far we can go in encouraging
use of alternatives to virgin materials, in support of the hierarchical approach. For
economic reasons manufacturers are already maximising the use of raw
materials by reducing the clay content of bricks as far as possible, by recycling
wet clay off cuts, crushed fired waste (grog) and other materials, and by using
alternatives to primary aggregates.
4.23 It is estimated that around 10% of the materials used to make bricks
derive from alternative sources, called MARSS (materials of recycled or
secondary aggregates).35 Manufacturers say that the scope to increase this is
limited, and that achieving 15% MARSS would be challenging. The following
barriers to increased use of alternative materials have been identified:
• Quality – it needs to perform as well as virgin clay;
• Cost/ benefit – e.g. transport, companies may also charge more for the
material once they realise it has a value;
• Regulatory issues – classification of waste and requirements for
treating it and managing it;
• Reliability of supply – whether the source of waste used will continue to
be available on a regular basis.
Manufacturers are therefore likely to continue to rely on virgin clays as the main
source of material for bricks at least for the foreseeable future.
35
See: A Sustainability Strategy for the Brick Industry: An Update (2009), Brick Development Association
54
Etruria Marl
4.24 As Etruria Marl is the main brick clay used by Black Country brickworks
and the most important clay resource available locally, a key priority for the Core
Strategy is to identify potential new sources of this material, of sufficient quality to
meet the needs of the manufacturers, which can keep the Black Country
brickworks in production for as long as possible.
4.25 The Black Country Minerals Study shows that some of the resource areas
have already been worked out (see Black Country Minerals Study Figure 003),
and that much of the remaining resource is sterilised by urban development. The
main unsterilised resource areas remaining are in the Himley, Kingswinford and
Pensnett areas of Dudley, and in the Stubbers Green, Shelfield, Walsall Wood
and Brownhills areas of Walsall. The extent of clay resources is shown on Map
MC2 in Appendix 7 of the Core Strategy.
4.26 However, just because a resource exists, it does not mean that it can be
worked or that it will be suitable for making bricks. The suitability and viability of
the resource can only be established through stakeholder engagement. For
example, we know from this that the quality of clays is very important. Each of
the brickworks in the Black Country uses different machinery and makes different
products, so clays that may be acceptable to one factory may not be acceptable
to others.
4.27 We have also learned from the industry that the quality of the clay
resource varies across the Black Country. Some outcrops of Etruria Formation
clays are faulted, which means that the clays are mixed up with other materials
and may also have significant overburden, making them difficult or uneconomic
to work. This can also affect the quality and quantity of usable material. The
industry has therefore focused its interest on areas where investigations have
shown that clays of the right quality are present, and could be worked
economically.
55
4.28 In Dudley the remaining resource areas are restricted and constrained by
the proximity of existing/ proposed residential and employment areas,
recreational areas and nature conservation designations. The Dudley resource
areas also lie within Regeneration Corridor 10: Pensnett – Kingswinford where
new employment and housing development is proposed (see Figure 005 of Black
Country Minerals Study, Appendix 2 of the Core Strategy and Appendix 3 of
Sustainability Appraisal).36 As this is an employment-led corridor and most of the
areas surrounding the resources are to be retained in employment use, this need
not be incompatible with mineral working. However, if working is to continue in
the long-term, or even expand, potential conflicts with neighbouring uses must be
minimised.
4.29 The remaining resource areas in Walsall are larger and are less
constrained by proximity of residential areas and non-mineral development
proposals. Most of the resources in the Stubbers Green area are not badly
affected by faulting or overburden as areas, and the quality of the clay is
considered good, although in places there is a risk of flooding. However, the
resource areas to the north of the A461 are affected by overburden and faulting
and by nature conservation designations (see Figure 005 of Black Country
Minerals Study and Appendix 3 of the Core Strategy Sustainability Appraisal
Report).37 This means that difficult choices may have to be made about which
areas should be allowed to be worked.
4.30 The relationship of the resources to the brickworks is an important issue.
Brickworks are where they are for historic reasons – they are usually located
adjacent to their main source of supply. However, as the clay is a finite resource,
these reserves will reduce over time and when they dry up completely, this can
leave a brick works entirely reliant on imports. This has already happened to
Aldridge Works in Walsall and Stourbridge Works in Dudley. Sandown Works in
Walsall may suffer the same fate within the next few years if no new resources
36
Note: Appendix 3 of the Sustainability Appraisal Report (November 2009) by UE Associates shows a wider range of constraints than Figure 005 of the minerals study. Figures B-1 and B-4 of the Black Country Strategic Flood Risk Assessment (SFRA) (February 2009) by Jacobs also supersede the flood risk areas shown on Figure 005. 37
See note above.
56
can be identified. 38 Ketley Quarry in Dudley is also some distance from
Dreadnought Works which it supplies, although the supply to the works is secure
as both are in the same ownership.
4.31 Dudley MBC and Walsall Council have been engaging with the operators
of factories with the greatest deficiencies, with a view to identifying new sources
of supply if possible within the resource areas identified above. As a result of
these discussions, several potential future working areas were put forward.
Operators have also suggested that deeper working within existing permitted
areas may increase existing permitted reserves. However, this can only be
supported where it would not cause instability problems which might affect final
restoration.
4.32 The identification of areas for future working must also take into account
other important constraints and material considerations, such as proximity to
residential areas and other development areas, environmental constraints and
access/ highway capacity issues. Some potential resource areas have significant
constraints, for example, there are SSSIs covering parts of the resource area in
Walsall.39
4.33 Policy M3 of the Core Strategy proposes the following areas of search for
extraction of Etruria Marl, based on the resources identified through engagement
with manufacturers (including an additional area identified in Dudley):
• MA3: Himley/ Oak Farm (Dudley)
• MA4: Ketley (Dudley)
• MA5: Stubbers Green (Walsall)
38
Cradley Special Brick are also entirely reliant on imported material. The statement on page 55 of the Black Country Minerals Study is incorrect, with regard to their supply of fireclay. This factory uses relatively small quantities of different materials which are supplied by their parent company, Hanson. These arrangements are considered satisfactory and the company has not indicated it has any concerns about supply. 39
See: Figure 005, Black Country Minerals Study 2008 Final Report (March 2008), RPS Planning and Development and the Sustainability Appraisal of the Joint Black Country Core Strategy - Volume 3: Constraints Mapping (November 2009), UE Associates.
57
4.34 Table A1a in Appendix 2 shows how the additional resources would affect
supplies. This is the information underlying Table 21 in the Justification to Policy
WM3, but it should be noted that Table 21 does assume that imports will make
up shortfalls, which is by no means certain as there is no guarantee that suitable
material will be available in other areas. There is a Proposed Change (February
2010) to Table 21 of Policy WM3, to correct/ update the information in the table in
the light of the information presented in the Appendix to this Background Paper.
There are also concerns about the relative quality of the clays available
elsewhere, compared to the quality of the resources in the Black Country.
Discussions with the manufacturers and neighbouring MPAs suggest that there
are similar supply issues in adjoining parts of Staffordshire, which is the other
main source of Etruria Marl.
4.35 The permitted reserves and the other potential resources identified in the
areas of search are not sufficient to provide a 25 year supply of Etruria Marl to
each operational works, and they may not be sufficient to provide supplies to
2026 in some cases, even allowing for imports. However, the additional
resources in the areas of search should be sufficient to maintain supplies to the
main Black Country brickworks for at least 10 years (where requirements can be
quantified), and possibly longer if imports and deeper working are able to
supplement local supplies.
4.36 During the preparation of the Core Strategy no other areas with proven
resources suitable for brick making could be identified. The Core Strategy can
therefore only go so far in meeting future supply requirements, and where
shortfalls remain this will need to be addressed through other DPDs, if possible.
Unfortunately, as some operators have been unwilling to disclose supply
information, it is not possible to specify the tonnages of Etruria Marl required by
each works to maintain a supply to the end of the plan period and to maintain a
25-year supply.
4.37 However, it is possible to provide an estimate of the residual requirements
which Dudley and Walsall will need to plan for outside of the Core Strategy. This
information is presented in Table A2c of Appendix 2. These are minimum
58
requirements, as they do not include requirements for Stourbridge Works in
Dudley or Aldridge Works in Walsall, for which we have no confirmed data. It will
not be possible to plan for future supplies to these works unless the information
is forthcoming from the operator.
4.38 It will be seen from this table that whilst Dudley appears not to have any
residual requirements, Walsall has significant shortfalls in supply. There are no
guarantees that Walsall Council will be able to identify the resources required in
other DPDs, as this will depend on whether or not suitable resources can be
identified outside the Stubbers Green area of search. There may also be a need
for Dudley to identify further supplies for Stourbridge Works if the works re-
opens, and if the operator provides evidence that the resources within the area of
search are not sufficient.
Importation of Clay to Brickworks
4.39 Any material obtained from a clay pit not immediately adjacent to a works
is normally regarded as an import. Imports are likely to continue to play a role in
supplying Black Country brickworks, even though they may not be able to fully
address shortfalls in supply. For example, they allow brickworks to be supplied
with material which does not occur locally. However, increasing the level of
imports will inevitably have some impacts on the local highway network and
possibly local communities if haulage routes go through or near to residential
areas. Policy WM3 therefore sets out requirements for proposals to allow or
increase imports of clay to brickworks.
4.40 The definition of “imports” has been reassessed in the case of two of the
brickworks in Walsall (Atlas and Sandown) which are subject to restrictions on
imports, given their close relationship to the Stubbers Green area of search. As
the resource area at Stubbers Green is relatively self-contained and well-related
to these works and also to Aldridge Works, if these resources could be pooled or
shared between the works, haulage distances would be minimal. Walsall Council
has therefore agreed with the manufacturers that in this scenario (and subject to
satisfactory haulage arrangements), the haulage of material from the Stubbers
59
Green area of search to brickworks in Walsall will not be regarded as importation.
This is reflected in Policy MIN3.
Fireclay – The Case for Strategic Stockpiling
4.41 Identifying an adequate supply of fireclay to the brickworks which use this
material is currently not possible as there is no certainty that fireclay will be
extracted in the Black Country during the plan period. Brick manufacturers have
also noted that the need for fireclay is market-driven and fluctuates according to
demand for buff bricks so it is difficult to predict future requirements.
4.42 As fireclay occurs naturally as a layer beneath coal seams, it is not easily
accessible or economic to work on its own. Supplies are therefore only likely to
be obtained as a by-product of surface coal working, if this happens in the future.
The most likely source for coal and fireclay in the Black Country is the Brownhills
area of Walsall, although we do not know whether the fireclay resources are of
the right quality for making bricks and this can only be confirmed by testing.
4.43 As well as being recommended by the Black Country Minerals Study,
stakeholders have commented on the need to identify locations for stockpiling of
clay, and the RSS Phase 3 Revision has sought to address the possible need for
“strategic stockpiles” or “virtual quarries” where clay can be stored on a long-term
basis and used by brick manufacturers as and when required. The need for
surface coal working to provide fireclay (where feasible) is addressed in Policy
MIN4 (see Section 5 for details), and the need for strategic stockpiling is
addressed in Policy MIN3.
4.44 There is already one stockpile of fireclay operating in the Black Country at
Birch Coppice in Walsall, but this is not a large resource. There are Proposed
Changes (February 2010) to Policy MIN3, the Policy Justification and the
Proposals Map to reflect the existence of this resource and to correct factual
inaccuracies, in response to comments received from Potters Clay & Coal
Company at the publication stage. The evidence therefore points to a need to
make provision for further stockpiling, as this is likely to provide the only means
of ensuring long-term supplies of fireclay if extraction takes place. This is
60
because surface coal working tends to be a relatively rapid operation which does
not lend itself to supplying limited amounts of material on a regular basis, in the
way that brick works or pottery clay suppliers would require.
4.45 However, brick manufacturers have pointed out that stockpiling only works
if the whole scheme, from extraction to storage, is properly thought out, having
regard to the needs of the industry. For example:
• The extraction process needs to be designed with clay extraction in
mind and needs to have a direct input from the industry to ensure that
the material extracted is of the right quality for brick making. Testing
should be done prior to extraction, to check the quality of the material
and determine how extraction should proceed.
