6.8.7

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Comment

Preferred Strategy

Representation ID: 28031

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Representation Summary:

This paragraph states, "It is proposed to only safeguard deposits which exceed a defined threshold of size...."

There is no indication of the "size threshold" in the text. We would also question this approach as consideration must be given to area, quantity and quality of the mineral, together with other economic considerations.

Full text:

See attached document.

Attachments:


Our response:

Accepted in part. The exercise to limit safeguarded sand and gravel resources to a pragmatic and proportionate scale used an iterative sieve mapping process to remove small and spatially intermittent deposits. This considered factors such as accessibility, remoteness, planning constraints, proximity to other allocations and tidal flood plains to remove deposits which are considered unlikely to be of economic or social value for the LDP period and beyond for future generations. The random and discontinuous nature of many of the smaller deposits, often being less than 100 metres in extent and thin in depth, are not know to be of high quality, and are interspersed with boulder clays and silt. The application of the requisite buffer zone around the outer edge of the deposit creates a disproportionately large safeguarding area which is exacerbated where several small 20 to 100 metre diameter deposits are located within 200 metres of each other which causes the buffer zones to merge, giving the false impression of a much wider and extensive deposit than is the case. In the absence of evidence to confirm that such deposits have a quality worthy of safeguarding, they are not included.

Comment

Preferred Strategy

Representation ID: 28032

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Representation Summary:

This paragraph does not refer to the requirements within PPW to safeguard minerals infrastructure.

As stated above, Paragraph 5.14.7 of PPW addresses the Safeguarding of Mineral Resources and Infrastructure. As proposed the wording of this paragraph does not recognise the need to safeguard the infrastructure associated with minerals processing activities, storage transportation and added value facilities.

Full text:

See attached document.

Attachments:


Our response:

Accept. Refer to the response given to representation 28029. In the first sentence insert the text "and minerals related infrastructure" after "Welsh government requires land containing mineral resources..."