Preferred Strategy

Comment

Representation ID: 28024

Received: 20/09/2019

Respondent: Mineral Products Association ltd

The section does not appear to make reference to the benefits of mineral extraction to the local and wider economy and influencing the baseline characteristics of many of the topics identified.

Accepted. Add a bullet point to say the following or similar "Contribution of aggregate minerals for construction and the wider economy."

Comment

Representation ID: 28025

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Page 27 - Under the column headed implications for the RLDP, the first paragraphs states ".....the LDP review period plus the required 10 years landbank..."

To reflect the wording of PPW the reference to the 10 years landbank should recognise that this figure is the minimum as indicated in the "Priority Issues" column.

Accepted.

Comment

Representation ID: 28026

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Table 4, references minerals, however, the statement could be improved by recognising that it is society's needs which are to be met and not solely over the plan period.

Accepted.

Comment

Representation ID: 28027

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Mineral resources support much more than the "construction economy". Whilst aggregates and other minerals products provide many of the raw materials for the construction industry, they benefit the wider economy.

Accepted.

Comment

Representation ID: 28028

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Strategic Policy 33 a)
Whilst we support the commitment to ensuring a sufficient provision of permitted reserves, the subsection of the policy would benefit from a brief indication of how this would be achieved, i.e. through the provision of landbanks as referred to in paragraph 6.8.3. We do however believe this should be a policy commitment.

Accepted. The commentary in paragraph 6.8.3 sets out the rationale, for clarity add the following to Policy 33a: ...by maintaining a minimum landbank of 10 years supply of permitted reserves of crushed rock.

Comment

Representation ID: 28029

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Strategic Policy 33 e)
Paragraph 5.14.7 of PPW addresses the Safeguarding of Mineral Resources and Infrastructure. As proposed the wording of this section of the policy does not safeguard the infrastructure associated with minerals processing activities, storage transportation and added value facilities.

Accepted. Facilities which are intrinsic or ancillary to a given quarry such as processing and batching plant are already afforded protection by the quarry buffer-zone policy and by virtue that the surrounding mineral resource is safeguarded and identified on the proposals map and further differentiation is not required within minerals safeguarding layer on the proposals map. The suggested amendment will provide adequate policy protection without needing to identify every such facility. However, it is intended that because the wharf at Raynes Quarry and the rail loading terminal at Penmaenmawr Quarry are at remote locations from the main quarry, these will be identified on the proposals map.

Comment

Representation ID: 28030

Received: 20/09/2019

Respondent: Mineral Products Association ltd

Whilst the principal of this statement is supported, we wonder if reference should be mineral "reserves" not resources. Reserves are mineral resources with the benefit of planning permission.

Accepted. Note that the suggested change to the plan above has erroneously retained the word resources. Delete the word "resources" and only use the word "reserves".

Comment

Representation ID: 28031

Received: 20/09/2019

Respondent: Mineral Products Association ltd

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.

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

Representation ID: 28032

Received: 20/09/2019

Respondent: Mineral Products Association ltd

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.

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..."