• Different batches of clay may also need to be stockpiled separately to
maintain quality control. Limitations of space and costs usually
prohibits stockpiling on-site at brickworks, therefore separate
stockpiles are needed in suitable locations elsewhere.
• With fireclay, quality control is very important because different users
have different requirements. For example, material suitable for pottery
making may not be suitable for brick-making.
4.46 Donnington (Leicestershire) was quoted as an example of stockpiling
which had worked reasonably well. This was a large coal and fireclay extraction
scheme carried out by a consortium of operators including brick manufacturers.
The material extracted had been sorted into a number of different stockpiles each
of which had been allocated to the consortium members. Although the stockpiles
were not intended to last beyond 1984 there is still material remaining. At
Caughley (Telford & Wrekin), both red and buff clays are stockpiled as different
layers within a “virtual quarry.”
4.47 The Donnington experience suggests that strategic stockpiles could have
a very long life, and could also be visually intrusive without adequate mitigation.
They will also generate significant HGV movements on the highway network both
61
during the stockpiling process, and afterwards, as and when the clay is removed.
They are therefore not the kind of proposal that either Dudley MBC or Walsall
Council will be prepared to approve anywhere within their administrative area
unless they are carefully designed and landscaped, to avoid harmful visual
impacts. The transport and amenity impacts of strategic stockpiling must also be
fully addressed.
4.48 There is at present insufficient evidence to support the identification of
specific locations for “strategic stockpiles” at the present time, although logic
suggests that strategic stockpiles should be conveniently located to the
brickworks which will be using them. It cannot be assumed that the existing
stockpile at Birch Coppice is the most appropriate location for a strategic
stockpile serving several brickworks. Policy MIN3 sets out appropriate guidance
on the location of such stockpiles and requires proposals to be well-related to
both the likely sources of fireclay and the brickworks which would be supplied,
and to address visual impacts/ impacts on the character of the landscape,
accessibility and impact of transportation of material on the highway network and
local communities. The manufacturers’ concerns about the methods of
extraction are reflected in Policy MIN4.
62
5. Policy MIN4: Exploitation of Other Mineral Resources
5.1 Coal and New Coal Based Energy Technologies
Black Country Minerals Study – Key Findings and Recommendations
5.1.1 The Black Country Minerals Study found evidence of considerable coal
resources in the Black Country, mainly in Dudley and Walsall. Although much of
the resource is sterilised by built development, there is evidence that resources
in the Brownhills may be viable. The Study also noted the potential role of coal in
providing a secure, diverse and sustainable energy supply in line with the
Government’s current policy on energy,40 and the potential of new / emerging
coal based energy technologies such as coal bed methane and underground
coal gasification.
5.1.2 The Study recommended the following action with regard to coal and coal
based energy technologies:
• Spatial approach – supply of minerals needs to be linked to other
spatial issues such as economy, environment, growth,
regeneration, health, transport, climate change and waste (1.4.1);
• Joined-up approach – need to work with adjacent authorities on
minerals to resolve regional and cross-boundary issues (1.4.1);
• The scope for coal extraction and coalbed methane exploitation
should be explored, although the scope for coal extraction may be
limited given the environmental and amenity constraints (1.3.25 –
1.3.28);
• Where Natura 2000 Sites may be affected by mineral working
proposals the Core Strategy should demonstrate that this would not
harm their integrity.
40
See: Meeting the Energy Challenge: A White Paper on Energy (May 2007), HM Government, Chapters 4 and 5
63
Evidence Base - Update
5.1.3 The coal resources in the Black Country form part of the South
Staffordshire Coalfield, and their general extent is shown in Figure 002 of the
Black Country Minerals Study (Summary Geology). As well as coal, the Coal
Measures contain ironstone and fireclay which have also been exploited in the
past. It is not clear whether there is any demand for ironstone, but as mentioned
above (see Section 4) there is a demand for fireclay from local brick
manufacturers and also from a local supplier of pottery clay blends.
5.1.4 The following new evidence has become available since the Study was
prepared:
• Surface Coal Area Mapping has been provided to the authorities by the
Coal Authority. This mapping project by the BGS was completed in the
spring of 2008 and was unfortunately not available in time to inform the
Black Country Minerals Study;
• Evidence of the need and demand for fireclay has been reviewed and
discussed with the relevant stakeholders;
• Evidence on potential for new and emerging coal-based technologies
has been reviewed and discussed with the Coal Authority.
5.1.4 Map MC3 in Appendix 7 of the Core Strategy shows the extent of coal
resources in the Black Country, including surface coal resources (i.e. resources
of 30 – 50 m depth) identified by latest BGS mapping, supplied to MPAs under
licence by the Coal Authority. As the Black Country Minerals Study has noted,
most of these resources are sterilised by built development, although there may
be potential to exploit these resources through prior extraction in advance of
redevelopment (see Section 2 and Policy MIN1). The Black Country Minerals
Study identifies significant coal resources in the Pelsall and Brownhills areas of
Walsall. The new surface coal resource data confirms that the main areas of
64
unsterilised resources are on the southern fringes of Dudley (south and west of
Halesowen) and on the north-western fringes of Walsall (Pelsall and Brownhills).
5.1.5 The scope for working the resources in Dudley is not known. The
unsterilised resources in Walsall are in the Green Belt areas to the west of
Regeneration Corridor 15: Brownhills (see Appendix 2 of the Core Strategy). Any
future proposals for surface coal and clay working would need to be carefully
designed to avoid unacceptable impacts on existing and proposed residential
areas in and around the Corridor. Some of the unsterilised coal resource areas in
Walsall are also important for nature conservation, for example, Brownhills
Common and The Slough SINC/ proposed Local Nature Reserve.
5.1.6 There is currently no requirement in national policy guidance to identify
sites for the working of coal. Only a small proportion of the total coal resource in
the UK is currently economically workable, and surface working is more likely to
be viable than deep mining. The economic potential of surface coal resources
can only be confirmed through testing.41 Coal has been exploited in Walsall in
the recent past, so it is possible that proposals might come forward within the
plan period, particularly in the light of increasing concerns about energy security.
5.1.7 The last surface coal working scheme in the Black Country, at Ryders
Hayes in Walsall, did not happen very long ago (1998 – 2001). There is also a
“dormant” permission for coal and clay working at Brownhills Common dating
back to the 1950s which could be activated at any time on submission of a
schedule of “modern” conditions to Walsall Council in accordance with the
Environment Act 1995, and there has also been interest in working in the areas
to the west of Brownhills Common. As this is an existing commitment, it is
proposed that the location of the dormant permission at Brownhills Common
should be shown on the Minerals Key Diagram, on Corridor Map 15 and on the
Walsall Proposals Map.
5.1.8 The permission covering Brownhills Common also covered another site to
the south, Birch Coppice, which was worked during the 1950s and 1960s. 41
See MPG3: Coal Mining and Colliery Spoil Disposal (March 1999), ODPM and Summary of Information on Coal For Land-Use Planning Purposes (2006), BGS for CLG
65
Significant quantities of fireclay as well as coal were taken out of the Birch
Coppice site as well as out of Ryders Hayes, and a stockpile of this material still
remains. It is believed that resources of similar quality exist at Brownhills
Common. The operator of the stockpile, Potters Clay & Coal Company Ltd, has
confirmed that they are of excellent quality for pottery clay blends. However, the
properties required for potting clays are different to the properties required for
brick clays, so it is uncertain whether the fireclay resources in Brownhills are also
suitable for brick making.
5.1.9 Although surface coal and clay working is a relatively short-lived activity
compared to other mineral operations, and final restoration can be beneficial, the
impact of the mining process can be considerable, involving the removal of
significant quantities of overburden and transportation of large quantities of
material away from the site. It is therefore recognised in national policy guidance
that there should normally be a presumption against coal working unless a
proposal would meet certain environmental acceptability tests42 and existing
“saved” UDP policies reflect this (see Dudley UDP Policy M4, Sandwell UDP
Policy M5, Walsall UDP Policy M9 and Wolverhampton UDP Policy EP18). There
are Proposed Changes (February 2010) aimed at addressing inconsistencies
between MIN4 and national policy guidance, in response to comments by the
Coal Authority, Potters Clay & Coal Company and the Wyrley Estate at
publication stage.
Stakeholder Engagement
5.1.10 Stakeholders have commented as follows:
• Environmental bodies have highlighted the potential environmental and
amenity impacts of mineral working and have argued that it should be
minimised as far as possible;
42
See MPG3: Coal Mining and Colliery Spoil Disposal (March 1999), ODPM, paragraph 8
66
• The Regional Conformity Panel and neighbouring MPAs have
highlighted the need to work together on minerals, and that identifying
future supplies is a collective responsibility;
• GO-WM has queried the need for so many minerals policies/ for
policies on coal and natural building stone, although the latter has
been supported by the Coal Authority and English Heritage;
• Natural England has commented that Brownhills Common is of
sufficient quality to be designated as a SSSI;
• The Wyrley Estate has put forward a proposal for coal and fireclay
working at Yorks Bridge, to the west of Brownhills Common;
• Staffordshire County Council and Cannock Chase District Council have
objected to Yorks Bridge on various grounds, and have questioned its
deliverability;
• The Coal Authority has also commented on the need to address the
safety and stability issues arising from the legacy of former mineral
working.
Developing a Policy for Coal/ Fireclay and New Coal Based Energy Technologies
The Potential for Coal and Fireclay Working
5.1.11 The GO-WM has queried the need for a policy on coal as this is not a “pan
Black Country issue.” However, there are other non-pan Black Country issues
which the GO-WM has not objected to, such as the identification of locations for
primary sand and gravel extraction. National policy guidance advises that
structure plans and Part 1 of UDPs should set out strategic policies on coal,43
suggesting that this does belong in the Core Strategy rather than in another
43
MPG3: Coal Mining and Colliery Spoil Disposal, paragraph 37.
67
DPD. The inclusion of policy guidance on the working of coal and fireclay is also
supported by the Coal Authority.
5.1.12 Furthermore, the exploitation of coal through surface working is likely to
be the only means of providing supplies of fireclay to brickworks in the
foreseeable future. A policy on this is considered to be justified to avoid needless
waste of resources. This will ensure that where coal working is permitted,
opportunities to extract fireclay are not missed, and that material of sufficient
quality for brick manufacture is extracted and made available to local end users
in ways that will meet their needs. The requirements in Policy MIN4 reflect the
comments received from brick manufacturers during stakeholder engagement
(see paragraphs 4.35 – 4.42 above).
5.1.13 Walsall Council is not aware of any current proposals for working the coal
at Brownhills Common, but there can be no objection to this in principle as a
“dormant” permission already exists. However, working could only commence on
the submission of a schedule of modern conditions, so Policy MIN4 includes
guidance on what such conditions should cover. If such a proposal came forward
it would be unfortunate, because this area has significant nature conservation
value and is an important recreational resource for local communities (see
paragraph 5.1.5 above and Volume 3 of Core Strategy Sustainability Appraisal
Report). Although Natural England has commented that the SINC is of sufficient
quality to be designated as a SSSI, this has not yet happened.
5.1.14 The Yorks Bridge proposal has been the subject of earlier discussions
between the landowner (Wyrley Estate) and Walsall Council. The cumulative
impact of working both Yorks Bridge and Brownhills Common is likely to be
unacceptable to Walsall Council, given the impact that this would have on nature
conservation sites, the amenity of local communities, and the local transport and
canal networks. Working at Yorks Bridge is only likely to be acceptable to Walsall
Council if it can be demonstrated that the environmental, amenity and transport
constraints can be successfully overcome, and if, through negotiation with the
various interested parties, this would lead to the permanent revocation of the
68
permission at Brownhills Common. Walsall UDP Policy M8 makes reference to
this.
5.1.15 The Yorks Bridge proposal covers a large area, extending beyond the
Walsall Borough boundary into Staffordshire (Cannock Chase District). The
boundary is shown on a plan supplied with the Wyrley Estate’s representation on
the Core Strategy Issues and Options. They also put the site forward as a
strategic mineral proposal during consultation on options for the Staffordshire
Minerals Core Strategy.44 Coal and clay working at Yorks Bridge would therefore
require the approval of Staffordshire County Council as well as Walsall Council.
5.1.16 Officers from Walsall Council and Staffordshire County Council met with
Wyrley Estate and their representatives in February 2008 to discuss the Yorks
Bridge proposal. During the discussions, a number of potential constraints to
working were noted:
• Potential impact on Cannock Extension Canal SSSI and SAC - Habitats
Directive requires an assessment demonstrating that the proposal will not
harm the integrity of the site;
• Potential impact on Brownhills Common and The Slough SINC and
proposed LNR, part of which is within the proposal site;
• Potential impact on local communities in the Brownhills area, and impact
of uncertainty about timescale on Core Strategy proposals for this area
(Regeneration Corridor 15);
• Potential impacts on the highway network – there is unlikely to be scope to
transport material by rail, and the feasibility of transporting it by canal is
unproven.
44
See Site Profile, available on Staffordshire County Council website at: http://www.staffordshire.gov.uk/environment/developmentcontrol/planning/policy/mineralsWasteDevelopmentFramework/mineralsDevelopmentPlanDocuments/Potential+Site+Options.htm
69
5.1.17 It was also noted that the proposal might bring benefits in terms of lifting
the threat to Brownhills Common, restoring degraded areas at Wyrley Common
(in Cannock Chase District), and addressing unmet demand for fireclay.
However, it was clear from the discussion that the proposal is still at a relatively
early stage, for example, no ecological report or Habitats Regulations
Assessment has been carried out.45
5.1.18 The economic viability of working these resources is uncertain. There
appears to be more winnable clay than coal at Brownhills Common and Yorks
Bridge, suggesting that at the moment it is not economic to work them. It was
implicit in the discussions with Wyrley Estate and Potclays Ltd that end users
would need to be found for both the clay and the coal to make the Yorks Bridge
project viable. The Yorks Bridge proposal is also being promoted by the
landowner rather than by any of the main players in the coal industry, such as UK
Coal or Parkfield Estates.
5.1.19 This suggests that future proposals for coal and clay working in
Brownhills may be driven more by the demand for the clay than the demand for
the coal - assuming of course that the quality of the clay fulfils the requirements
of the brick industry and that it is economic to work it. Brick manufacturers have
also indicated that the need/ demand for fireclay fluctuates, making it difficult to
predict future requirements. Thus, there is no certainty that either of these sites
could be worked economically within the plan period.
5.1.20 Walsall Council therefore considers that there is insufficient evidence to
support the allocation of Yorks Bridge as a mineral working proposal in the Core
Strategy. The proposal is not essential to the delivery of the strategy and may
cause harm to key environmental assets and local communities. The long-term
benefits of the proposal following restoration may therefore outweigh the harm
caused by it, in which case, far from supporting the strategy it would conflict with
Spatial Objectives 6 and 8. Nevertheless, surface coal and clay working cannot
be ruled out completely, so there is a need for locally specific guidance, setting
out the key issues that need to be addressed if an application does come
45
Walsall Council is not aware that any such assessment has been carried out.
70
forward. There are Proposed Changes (February 2010) to Policy MIN4 and the
Policy Justification, aimed at clarifying the status of the Brownhills Common and
Yorks Bridge proposals, their relationship to each other, and the position of
interested parties, in response to comments made by Potters Clay & Coal
Company, the Wyrley Estate, Staffordshire County Council and Cannock Chase
District Council at publication stage.
5.1.21 The “saved” UDP Policies M8 and M9 provide guidance against which
proposals at Brownhills Common and Yorks Bridge could be considered if they
came forward in advance of the Core Strategy. It is proposed to replace them
with the guidance in Core Strategy Policy MIN4 and the justification to this policy,
so that key policies towards minerals are contained in the same place. However,
if it is decided that there should not be a policy on coal in the Core Strategy,
Walsall Council will wish to retain UDP Policies M8 and M9. The situation has not
changed significantly since the UDP was adopted and these policies remain up-
to-date and relevant.
Addressing the Legacy of Previous Mining Activity
5.1.22 Legacy issues raised by the Coal Authority are a delivery / viability issue
rather than a minerals issue. The Stage Two Infrastructure and Deliverability
Study has considered geotechnical risks to delivery of the strategy, and identifies
the areas of the Black Country which have been subject to underground coal and
limestone mining in the past.46 This indicates that much of the central part of the
Black Country is affected, with most of the Regeneration Corridors having had
some previous mining activity.
5.1.23 However, as this was a high level assessment, more detailed risk
assessments will need to be undertaken at a local level to determine constraints
affecting specific sites or areas. The Coal Authority has recently provided the
authorities with more up-to-date information about previous mining activities in
46
See Black Country Joint Core Strategy: Stage 2 Infrastructure and Deliverability Study
(November 2006), Mott MacDonald, Technical Note 6: Ground Risk and Mineral Extraction, Section 1.2.2, Table 3 and Figure 5.
71
the Black Country. This information became available too late to influence the
Core Strategy, but will help the authorities to identify risks affecting specific sites
and areas when planning development at a more local scale through other
DPDs.
5.1.24 Section 2e of the Core Strategy “Delivering Our Vision” acknowledges the
legacy of previous mining activity and identifies land remediation as a priority for
delivery intervention. It is also recognised that remediation and stabilisation
schemes play an important role in bringing forward new development and may
be undertaken in association with extraction of mineral resources. The Core
Strategy mineral policies therefore address the legacy of previous mineral
working through Policy MIN1 which covers mineral safeguarding. Policy MIN5
also requires new mineral working proposals and restoration programmes to
include measures to maintain stability, to prevent future problems. There are
Proposed Changes (February 2010) to the published Policies CSP4 and MIN4,
aimed at addressing outstanding concerns about legacy issues expressed by
the Coal Authority at the publication stage.
The Potential for New Coal Based Energy Technologies
5.1.25 National policy guidance requires MPAs to consider options for
exploitation of coal bed methane and underground coal gasification in areas with
potential for these technologies (MPS1, Annex 3). This was also highlighted in
the Black Country Minerals Study.
Coal Bed Methane
5.1.26 Coal bed methane (CBM) can be recovered commercially from old mines
or coal resource areas which were not mined previously because it was either
unsafe or uneconomic to do so. 47 As well as providing a new source of energy,
exploitation of CBM also minimises the potential for this potent greenhouse gas
to escape into the atmosphere.
47
See Mineral Profile: Coal (February 2007), BGS, Section 8
72
5.1.27 The main requirement for exploiting virgin coal bed methane (VCBM) is
an unworked coal seam thicker than 0.4m at depths of between 200 – 1200m.
The Black Country may therefore have some potential for this although the
resource mapping undertaken by the BGS does not appear to have identified the
Black Country as an area of “Good CBM Potential” (this is difficult to tell from the
scale of the maps available).48
5.1.28 The authorities are not aware of any interest in CBM exploration in the
Black Country, and the Coal Authority has confirmed that no licences have been
granted to prospect for it in the area to date. However, licences have been
granted in other parts of the South Staffordshire Coalfield (Cannock Chase &
Lichfield). If a viable resource is found there, there may be interest in prospecting
for CBM in adjoining parts of the Black Country, and we cannot rule out the
possibility that this will happen within the plan period.
5.1.29 Extraction of CBM is regulated partly by other licensing regimes and partly
by the planning system. A Petroleum Exploration Development Licence (PEDL)
is required to “search for and bore for and get” CBM. Licences are issued by the
Department for Energy and Climate Change (DECC) through a “bidding”
procedure. A PEDL allows prospecting within a particular grid square and gives
the holder the right to prospect for methane within the area and to exploit any
methane present. However, a Coal Access Agreement must also be obtained
from the Coal Authority to drill through any coal seams. Planning permission is
also required to extract CBM (though it may not be required for boreholes sunk
for testing purposes), and for the pumping apparatus.
5.1.30 Extraction of CBM is not like a normal quarrying operation. Like oil, the
gas is pumped from underground and transported via pipes, and therefore does
not require transport by road or rail. The pumping apparatus is in the form of a
small wellhead or rig around 8 – 18m tall which occupies a site of around 0.3 ha.
The main spatial planning issues are likely to be noise and visual impact from the
pumping apparatus. There is some flexibility over where the apparatus can be
48
Maps of the UK are available in Mineral Planning Factsheet: Coal and Coalbed Methane (October 2006), BGS (Figure 6) and Mineral Profile: Coal (February 2007), BGS (Figure 8.3.2).
73
located, but this is to a large extent dictated by the location of the underground
resources. As these resources can cover a wide area, the apparatus may have to
move around to exploit them fully.
5.1.31 Policy MIN4 recognises that there may be potential for exploitation of
CBM within the plan period, and explains what action will be taken if a PEDL is
issued. It also provides interim guidance on the information proposals for CBM
exploitation will be expected to provide, with regard to the duration of the
operations, siting, and the need for appropriate screening to minimise noise and
potentially harmful visual impacts.
Underground Coal Gasification
5.1.32 Underground coal gasification (UCG) requires coal seams more than 2m
thick at depths of between 600 – 1200m. The scope for this in the Black Country
is unclear. Information published by BGS appears to suggest there is some
potential for UCG in the general vicinity of the area. However, the authorities are
not aware of any interest being shown in UCG in the Black Country. The Coal
Authority has confirmed that this technology is not at an advanced stage, and
there are also significant constraints to this technology compared to CBM.
Provision has therefore not been made in the Core Strategy for UGC, but if the
situation changes this can be addressed through a future review.
5.2 Natural Building Stone
Black Country Minerals Study – Key Findings and Recommendations
5.2.1 The review of the geological data shows that much of the area’s natural
building stone resources (particularly limestone and dolerite) have been sterilised
by built development. However, the Study suggested that there may be
resources that could be exploited to provide resources for conservation of historic
buildings.
5.2.2 The Study recommended the following action:
74
• Joined-up approach – need to work with adjacent authorities on
minerals to resolve regional and cross-boundary issues (1.4.1);
• The scope and potential need for natural building stone should be
considered (1.3.29 – 1.3.31).
Baseline Evidence - Update
5.2.3 There have been no improvements to the baseline evidence for natural
building stone resources since the Black Country Minerals Study was prepared.
However, the following developments have occurred:
• Mineral Extraction and the Historic Environment – final version
of this guidance has been issued by English Heritage;
• Historic Stone – a new project to source historic stone for
conservation projects been launched by a quarry operator in
Staffordshire;
5.2.4 The Black Country Minerals Study identifies significant natural stone
resources in the Black Country. These are Silurian and Devonian limestone in
Sedgley and Dudley Town Centre and in Rushall and Walsall Town Centre,
dolerite in various locations, and building stones (mainly sandstones) from the
Halesowen formation in Halesowen and the surrounding areas of Dudley. The
extent of these resources is shown on Maps MC1 and MC2 in Appendix 7 of the
Core Strategy.
5.2.5 Natural building stone is not currently worked in the Black Country. The
last stone quarry, Edwin Richards in Sandwell, closed in 2007. This was
producing dolerite, but for use as aggregate rather than as a building stone.
Historically, local stone has not played a major role in building construction in the
Black Country. This is because most of the natural building stone resources
available locally are of poor quality compared to alternatives, such as brick.
75
However, there are exceptions to this general rule in parts of Dudley, where
historic buildings made from locally quarried building stones do contribute to local
character and distinctiveness.
5.2.6 Conservation officers have confirmed that the following local building
stones are important to the historic environment:
• Limestone (Gornal Stone) – a grey/ white stone quarried and
used mainly in the Gornal, Sedgley and Dudley areas, for example,
Dudley Castle and the Earl of Dudley’s Fountain in the Market
Place, Dudley;
• Dolerite (known as Rowley Rag) - a hard, black basalt quarried
from various sites and used mainly in stone setts and kerbs
throughout the Black Country and beyond;
• Halesowen Sandstone – red sandstone quarried and used mainly
in the Halesowen area and adjoining parts of north Worcestershire,
for example, in the church of St. John the Baptist in Halesowen and
Halesowen Abbey ruins.
Stakeholder Engagement
5.2.7 Stakeholders have commented as follows:
• GO-WM and the Regional Conformity Panel have queried the need for a
policy and have suggested this could be addressed through policies on
mineral safeguarding and local character and distinctiveness or through
other DPDs;
• English Heritage, CPRE (Staffordshire) and the Black Country
Geodiversity Partnership have expressed support for the policy;
• AWM has commented that it is sustainable to source material locally.
76
Developing a Policy for Natural Building Stone
5.2.7 National policy guidance advises that authorities should consider the need
for natural building stone (MPS1, Annex 3). However, the GO-WM and the
Regional Conformity Panel have queried the need for a policy on this. The
authorities feel that general principles for the exploitation of these resources
belong in a strategic plan such as the Core Strategy rather than in another DPD.
The inclusion of policy guidance on natural building stone is also supported by
English Heritage.
5.2.8 There is increasing interest in natural building stone at a national level.
The new English Heritage good practice guide highlights the importance of this in
maintaining historic fabric and local distinctiveness.49 English Heritage and the
BGS are also working with geologists and conservation specialists to develop a
Strategic Stone Study for each county area in England.50 This will identify and
catalogue the most important stones used in local historic buildings and potential
sources of supply. It is hoped that the technical work undertaken for the Black
Country Core Strategy will inform this study.
5.2.9 Although the Black Country Minerals Study confirms the existence of
natural building stone resources in parts of the Black Country, it is not certain that
anyone will wish to work these resources in the future. The only circumstances
where this is likely to happen are if materials are needed for the repair and
conservation of historic buildings or structures built out of the same materials. As
blasting is not necessary for the working of stone as a building material (as is
normally the case with stone quarried as aggregate), with appropriate screening
and mitigation,51 working could take place on a small-scale without causing
unacceptable harm to neighbouring uses.
49
Mineral Extraction and the Historic Environment (January 2008), English Heritage 50
See: http://www.bgs.ac.uk/mineralsuk/minequar/stones/eh_project.html 51
Mineral Planning Factsheet: Building and Roofing Stone (March 2007), BGS
77
5.2.10 The authorities have recently been approached by a quarry operator in
Stoke-on-Trent who is developing a new project called “Historic Stone.”
Essentially, the operator will act as a “broker,” identifying sources of natural
building stone that become available through quarrying activities, and supplying it
to those who require it for conservation projects. His aim is to minimise waste of
stone that may be present within quarries extracting other materials, and on
redevelopment sites.
5.2.11 Discussions with this operator indicate that viability can be a significant
issue for contractors seeking supplies of small quantities of natural building
stone. It also suggests opportunities to extract natural building stone through
“prior extraction” can often be missed, as developers may not be aware of the
potential demand/ value of the material. The Core Strategy therefore aims to
address the supply issue in the following ways: through the mineral safeguarding
policy (MIN1), which aims to minimise needless waste of mineral resources,
through an “enabling” policy for extraction of natural building stone (MIN4), where
this may prove viable, and through the general policy on mineral working (MIN5),
which requires operators to minimise waste and extract all potentially useable
materials.
5.2.12 The evidence base for natural building stone resources could also be
further developed to provide better information to developers on the resources
likely to be present within different areas, and details of those who may be
interested in using them, for example, local conservation officers, English
Heritage, and a contact for the Historic Stone project.
78
6. Policy MIN5: New Proposals for Mineral Development
Black Country Minerals Study – Key Findings and Recommendations
6.1 The Black Country Minerals Study identified a range of potential positive
and negative effects from mineral working and processing in the Black Country.
6.2 The main positive impacts identified are: potential to utilise waste to
provide alternatives to primary land-won aggregates, potential to support the
growth and development proposed in the strategy, potential of locally sourced
materials to promote local distinctiveness and support conservation of the built
environment, potential to provide a source of energy (in the case of coal), and
potential to contribute positively towards environmental enhancement through
appropriate restoration and after-uses.
6.3 The main negative impacts identified are: potential impacts on
internationally and nationally important environmental assets (e.g. SSSIs/ SACs)
and water resources, potential to exacerbate flood risk, potential conflict with the
Urban Park initiative, potential impacts on local communities, and impacts on air
quality and climate change from processing and the transportation of minerals by
road.
6.4 The Study included the following recommendations on balancing the
positive and negative aspects of mineral working:
• Spatial approach – supply of minerals needs to be linked to other
spatial issues such as economy, environment, growth,
regeneration, health, transport, climate change and waste (1.4.1);
• Where Natura 2000 Sites may be affected by mineral working
proposals, the Core Strategy should demonstrate that this would
not harm the integrity of the protected habitats (1.13.22);
79
• Existing and future mineral developments should reflect/ contribute
positively towards green infrastructure objectives (e.g. Landscape
Action Plan, Urban Park, BAP and GAP) (4.13.24 - 4.13.25 and
4.13.36);
• Community buffer zones may be necessary to protect local
communities from mineral working and to support the Urban Park
objectives (4.13.28, 4.13.37, 4.13.40);
• Mitigation of potential impacts of mineral working can be achieved
through progressive restoration, siting of processing plant away
from sensitive land uses, imposing conditions to limit vehicle
movements, hors of working, noise and dust, and through
landscaping to minimise visual impacts (4.13.29);
• Mineral working should not be permitted if it would cause
unacceptable harm to important environmental assets, though the
degree of protection given to such assets may vary according to
their relative importance (4.13.33 – 4.13.34).
Baseline Evidence - Update
6.5 The following new evidence has become available since the Study was
completed:
• The Black Country Core Strategy Phase One Environmental
Infrastructure Guidance (2009), carried out by the Black Country
authorities, has provided up-to-date mapping of key environmental
assets in the Black Country;
• The Black Country Core Strategy Strategic Flood Risk
Assessment (February 2009) by Jacobs Babtie – final version is
now complete and this has defined areas at risk of flooding in the
Black Country;
80
• The Black Country Core Strategy Outline Water Cycle Study
and Scoping Surface Water Management Plan (September
2009), by Scott Wilson, has considered risks to water supplies;
6.6 Mineral working is a highly regulated activity. Working is controlled in a
number of ways, not only through the planning system but also through pollution
control legislation and also by conditions imposed on working permits. Action can
be taken against operators who breach the conditions of their permits.
6.7 In the Black Country, the most important unsterilised mineral resources
can be found in the Green Belt areas. Although they are generally not sterilised
by non-mineral developments, these resources are not without constraints. For
example, they may be close to the edge of the built-up area, within sites
designated for their importance for biodiversity / geodiversity, or near to areas
containing important water resources.
6.8 When defining areas of search for mineral working, the most sensitive
areas (including SSSIs) have been excluded. Constraints affecting particular
resource areas and areas of search are highlighted in the minerals policies
(MIN2 – MIN4), and mineral working proposals will be required to demonstrate
that potentially harmful effects have been addressed. To minimise the cumulative
effects of mineral working on particular areas, new mineral extraction proposals
within the areas of search will also be required to demonstrate that progress is
being made on restoring areas already worked.
6.9 It is also recognised that requirements for restoration programmes should
support the overall spatial strategy for the Black Country. As the Black Country
Minerals Study has noted, the proximity of mineral resource areas to the urban
areas provides opportunities for mineral working to make a positive contribution
towards the Black Country’s environmental infrastructure, through appropriate
landscaping and restoration schemes which are designed to reinforce and
enhance local character and provide opportunities for biodiversity, geodiversity,
and outdoor sport and recreation which might not happen otherwise. In some
81
cases, mineral working may also provide opportunities for new archaeological
investigations, adding to our knowledge of the past.
6.10 The potential negative impacts of mineral working are well understood and
in general terms these are covered in national policy guidance. MPS2:
Controlling and Mitigating the Environmental Effects of Mineral Extraction in
England covers the use of planning conditions, potential impacts on local
communities, and how to manage impacts through the use of Environmental
Management Standards. There are also annexes on Noise and Dust which
explain how these impacts should be addressed. There is no need to repeat
these requirements in the Black Country Core Strategy. Any policy setting out
general requirements for mineral working must therefore focus on addressing
issues of particular local concern.
6.8 There are other Core Strategy policies covering environmental issues,
such as environmental infrastructure (CSP3), nature conservation (ENV1),
historic character and local distinctiveness (ENV2), design quality (ENV3), canals
(ENV4), flood risk, sustainable drainage systems and urban heat island (ENV5),
and open space, sport and recreation (ENV6). These policies are underpinned by
the updated baseline evidence on environmental infrastructure, sports and
recreation infrastructure, flood risk and water resources.
6.9 However, it was felt that there was a need for a general policy on mineral
development proposals, setting out the requirements that proposals should
address, such as the information that should be included with applications,
issues of particular local concern which need to be addressed, and the criteria
which will be used for assessing new proposals.
Stakeholder Engagement
• Environmental bodies have highlighted the potential environmental and
amenity impacts of mineral working and have argued that it should be
minimised as far as possible;
82
• The Black Country Geodiversity Partnership has commented that the
minerals policy should provide opportunities to promote geodiversity/
create new geological exposures;
• Councillors representing Aldridge and Walsall Wood have objected to
further quarrying and landfilling in the Aldridge and Stonnall areas of
Walsall, due to impacts on the amenity of local communities and the
local highway network.
Developing Guidance for New Mineral Developments
6.10 The Government Office for the West Midlands has advised that policies in
the Core Strategy should be locally specific and avoid repeating national policy
guidance. The minerals policies should therefore reflect the overall strategy for
the area and include policy criteria directly linked to the strategy for the area, and
aimed at addressing specific issues of local concern, rather than merely
repeating the general guidance that applies nationally, or repeating the guidance
contained elsewhere in the Core Strategy.
6.11 The authorities have considered the Black Country Minerals Study
recommendation that “community buffer zones” should be defined around
existing and potential mineral working areas. However, we cannot be prescriptive
about this, as it is possible for mineral working to take place close to sensitive
areas, provided that adequate mitigation is in place. The key recommendation in
national policy guidance is that distance separation should be “adequate” (see
MPS2, paragraphs 24 – 29). The guidance also makes it clear that MPAs are
entitled to reject proposals which are so close to residential properties that
harmful effects cannot be adequately mitigated.
6.12 In the Black Country there is a potential tension between the need to allow
mineral production to support regional requirements and development within the
Growth Network, and the objectives of environmental transformation and
retention of population/ attracting new AB households. These are two of the
83
objectives for the Black Country in the RSS, and are key principles underpinning
the whole of the Core Strategy.
6.13 One of the main attractions of the Black Country as a place to live is that
so much of its peripheral areas are still “green,” with high quality suburban and
semi-rural areas on the eastern side of Walsall and on the southern and western
fringes of Dudley. This is precisely the kind of environment where AB households
want to live. They are also the areas which contain the Black Country’s most
important unsterilised mineral resources, and which are likely to be the focus for
future mineral working.
6.14 Although it is temporary, the impact of mineral working can extend over
several years in the case of sand and gravel working and much longer in the
case of extraction of clay. Nevertheless, there is a lot that can be done to
address visual impacts through appropriate landscaping and screening of
working areas. For example, Walsall’s existing quarries are generally very well
screened from the surrounding areas by landscaping, and are not highly visible
from adjacent roads or residential areas. There is a Proposed Change to the
guidance on enclosure of mineral working operations in the Environmental and
Amenity Issues section of Policy MIN5, to reflect comments by Cemex at the
publication stage.
6.15 The main objections to mineral working and mineral working proposals in
the Black Country tend to be:
• Noise and disturbance from HGV movements on the highway
network;
• Impact of HGV movements on congestion in parts of the highway
network (particularly Shire Oak junction on the A451 in Walsall)
• Associated problems such as dust and debris deposited onto the
roads and into the drains;
84
• Potential visual impacts;
• Potential harm to the Green Belt and nature conservation areas;
• Cumulative impacts on areas already affected.
6.16 To address these concerns, it is vital that future mineral working is
controlled and steered towards the areas where it is likely to cause least
environmental damage while operations are underway, and that every effort is
made to minimise the visual and other impacts of working. It is equally important
to maximise the potential benefits of mineral working which can be achieved
through advance planting and final restoration to after-uses which will
complement the environmental infrastructure.
6.17 Policy MIN5 sets out general requirements for mineral applications, to
ensure that they include all the information needed to understand the positive
and negative aspects of the proposal and to make a balanced decision.
Proposals are also required to address key issues emerging from the technical
evidence on minerals, and from other mineral policy areas, in particular:
• Waste minimisation and mineral safeguarding
• Contribution towards mineral supply requirements and targets
• Ground stability and geotechnical risks
• Impacts on flood risk and water resources
• Impacts on the environment and local character
• Impacts on neighbouring uses
• Impacts on the highway network and scope for transporting
material by rail or canal.
Where relevant there are cross-references to other Core Strategy policies.
6.18 The final part of the policy provides a series of criteria against which
proposals may be assessed. These relate directly to the overall spatial strategy
and to local concerns, and are as follows:
85
• Consistency with minerals strategy (spatial objective 10)
• Contribution towards local economic/ regeneration objectives
• Contribution towards environmental transformation objectives
• Potential for co-location/ synergies
• Impact on neighbouring uses
• Impact on highway/ transport network
Appendix 4 sets out some key considerations that authorities might take into
account when assessing proposals against these criteria.
86
Bibliography
Note: The URLs below were correct at the time this report was
prepared, but may be subject to change.
Policy Documents on Minerals and Related Subjects
Title
URL
National Policy Guidance Meeting the Energy Challenge: A White Paper on Energy (May 2007), HM Government
http://www.decc.gov.uk/en/content/cms/publications/white_paper_07/white_paper_07.aspx
Waste Strategy for England 2007 (2007), Defra
http://www.defra.gov.uk/environment/waste/strategy/
Planning Policy Statement 12: Local Spatial Planning (PPS12), CLG
http://www.communities.gov.uk/publications/planningandbuilding/pps12lsp
Minerals Policy Statement 1 (MPS1): Planning and Minerals (November 2006), CLG
http://www.communities.gov.uk/publications/planningandbuilding/mineralspolicystatement5
Planning and Minerals: Practice Guide (November 2006), CLG
http://www.communities.gov.uk/publications/planningandbuilding/planningminerals
A Guide to Mineral Safeguarding in England (December 2007), BGS for CLG
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Minerals Policy Statement 2 (MPS2): Controlling and Mitigating the Environmental Effects of Minerals Extraction in England (March 2005), ODPM
http://www.communities.gov.uk/publications/planningandbuilding/mps2
Minerals Policy Statement 2 (MPS2): Controlling and Mitigating the Environmental Effects of Minerals Extraction in England: Annex 1: Dust (March 2005), ODPM
http://www.communities.gov.uk/publications/planningandbuilding/mps2annex1
Minerals Policy Statement 2 (MPS2): Controlling and Mitigating the Environmental Effects of Minerals Extraction in England: Annex 2: Noise (March 2005), ODPM
http://www.communities.gov.uk/publications/planningandbuilding/mps2annex2
87
National and Regional Guidelines for Aggregates Provision in England 2005 -2020 (July 2009), CLG
http://www.communities.gov.uk/publications/planningandbuilding/aggregatesprovision2020
Minerals Planning Guidance Note 3: Coal Mining and Colliery Spoil Disposal (April 1998), ODPM
http://www.communities.gov.uk/publications/planningandbuilding/mineralsplanningguidance2
Regional Spatial Strategy and Regional Spatial Strategy Revision Regional Planning Guidance for the West Midlands (RPG11) (January 2008), Government Office for the West Midlands
http://www.gos.gov.uk/gowm/Planning/515750/?a=42496
Regional Planning Guidance for the West Midlands (RPG11): Phase 2 Revision Preferred Option (December 2007), WMRA
http://www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/RSS_Revision/RSS_Revision_Phase_2/RSS_Revision_Phase_2.aspx
Regional Planning Guidance for the West Midlands (RPG11): Phase 2 Revision Preferred Option – Report of the Panel (2009)
http://www.planning-inspectorate.gov.uk/pins/rss/west_midlands_phase_two/index.htm
Regional Planning Guidance for the West Midlands (RPG11): Phase 3 Revision Options (July 2009), WMRA
http://www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/RSS_Revision/RSS_Revision_Phase_3.aspx
Black Country Local Development Frameworks and Other Local Policy Guidance
Dudley Unitary Development Plan 2005 (October 2005), Dudley MBC
http://www.dudley.gov.uk/environment--planning/planning/unitary-development-plan
Sandwell Unitary Development Plan 2004 (April 2004), Sandwell MBC
http://sandwelludp.wisshost.net/
Solihull Unitary Development Plan 2006 (February 2006), Solihull MBC
http://www.solihull.gov.uk/section.asp?docid=813&catid=1949
Walsall Unitary Development Plan 2005 (April 2005), Walsall Council
http://www.walsall.gov.uk/index/environment/planning/unitary_development_plan.htm
Wolverhampton Unitary Development Plan 2006 (June 2006), Wolverhampton City Council
http://www.wolverhampton.gov.uk/environment/planning/policy/udp/
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The Black Country Geodiversity Action Plan - Leaflet (2006), Black Country Geodiversity Partnership
http://www.laws.sandwell.gov.uk/ccm/content/urbanform/planninganddevelopment/ldf/supplementary-planning-documents/black-country-geodiversity-action-plan.en
Baseline Evidence for Minerals
Title
URL
General The Economic Importance of Minerals to the UK (2004), British Geological Survey/ ODPM
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
United Kingdom Minerals Yearbook 2008: Statistical Data to 2007 (2009), British Geological Survey (Previous yearbooks are also available to download from the UK Minerals website)
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Geological/ Mineral Resource Information A Geological Background for Planning and Development in the Black Country: Technical Report WA/92/33 (1992), British Geological Survey - covers all of Dudley and Sandwell but only parts of Walsall and Wolverhampton
NOT AVAILABLE ONLINE – AVAILABLE FROM BGS (THERE IS A CHARGE)
1:50,000 Solid and Drift Geology Map and Memoir covering Lichfield (E154) (1909/19), British Geological Survey *Covers the northern parts of Walsall
NOT AVAILABLE ONLINE – AVAILABLE FROM BGS (THERE IS A CHARGE)
1:50,000 Solid and Drift Geology Map and Memoir covering Wolverhampton and Telford District (E153) (2001/02), British Geological Survey *Covers the northern parts of Wolverhampton
NOT AVAILABLE ONLINE – AVAILABLE FROM BGS (THERE IS A CHARGE)
Mineral Resource Information for Development Plans – West Midlands: Resources and Constraints (Birmingham, Coventry, Dudley, Sandwell, Solihull, Walsall and Wolverhampton) (1999), British Geological Survey
NOT AVAILABLE ONLINE – AVAILABLE FROM BGS (THERE IS A CHARGE)
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Mineral Safeguarding A Guide to Mineral Safeguarding in England (December 2007), BGS for CLG
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Aggregates – General Planning 4 Minerals: A Guide on Aggregates (2006), Quarry Products Association, British Marine Aggregate Producers’ Association, British Geological Survey and Entec Ltd
http://www.bgs.ac.uk/planning4minerals/Downloads.htm
Mineral Planning Factsheet: Construction Aggregates (February 2007), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Aggregates Supply in England: Issues for Planning (2008), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Primary Aggregates Primary Aggregate Reserves in England 1990 – 2004 (2006), British Geological Survey
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Collation of the results of the 2005 Aggregate Minerals Survey for England and Wales (May 2007), BGS for CLG
http://www.communities.gov.uk/publications/planningandbuilding/aggregatesmineralssurvey2005
Aggregate Mineral Resource Maps: West Midlands Region (2008), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
West Midlands Sub-Regional Aggregates Apportionment Review National and Regional Guidelines for Aggregates Provision in England 2005 -2020 (July 2009), CLG
http://www.communities.gov.uk/publications/planningandbuilding/aggregatesprovision2020
West Midlands Regional Spatial Strategy Phase 3 Revision: Minerals Background Paper (June 2009), WMRA
http://www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/RSS_Revision/RSS_Revision_Phase_3.aspx
WMRSS Update: Phase 3 Special (November 2009), WMRA
http://www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/Latest_News/Latest_News_.aspx
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West Midlands Regional Assembly – Report to Regional Planning and Environment Executive, 23 February 2010: Interim Policy Statement – Sub-Regional Apportionment of Aggregates
http://www.wmra.gov.uk/Planning_and_Regional_Spatial_Strategy/Meetings_and_Agendas/Planning_and_Environment_Executive/23_February_2010.aspx
Secondary/ Recycled Aggregates Survey of Arisings and Use of Construction, and Demolition Waste in England and Wales in 2001 (October 2002), Capita Symonds Ltd/ WRc Ltd for ODPM
http://www.communities.gov.uk/archived/publications/planningandbuilding/surveyarisings
Survey of Arisings and Use of Secondary Materials as Aggregates in England and Wales in 2001 (November 2002), Capita Symonds Ltd/ WRc Ltd for ODPM
http://www.communities.gov.uk/archived/publications/planningandbuilding/surveyarisings3
Survey of Arisings and Use of Construction, Demolition and Excavation Waste as Aggregate in England in 2003 (October 2004), Capita Symonds Ltd/ WRc Ltd for ODPM
http://www.communities.gov.uk/publications/planningandbuilding/surveyarisings
The Sustainable Use of Resources for the Production of Aggregates in England (2006), WRAP
http://www.aggregain.org.uk/templates/temp_agg_publication_details.rm?id=2298&publication=3337
Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005: Construction, Demolition and Excavation Waste (February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG
http://www.communities.gov.uk/publications/planningandbuilding/surveyconstruction2005
Survey of Arisings and Use of Alternatives to Primary Aggregates in England 2005: Other Materials (February 2007), Capita Symonds Ltd/ WRc Ltd for DCLG
http://www.communities.gov.uk/publications/planningandbuilding/surveyother2005
Primary Aggregates Sub-Regional Apportionment in South-East England: Final Report (November 2007), Land Use Consultants for SEERA
http://www.southeast-ra.gov.uk/sustainability_minerals.html
West Midlands Regional Aggregates Working Party (RAWP) Annual Reports 2004 – 2007 (N.B. 2008 report will be available shortly on the same website)
http://www.communities.gov.uk/planningandbuilding/planning/planningpolicyimplementation/managedaggregatessupply/regionalaggregateworking/westmidlandsrawp/
Bricks and Brick Clay Brick Clay: Issues for Planning – Executive Summary (2001), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
The Role of Brick in the Environment (November 2001), Michael Hammett for Brick Development Association
http://www.brick.org.uk/publications/sustainability.html
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Brick – The Case for Sustainability (undated), Brick Development Association
http://www.brick.org.uk/publications/sustainability.html
Mineral Planning Factsheet: Fireclay (October 2006), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Mineral Planning Factsheet: Brick Clay (February 2007), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Wienerberger Finance Service BV / Baggeridge Brick plc: Final Report, Appendix C – Brick Industry Profile (10.05.07), Competition Commission
http://www.competition-commission.org.uk/rep_pub/reports/2007/526wienerberger.htm
New Tricks with Old Bricks: How re-using old buildings can cut carbon emissions (2008), Empty Homes Agency & Building and Social Housing Federation
http://www.bshf.org/published-information/publication.cfm?thePubID=3DE7278E-15C5-F4C0-99E86A547EB36D44
A Sustainability Strategy for the Brick Industry: An Update (2009), Brick Development Association
http://www.brick.org.uk/publications/sustainability.html
Coal and Coal Based Energy Technologies Resource for New Exploitation Technologies: Mining and New Technologies (November 2004), BGS, Wardell Armstrong and Imperial College for BERR (Summary Map is not available online and we have not been able to obtain a copy)
http://www.berr.gov.uk/files/file19153.pdf
Summary of Information on Coal for Land Use Planning Purposes (2006), BGS for CLG
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Mineral Planning Factsheet: Coal and Coalbed Methane (October 2006), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Mineral Profile: Coal (February 2007), BGS http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Surface Mining and Coal Resource Areas: 1:250,000 map of West Midlands Region and 1:50,000 maps of Dudley, Sandwell, Walsall and Wolverhampton (July 2008), Coal Authority
NOT AVAILABLE ONLINE – AVAILABLE FROM THE COAL AUTHORITY (MAY BE A CHARGE)
92
Natural Building Stone Mineral Planning Factsheet: Building and Roofing Stone (March 2007), BGS
http://www.bgs.ac.uk/mineralsuk/search/downloadSearch.cfc?method=viewDownloadsByCategory
Mineral Working and the Historic Environment (January 2008), English Heritage
http://www.helm.org.uk/server/show/nav.00h01c001/chooseLetter/M
Buildings of Walsall (2000), P. A. Arnold, Tempus Publishing
NOT AVAILABLE ONLINE
Black Country Core Strategy Technical Reports Survey of Current Mineral Reserves in the Black Country: Published Report (March 2007), Scott Wilson
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa
Black Country Core Strategy: Black Country Minerals Study 2008 Final Report & Appendices A – C (March 2008), RPS Planning and Development
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa
The Black Country Strategic Flood Risk Assessment (SFRA) (February 2009), Jacobs
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa
Black Country Core Strategy: Waste Planning Study Final Report (May 2009), Atkins Ltd
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa
Black Country Core Strategy: Sample Sites Viability Study (October 2009), Mott Macdonald
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa
Black Country Core Strategy: Stage Two Infrastructure & Deliverability Study: Technical Note 6: Ground Risk and Mineral Extraction (November 2009), Mott Macdonald
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa
Sustainability Appraisal of the Black Country Joint Core Strategy: Sustainability Appraisal Report to accompany the Publication Version of the Joint Core Strategy: Volumes 1 – 3 (November 2009), UE Associates
http://blackcountrycorestrategy.dudley.gov.uk/evidencesa/sa
Dudley LDF Annual Monitoring Reports 2005 – 2009
http://www.dudley.gov.uk/index.asp?pgid=15841
Sandwell LDF Annual Monitoring Reports 2005 – 2009
http://www.laws.sandwell.gov.uk/ccm/content/urbanform/planninganddevelopment/unitary-development-plan/unitary-development-plan-review---annual-monitoring-report-2005-6.en
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Walsall LDF Annual Monitoring Reports 2005 – 2009 (N.B. only the latest two reports are available online, earlier reports are available from Walsall MBC)
http://www.walsall.gov.uk/index/environment/planning/local_development_framework/ldf_annual_monitoring_report.htm
Wolverhampton LDF Annual Monitoring Reports 2005 - 2009
http://www.wolverhampton.gov.uk/environment/planning/policy/ldf/AMR.htm
Black Country Core Strategy Launch Event, 6 December 2006 (January 2007), Black Country Authorities
http://blackcountrycorestrategy.dudley.gov.uk/how-can-i-get-involved/launch-event
Black Country Core Strategy Minerals & Waste Event, 29 March 2007 (April 2007), Black Country Authorities
http://blackcountrycorestrategy.dudley.gov.uk/how-can-i-get-involved/other-events/minerals-waste
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Glossary Abbreviation Term Meaning
- Aggregates/ Aggregate
Minerals Hard, granular minerals used for building and engineering purposes either on their own or with a “binder” (e.g. lime or cement) to create other building products such as asphalt or mortar. The two main types of aggregates are sands and gravels and crushed rock. Aggregates can be produced from primary, secondary or recycled sources.
- Alternatives General term used to describe alternatives to primary aggregates, such as secondary and recycled aggregates.
AMR Annual Monitoring Report
A report which each WPA is required to produce every year by 31 December, with details of progress on implementing LDF/ MWDF waste policies. There are two Core Output Indicators on waste that all WPAs must monitor, one relating to MSW management and one relating to new waste management capacity coming forward.
AWM Advantage West Midlands
The regional development agency for the West Midlands, responsible for the regional economic strategy. From April 2010, they will become part of the regional planning body (the other element will be the Local Authority Leaders’ Board).
- Blue Bricks See Engineering Bricks. BAA British Aggregates
Association Trade association for independent aggregate quarry operators. Has fewer members than the Mineral Products Association and there are currently no BAA members within the Black Country.
BCC British Ceramics Confederation
The trade association for the UK ceramics industry. Members include manufacturers of bricks, tiles, clay pipes, china, industrial ceramics and sanitary ware. Most of the brick manufacturers active in the Black Country are members.
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BDA Brick Development Association
The main trade association for UK and Irish brick manufacturers.
BGS British Geological Survey
The BGS is the UK’s main centre for research into geology and earth science. They provide technical information and support on geology, mineral resources and related issues to the Government, to MPAs, the private sector and the general public. The BGS is the main source of mineral resource information for land use planning, and has also produced a range of mineral commodity fact sheets, profiles and other technical information.
- Brick Clay Sometimes referred to as Clay and Shale. Clays are sedimentary mudstones of different ages and compositions, which form a fine-grained impermeable earth which can be moulded when wet and fired to produce structural clay products such as bricks, tiles, pavers and pipes. Not all clays are suitable for making these products. The main clays occurring in the Black Country which are used to make bricks are from the Etruria Formation.
- Buff Clays Brick clays with a yellow or cream colour, such as fireclay. Other types of clay with a similar colour do not occur in the Black Country.
- Clay and Shale See Brick Clay. - Coal Sedimentary rock made of fossilised
plant remains. Coal occurs in layers, or seams, of various thicknesses. The coal resources in the Black Country form part of the South Staffordshire Coalfield and were extensively exploited in the past.
CBM Coal Bed Methane Methane gas present within coal seams which was trapped within the coal when it was formed, or into pore spaces around the coal seam. Where significant amounts of CBM exist, these can be extracted by drilling, and the recovered gas can be used as an energy source.
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- Coal Measures Deposits of sedimentary rock containing seams of coal, fireclay and other minerals.
- Coal Authority
The Coal Authority is the statutory body responsible for licensing coal mining operations and addressing the legacy of previous mining activities. They are a statutory consultee on planning applications affecting coal resources and on Development Plan Documents in areas containing coal resources.
CD&EW Construction, Demolition & Excavation Waste
Waste arising from the development and redevelopment process, i.e. as a result of building, engineering, demolition and land remediation.
Common Bricks Bricks of a lower quality than facing or engineering bricks, usually used in the parts of a building where they are not visible.
- Crushed Rock Aggregate minerals formed by the crushing and grading of hard rocks. They are used as a constructional fill material as well as to make products such as concrete, gravel surface dressings, roadstone and rail ballast.
DPD Development Plan Document
A land use plan prepared by a strategic or local planning authority, which forms part of the authority’s LDF or MDF/ MWDF. Once adopted, a DPD becomes part of the statutory development plan for the area it covers, and decisions on planning applications should be in accordance with it. The Black Country Core Strategy is a DPD.
- Dolerite A type of basalt - an igneous rock formed by cooling of hot molten magma from ancient volcanic activity. Dolerite occurs as outcrops in various parts of the Black Country and the local material is often referred to as Rowley Rag.
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End Use A new use for a former quarry site which has been restored. Mineral working permissions will often include conditions specifying the end uses that are suitable, and will require restoration to a standard which will support the uses specified. Most Black Country quarries are in the Green Belt, which limits the kinds of end uses which can be implemented.
- Engineering Bricks Also known as Blue Bricks or Staffordshire Blue Bricks. Facing bricks made to a heavy-duty/ high performance specification. They are made from iron-rich red clays such as those from the Etruria Formation in the Black Country. The distinctive dark grey-blue colour is a result of reducing the iron in the clay, by firing the bricks at very high temperatures.
EA Environment Agency The Environment Agency is the statutory body responsible for licensing and permitting landfill sites and many other waste management facilities which are subject to regulation, and for regulating water quality and flood risk. They are a statutory consultee on Local Development Documents and planning applications in areas at risk of flooding, or which may affect water quality.
EH English Heritage English Heritage is the Government’s adviser on the historic environment. They are a statutory consultee on Local Development Documents and planning applications affecting historic sites of national and international importance, such as Scheduled Ancient Monuments and Grade I and II* listed buildings. They are currently collaborating with the BGS on a Strategic Stone Study covering each county area in England.
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- Enville Formation A formation of mudstone which occurs in parts of Staffordshire and the Black Country. The clays within this formation are not generally regarded as being suitable for brick manufacture.
- Etruria Formation A formation of mudstone which occurs in parts of Staffordshire and the Black Country. This formation contains brick clays, notably Etruria Marl, which is a highly prized but nationally scarce type of clay.
- Etruria Marl A nationally scarce type of red clay found in Staffordshire and in parts of Dudley and Walsall, and used to make high-quality facing bricks.
- Facing Bricks Bricks designed to be used as external facing on buildings, often having decorative finishes such as variegated colours and textures.
- Fireclay Sedimentary mudstones (also called “seatearths” occurring beneath almost all coal seams. They are fossil soils, on which the coal-forming vegetation once grew. Fireclay has the ability to resist heat, and was exploited in the past for making “refractories” to line kilns and furnaces. Today fireclay is mainly used in the manufacture of high-quality facing bricks.
- Gornal Stone A type of limestone occurring in the Gornal and Sedgley areas of Dudley, which was exploited as a building stone. There are examples of historic buildings and structures built of Gornal Stone in Gornal, Sedgley and Dudley Town Centre.
GO-WM Government Office for the West Midlands
The Government office responsible for implementing national policy in the West Midlands region. The GO-WM advises Government on planning policy issues affecting the area, and advises MPAs on local interpretation of national policy guidance.
- Halesowen Sandstone Red sandstone used in the past as a building stone. This stone was quarried from and used in the Halesowen area of Dudley.
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- Keele Formation A formation of mudstone which occurs in parts of Staffordshire and the Black Country. The clays within this formation are not generally regarded as being suitable for brick manufacture.
Landfill The usual method of restoring former quarries, involving depositing of inert waste materials or pre-treated waste residues. Most landfill sites are former quarries where the waste is used to fill the void and help restore the site to a beneficial end-use. Restoration by landfilling with waste is often a condition of the original mineral permission.
- Limestone A soft calcium-based stone formed from the fossilised remains of marine organisms. Limestone occurs extensively across the Black Country, and was exploited in the past both for hydraulic lime (used to make cement and mortar) and as a building stone. The remains of former limestone workings can still be seen at the Wren’s Nest to the east of Dudley Town Centre, which is a National Nature Reserve.
LDD Local Development Document
Any plan that forms part of a local or strategic authority’s LDF or MDF/ MWDF. There are three types of LDD: Statements of Community Involvement (SCI), Development Plan Documents (DPD) and Supplementary Planning Documents (SPD).
LDF Local Development Framework
The framework for spatial planning within local authority or unitary authority areas. The “folder” containing all the authority’s spatial plans for minerals and other key issues, including the Core Strategy, Site Allocations Document and other Local Development Documents.
- Mercia Mudstone A type of mudstone containing red clays used for brick-making. This type of clay does not occur in the Black Country.
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MDF Mineral Development Framework
The equivalent of a LDF in county council areas, covering plans for minerals. This is the “folder” containing all the authority’s spatial plans for minerals, including the Core Strategy and other Local Development Documents. Some Counties have a combined MWDF covering minerals and waste.
- Mothballed/ Mothballing
Temporary closure of a brick or tile manufacturing plant. Two works supplied with Etruria Marl from Black Country sources (Sedgley Works and Stourbridge Works) are currently in this position.
MPA/ MPAs Mineral Planning Authority/ Authorities
Strategic authorities (county councils and unitary authorities) with a statutory duty/ responsibility for the spatial planning of minerals within their area through LDFs and MDFs/ MWDFs.
MPA Mineral Products Association
Formerly the Quarry Products Association (QPA). The main trade association for the aggregates, asphalt, cement, concrete, lime, mortar, and silica sand industries. The main companies involved in quarrying for aggregates or aggregates processing, including Cemex, JPE Aggregates, Midland Quarry Products and Tarmac, are members.
- Mineral Related Infrastructure
Facilities involved in the processing, handling, storage or transportation of minerals and mineral products. Examples include recycling facilities, coating plants, cement works and rail freight facilities.
- Mineral Resources See Resources. - Mineral Safeguarding The protection or safeguarding of
important mineral resources and mineral-related infrastructure from sterilisation or encroachment by incompatible non-mineral built developments or uses.
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MSA Mineral Safeguarding Area
An area defined around mineral resources which are or may become of economic importance. Mineral planning authorities with important mineral resources are required to safeguard these resources against needless sterilisation by non-mineral uses, by defining MSAs in their LDF or MDF/ MWDF.
MWDF Minerals and Waste Development Framework
See MDF.
- Natural Building Stone Stone used as a traditional building material. The most important natural stone resources used for building in the Black Country are: Rowley Rag (dolerite), Gornal Stone (limestone) and Halesowen Sandstone.
NE Natural England Natural England is the public body responsible for protecting and improving the natural environment. They are a statutory consultee on Local Development Documents and planning applications affecting sites of national and international importance for biodiversity and geodiversity, such as SACs and SSSIs.
- Paving Bricks/ Pavers Bricks used for flooring rather than for building walls.
- Permitted Reserves The term used to describe the quantity of mineral present within an area covered by a mineral planning permission, i.e. mineral resources which have permission to be worked. Usually expressed in tonnes or cubic metres.
- Primary Aggregates Virgin aggregate materials, naturally occurring mineral deposits quarried from the ground (land-won) or dredged from the sea bed (marine).
- Prior Extraction The term used to describe the extraction of mineral resources in advance of a new non-mineral development. Prior extraction of minerals is encouraged in national policy guidance and in the Black Country UDPs, as a means of safeguarding mineral resources against needless sterilisation.
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- Proposals Map A map showing all site specific proposals and designations in the LDF/ MDF/ MWDF.
QPA Quarry Products Association
See Mineral Products Association (MPA).
RAWP Regional Aggregates Working Party
Technical advisory body on aggregates. There is a RAWP for each English region, made up of representatives from Mineral Planning Authorities (MPAs), the aggregates industry and other statutory consultees. The RAWPs undertake annual surveys of aggregates supplies and reserves, and provide technical advice on aggregates issues to the Government and to the regional planning body (RPB).
- Recycled Aggregates Aggregates obtained from recycling waste. Most recycled aggregates are produced from construction, demolition and excavation wastes (CD&EW), but recycled materials also include road planings obtained from resurfacing and rail ballast.
- Red Clays Brick clays with a red or orange colour (due to high iron content), such as clays from the Etruria Formation which occur in the Black Country. Some red clays (e.g. from Mercia Mudstone) do not occur in the Black Country.
- Reserves See Permitted Reserves. - Resources The term used to describe the
quantity of mineral present within a given area, usually expressed in tonnes or cubic metres.
- Restoration What happens to a quarry when mineral extraction ceases. Mineral permissions normally include conditions requiring a restoration programme to be agreed with the MPA and for this to be implemented once quarrying has finished. Restoration is often achieved through filling with waste and then capping with suitable materials. Where the underlying geology will support this, restoration can also involve creation of water features.
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- Rowley Rag A hard black dolerite stone occurring as outcrops in various parts of the Black Country, but mainly in Rowley Regis in Sandwell. In the past it was widely used to make stone setts and kerbstones, and more rarely, as a building material. The material quarried more recently has been used as aggregate.
- Sands and Gravels Aggregate minerals which can be either land-won or marine-dredged. Land-won sands and gravels can be quarried from either sandstone bedrock (as in the Black Country) or from alluvial deposits. They are used as a constructional fill and bedding material as well as to make products such as concrete, asphalt and bricks.
- Saved Plan/ Policy An old-style development plan or development plan policy pre-dating the 2004 planning system, which has been “saved” for a temporary period until it is replaced by policies in a new DPD. Most of the UDPs for Dudley, Sandwell, Walsall and Wolverhampton have been “saved.” Some “saved” policies will be superseded by the Black Country Core Strategy once this is adopted.
- Secondary Aggregates Aggregates obtained as a by-product of other quarrying and mining operations, such as clay waste, and aggregates obtained as a by-product of other industrial processes such as blast furnace slag, incinerator ash and spent foundry sand.
- Stakeholder A term used to describe interested parties who are involved in the spatial planning process.
- Sterilisation This is what has happened to the mineral resources underlying urban areas. Buildings and other structures on the surface of the ground prevent mineral working from taking place, so the mineral resources underlying them are said to be “sterilised.”
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SPD Supplementary Planning Document
A land use plan forming part of a strategic or local planning authority’s LDF or MDF/ MWDF, which supplements the guidance in an existing “saved” development plan or a DPD.
SWMP Site Waste Management Plan
A plan for a large remediation, demolition or building project, setting out how and where CD&EW is managed – from March 2008 it has been a statutory requirement for clients of all projects with a total cost of £300,000 or more to compile and maintain a SWMP.
- Staffordshire Blue Bricks
See Engineering Bricks.
TPA Tonnes Per Annum This is the normal way of measuring mineral production, or the operational throughput/ capacity of waste management infrastructure.
UDP Unitary Development Plan
An old-style single development plan which pre-dates the 2004 reformed planning system. Most of the UDPs for Dudley, Sandwell, Walsall and Wolverhampton have been “saved.” The policies still in force form part of the authorities’ LDFs.
UCG Underground Coal Gasification
An emerging technology involving controlled combustion of coal seams by the injection of various gases. The gases can then be recovered by drilling and used to generate electricity or be converted into a liquid fuel.
WMRA West Midlands Regional Assembly
Currently the regional planning body for the West Midlands, responsible for regional planning guidance. In April 2010, regional assemblies will be abolished and the regional planning body will be AWM and the Local Authority Leaders’ Board.
WMRAWP West Midlands Regional Aggregates Working Party
The RAWP covering the West Midlands region.
Black Country Core Strategy
Submission Document
Minerals Background Paper Version 2 (Revised)
Appendices
February 2010
1
BLACK COUNTRY CORE STRATEGY
PUBLICATION DOCUMENT
Minerals Background Paper - Version 2 (Revised):
Appendices
February 2010
Appendices
Pages
Appendix 1: Aggregates Data Tables 1 - 7
Appendix 2: Brick Clay Data Tables 8 – 13
Appendix 3: Potential Sites for Surface Coal and Clay
Working
14 – 15
Appendix 4: Assessment Criteria for Mineral Applications 16 – 18
1
Appendix 1:
Aggregates Data Tables
2
Appendix 1: Aggregates Data Tables
Table A1a: Estimated Production of CD&EW and Secondary and Recycled Aggregates in the Black Country 2001 – 2005 (tonnes)
Year/ Area
Weighted "share" of
regional total
Weighted "share" of
sub-regional total
Recycled Aggregate
Recycled Soil
Landfill Engineering/ Restoration
Backfilling Quarry Voids
Spread on Registered
Exempt Sites Landfill (Waste)
Total Arisings
Weighted "share" of
regional total 2001
WM Region 100.00 0 3,710,000 570,000 1,040,000 1,100,000 1,810,000 400,000 8,630,000 100.00 Dudley 4.05 0.00 150,000 23,000 42,000 45,000 73,000 16,000 349,000 4.05
Sandwell 7.37 0.00 273,000 42,000 77,000 81,000 133,000 29,000 635,000 7.37 Walsall 2.95 0.00 109,000 17,000 30,700 32,000 53,000 12,000 253,700 2.95
Wolverhampton 3.45 0.00 128,000 20,000 36,000 38,000 62,000 14,000 298,000 3.45 Black Country Total 17.82 0.00 661,000 102,000 185,000 196,000 323,000 71,000 1,538,000 17.82
2003 WM Region 100.00 0.00 4,290,000 647,000 542,000 1,142,000 779,000 731,000 8,131,000 100.00
Dudley 4.05 0.00 174,000 26,000 22,000 46,000 32,000 30,000 330,000 4.05 Sandwell 7.37 0.00 316,000 48,000 40,000 84,000 57,000 54,000 599,000 7.37 Walsall 2.95 0.00 127,000 19,000 16,000 34,000 23,000 22,000 241,000 2.95
Wolverhampton 3.45 0.00 148,000 22,000 19,000 39,000 27,000 25,000 280,000 3.45 Black Country Total 17.82 0.00 764,000 115,000 97,000 204,000 139,000 130,000 1,449,000 17.82
2005 WM Region 100.00 0.00 4,447,000 470,000 468,000 359,000 2,911,000 1,185,000 9,840,000 100.00
Birmingham & Black Country 17.82 0.00 1,508,000 182,000 24,000 35,000 692,000 438,000 2,879,000 17.82 Dudley 0.00 11.41 172,000 21,000 3,000 4,000 79,000 50,000 329,000 0.00
Sandwell 0.00 20.76 313,000 38,000 5,000 7,000 144,000 91,000 598,000 0.00 Walsall 0.00 8.31 125,000 15,000 2,000 3,000 58,000 41,000 244,000 0.00
Wolverhampton 0.00 9.72 147,000 18,000 2,000 3,000 67,000 43,000 280,000 0.00 Black Country Total 0.00 50.20 757,000 92,000 12,000 17,000 348,000 225,000 1,451,000 0.00
Note: All figures rounded to the nearest 1,000 tonnes - due to rounding, figures presented in Table 3.7 of Black Country Core Strategy Waste Planning Study may differ.
Sources: 2001: Survey of Arisings and Use of Construction and Demolition Waste in England and Wales 2001 (2002), Symonds / WRc for ODPM, Table 1 2003: Survey of Arisings and Use of Construction, Demolition and Excavation Waste as Aggregate in England in 2003 (2004), Capita Symonds / WRc for ODPM, Table A8.1 2005: Survey of Arisings and Use of Alternatives to Primary Aggregates in England, 2005: Construction, Demolition and Excavation Waste (2007), Capita Symonds / WRc for CLG, Tables A10.4 and A11.12 2005: also Black Country Core Strategy: Waste Planning Study Final Report (2009), Atkins for Black Country Authorities, Table 3.7
3
Table A1b: Production of Primary Aggregates in the West Midlands County Area: Aggregates Sales 1998 – 2007 by Type (tonnes)
Year Crushed Rock Apportionment Crushed Rock Sales
Sand & Gravel Apportionment Sand & Gravel Sales Total Sales
1998 560,000 630,000 540,000 445,000 1,075,000
1999 560,000 730,000 540,000 474,000 1,204,000
2000 560,000 450,000 540,000 481,000 931,000
2001 560,000 530,000 540,000 536,000 1,066,000
2002 560,000 630,000 506,000 512,000 1,142,000
2003 560,000 800,000 506,000 499,000 1,299,000
2004 575,000 630,000 506,000 520,000 1,150,000
2005 575,000 310,000 506,000 580,000 890,000
2006 0 506,000 550,000 550,000
2007 0 506,000 610,000 610,000
Source: WMRAWP Annual Reports 1998 - 2007, data relates to calendar years, all figures rounded to the nearest 1,000 tonnes Note: Apportionments changed in 2002 and crushed rock apportionment for the West Midlands County ceased to apply after 2005
4
Table A1c: Primary Aggregates Landbanks in the West Midlands County Area 1998 – 2007 by Type (tonnes)
Year
Permitted Reserves Required for 7-year Landbank (tonnes)
Landbank - Permitted Reserves @ 31 December
(tonnes) Landbank Requirement
(years) Landbank - Supply @ 31
December (years)
1998 3,780,000 4,372,000 7.00 8.10
1999 3,780,000 3,904,000 7.00 7.23
2000 3,780,000 3,838,000 7.00 7.12
2001 3,780,000 3,561,000 7.00 6.59
2002 3,542,000 3,578,000 7.00 7.07
2003 3,542,000 3,020,000 7.00 5.97
2004 3,542,000 2,500,000 7.00 4.94
2005 3,542,000 2,000,000 7.00 4.00
2006 3,542,000 1,600,000 7.00 3.16
2007 3,542,000 2,390,000 7.00 4.72 Source: WMRAWP Annual Reports 1998 - 2007, data relates to calendar years, all figures rounded to the nearest 1,000 tonnes Note: Apportionments changed in 2002 and crushed rock apportionment for the West Midlands County ceased to apply after 2005
5
Table A1d: Existing and Potential Future Supplies of Sand and Gravel in Walsall @ December 2008
Source of Supply
Estimated Quantity of Sand
and Gravel (million tonnes)
Source of Evidence
Permitted Reserves @ 31.12.08
0.24 2008 WMRAWP Annual survey – interim results1
Additional Permitted Reserves coming forward since December 2008 – New Planning Permissions
0.00 2008 Walsall AMR
Potential Reserves in the Pipeline – Planning Applications
1.20 Current Planning Application – Branton Hill Lane
Potential Resources identified in representations on emerging LDFs
2.60
Representation from Cemex - Black Country Core Strategy
Other Potential Resources identified through emerging LDFs
Resources identified outside
UDP MSAs, but not quantified
Black Country Minerals Study 2008 (RPS)
TOTAL SUPPLY (MILLION TONNES)
4.04
1 2008 Annual Report not yet published – this figure reflects survey returns provided by operators in Walsall.
6
Table A1e: Additional Sand and Gravel Resources identified through Core Strategy – Key Issues and Constraints
Potential Sand and Gravel Resource Area
Area of Search
Estimated Additional Resource (tonnes)
MPA Key Issues and Constraints
Land near Aldridge Quarry, Birch Lane, Stonnall
MA1: Birch Lane
2,600,000
Walsall Within MSA M1.ii in Walsall UDP. The main constraints to working are:
• Green Belt location
• Potential landscape/ potential visual impacts – screening/ advance planting required to mitigate impact on Lazy Hill residential area to the south-west and properties on the opposite side of Birch Lane
• Potential impact on water resources – the area lies within a groundwater source protection zone around a covered reservoir at Shire Oak (total catchment)
• Potential transport/ highway impacts on A452 Chester Road and Shire Oak Junction
• Working depends on agreement with landowner
This area was put forward in a representation by Cemex as a potential sand and gravel extraction site. They have confirmed that the area contains viable sand and gravel resources. The area is already within a MSA defined in the Walsall UDP, and environmental, transport and amenity constraints could be overcome with appropriate mitigation.
Branton Hill Quarry Extension, Branton Hill Lane, Aldridge
MA2: Branton Hill Lane
1,200,000 Walsall Within MSA M1.ii in Walsall UDP. The main constraints to working are:
• Green Belt location
• Potential transport/ amenity impacts – existing quarry access arrangements are unsatisfactory as haulage routes pass through residential areas
7
• Potential impact on water resources – the area is within a groundwater source protection zone (outer zone) around a borehole at Bourne Vale (pumping station adjacent)
This is the subject of an outstanding planning application which until recently was stalled, pending unresolved issues about impacts on hydrology and accessibility/ impact of haulage on nearby residential areas. However, the outstanding application is now being progressed, following a grant of permission earlier in 2009 for a new access road for the quarry, which would remove one of the main constraints to working this area.
8
9
Appendix 2:
Brick Clay Data Tables
10
Appendix 2: Brick Clay Data Tables
Table A2a: Existing and Potential Supplies of Etruria Marl to Black Country Brickworks 2009 – 2026
Works MPA for Works Operator
Main Source of
Supply
MPA for Main
Source of
Supply
Estimated Supply @ April 2009
(years)
Core Strategy Area of Search
Estimated Supply
+Further Resources Identified
in Areas of Search (years)
Maximum Imports
Permitted (%)
Potential Supply from
Imports - Subject to Availability
(TPA)
Total Req. for Core
Strategy 17 Year
Supply 2010 - 2026
(tonnes)
Theoretical Shortfall
for 17 Year Supply
2010 - 2026 with
Maximum Imports (tonnes) Comments
Aldridge Walsall Ibstock
Highfields South (imports) Walsall
Less than 5 years
MA5: Stubbers Green
Less than 5 years 100%
Confidential/ not
confirmed
Confidential/ not
confirmed 0
Works is not adjacent to a clay pit and relies on imports. Operator has not yet agreed to public disclosure of consumption and supply data
Atlas Walsall Ibstock Atlas Walsall 22.0
MA5: Stubbers Green Confidential 30% Confidential Confidential 0
Operator has identified potential additional reserves within Area of Search. However, has not yet agreed to public disclosure of consumption and supply data
Cradley Sandwell Cradley Special Brick
Relies on imports from outside the Black Country N/A Not known N/A Not known 100% 7,000 119,000 0
Specialist operator producing small quantities of bespoke bricks. Supplies provided by parent company (Hanson) - operator has confirmed this arrangement is satisfactory
Dreadnought Dudley Hinton Perry & Davenhill Ketley Dudley 15.0-20.0
MA4: Ketley 15.0-20.0 100% 32,000 554,000 0
No new sources of supply identified
11
Sandown Walsall Wienerberger
Sandown and Highfields South Walsall
Less than 5 years
MA5: Stubbers Green 10.0 65% 110,500
2,890,000 Not known
Operator has identified additional resources identified within Area of Search; planning application expected 2010
Sedgley Staffs CC Wienerberger Oak Farm Dudley 24.0
MA3: Himley/ Oak Farm 24.0 100% 50,000 850,000 0
Factory is currently mothballed - operator has confirmed supply is adequate
Stourbridge Dudley Ibstock Himley (imports) Dudley
Less than 5 years
MA3: Himley/ Oak Farm
Less than 5 years 100% Not known Not known Not known
Factory is currently mothballed. Works is not adjacent to a clay pit and relies on imports. Operator has identified potential additional reserves within Area of Search. Otherwise no information available.
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Table A2b: Additional Etruria Marl Resources Identified through Core Strategy – Key Issues and Constraints
Potential Clay Resource Area
Area of Search
Estimated Additional Resource (tonnes)
Works to be Supplied
MPA Key Issues and Constraints
Former Himley Brickworks Site, Himley
MA3: Himley/ Oak Farm
500,000 Stourbridge Dudley Outside MSA in Dudley UDP, and within Regeneration Corridor 10 (employment led corridor). The main constraint to working is:
• Proximal non-mineral uses
• Potential impact on proposed housing development to the east of the site
However, employment land (occupied by a haulage firm) provides a “buffer” between the site and the proposed housing development area.
The Causeway, Sandown Quarry, Stubbers Green
MA5: Stubbers Green
1,000,000
(Including resources already
permitted but not
accessible)
Sandown Walsall Within MSA M1.iii in Walsall UDP. The main constraints to working are:
• Green Belt location
• Potential stability problems which may affect feasibility of working/ future restoration
• Potential impacts on adjacent Swan Pool and The Swag Site of Special Scientific Interest (SSSI).
Former mineral railway line left as an un-worked area when Sandown and Barnett & Beddows Quarries were merged into a single working area several years ago. It is not covered by the existing working permissions. A previous
13
application to work the site was refused on appeal due to concerns about ground stability, but recent investigations suggest this constraint can be overcome. The site contains resources of similar quality to the worked area. Working the Causeway would also give access to reserves currently permitted but inaccessible. Pre-application discussions have commenced with Walsall Council, and an application is expected in 2010.
Recordon Land, Stubbers Green
MA5: Stubbers Green
900,000 Atlas Walsall Within MSA M1.iii in Walsall UDP. The main constraints to working are:
• Green Belt location
• Site is designated as a Site of Importance for Nature Conservation (Stubbers Green SINC) in Walsall UDP
• Flood risk – the site is prone to flooding and the Black Country Strategic Flood Risk Assessment indicates that part of it is within Flood Zone 3a.
The site adjoins Atlas Quarry and contains resources of similar quality. Working this area would improve the operational efficiency of the existing quarry by allowing working to continue in the same direction. There is potential for these resources to supply other works in the Stubbers Green area (Aldridge and Sandown). However this would be subject to agreement to pool these resources between factories, and subject to Walsall Council agreeing to vary a planning condition applied to Atlas Works which currently prevents clay from being exported.
14
Table A2c: Residual Etruria Marl Supply Requirements for Dudley and Walsall LDFs
MPA Total
Estimated
Core Strategy
Supply
Requirement
2010 - 2026
Total
Estimated
Supply
Requirement
2010 – 2035
(25-Year
Supply)
Total
Estimated
Supply @
April 2009
(tonnes)
Estimated
Supply within
Areas of
Search
(tonnes)
Total Supply
Identified in
Core Strategy
(tonnes)
Additional
Resources
Required for
Core Strategy
Supply 2010
– 2026
(tonnes)
Additional
Resources
Required for
25-Year
Supply 2010
– 2035
(tonnes)
Dudley 1,400,000 2,100,000 1,600,000 2,100,000 3,700,000 0 0
Walsall 5,300,000 7,800,000 3,200,000 2,000,000 5,200,000 1,500,000 2,300,000
Note: The above data relates only to factories for which we have information (data for Stourbridge Works in Dudley and Aldridge Works in Walsall is missing).
15
Appendix 3:
Potential Sites for
Surface Coal and Clay Working
16
Table A3a: Potential Sites for Surface Coal and Clay Working – Key Issues and Constraints
Potential Site for Surface Coal and Clay Working
Estimated Resource:
Coal (tonnes)
Estimated Resource:
Clay (tonnes)
MPA Key Issues and Constraints
Brownhills Common 30,000 200,000 Walsall Just outside Regeneration Corridor 15 (employment led corridor). The main constraints to working are:
• Green Belt location
• Proximal non-mineral uses (Coppice Side Industrial Estate)
• Potential impact on Brownhills Common and The Slough SINC/ proposed LNR (which may be of SSSI value)
• Loss of recreational resource/ accessible greenspace
• Potential impact on highway network
• Viability/ deliverability
Yorks Bridge* 800,000 3,000,000 Walsall/ Staffs CC
Just outside Regeneration Corridor 15 (employment led corridor). The main constraints to working are:
• Green Belt location
• Proximal non-mineral uses (Coppice Side Industrial Estate)
• Potential impact on Cannock Extension Canal SSSI and SAC
• Potential impact on Brownhills Common and The Slough SINC/ proposed LNR (which may be of SSSI value)
• Potential impact on highway network
• Viability/ deliverability
*Figures for Yorks Bridge include resources in Staffordshire. The data provided does not include a breakdown by MPA.
16
Appendix 4:
Assessment Criteria for Mineral
Applications
17
Table A4a: Criteria for Mineral Developments - Key Considerations
Policy MIN5 Criterion
Key Considerations
Consistency with minerals strategy
• Does it support the key planning objectives of national policy guidance towards minerals including the hierarchical approach?
• Does it support Spatial Objective 10 and the strategic objectives of Policy MIN1?
• Would it contribute to the targets and requirements set out in Policies MIN2 and MIN3?
• Would it be meeting a particular need or requirement identified in the RSS, LDF or national policy guidance?
Contribution towards economic/ regeneration objectives
• Would the proposal conflict with objectives to reverse out-migration and improve socio-economic mix?
• What types of minerals are being extracted or processed?
• Who are the customers for the minerals or end products?
• Are the minerals or end-products to be used in the Black Country and if so will they support the proposals for the Growth Network?
• Have opportunities been taken to source potential customers for secondary materials/ by-products?
Contribution towards environmental transformation objectives
• Would the proposal conflict with environmental transformation objectives?
• Would it harm important environmental assets?
• How would final restoration be achieved once working has ceased?
• In the case of mineral extraction, what capacity of void would be created, and what type of fill materials would be used to restore the site?
• What end-use is proposed and would this contribute towards geodiversity, biodiversity, recreation or other environmental infrastructure?
18
Potential for co-location of infrastructure/ synergies
• Does it involve more than one type of mineral development (e.g. extraction, processing, storage and transport)?
• Does it involve recovery of secondary materials or recycling of CD&EW and other wastes into aggregates or other useable mineral products?
• Will it have other benefits such as capturing or recovering potentially harmful greenhouse gases for energy?
• Would it be providing a service or supplying raw materials/ energy to local communities or businesses in the Black Country?
Impact on neighbouring uses
• What types of operations are proposed and would they be compatible with the surrounding/ neighbouring uses?
• Are they likely to cause nuisances to neighbours as a result of increased traffic, dust or noise?
• How long will the proposed use/ operations continue?
• If there are other similar facilities or operations nearby, what would be the cumulative impact of the proposal?
• Is the design and layout appropriate to the type of operation and the location?
• Does the proposal include measures to address potentially harmful effects and if so are they adequate?
Impact on the highway/ transport network
• Would the proposal have significant impacts on the local/ strategic highway network?
• Is there a designated haulage route for material being transported to/ from the site?
• Have potential impacts on the local drainage network from deposit of material onto the highway been addressed?
• Does it include measures to address highway/ traffic impacts and if so are they adequate?
• Have potential opportunities to transport minerals and/ or end products by rail or canal been fully explored?