Mineral Products Association                            ESH0063

Written evidence submitted by the Mineral Products Association

 

Environmental Audit Committee inquiry: Environmental sustainability and housing growth

 

 

 

About MPA

 

  1. The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and industrial sand industries. MPA membership is made up of the vast majority of independent SME quarrying companies throughout the UK, as well as the 9 major international and global companies. It covers 100% of UK cement and lime production, 90% of GB aggregates production, 95% of asphalt and over 70% of ready-mixed concrete and precast concrete production. In 2021, the industry supplied £22 billion worth of materials and services to the Economy. It is also the largest supplier to the construction industry, which had annual output valued at £178 billion. Industry production represents the largest flow of materials in the UK economy and is also one of the largest manufacturing sectors.

 

Overview

 

  1. The environmental sustainability of housing growth concerns not just where houses are built, but where the materials for them come from, in the UK and overseas. MPA members extract and manufacture construction materials using locally available mineral resources for homes and their associated infrastructure, and have a significant responsibility for nature in the quarries they operate and when they are restored.

 

  1. MPA members are rightly proud of the work they have done for decades on nature restoration, creating net gains in priority habitat through working and restoration plans.[1] These are a well-established part of our industry’s business-as-usual practice and have long been embedded in the mineral planning system.

 

  1. We are concerned that the introduction of Biodiversity Net Gain (BNG) could incentivise quicker but less ambitious restorations in our sector. Given the unique opportunities that are provided by mineral extraction and the considerable track record the sector has in demonstrating nature restoration delivery, minerals sector-specific guidance is required to avoid a perverse outcome for nature.

 

  1. Reduction of greenhouse gas emissions from construction is, of course, essential. Our sector is decarbonising, as set out in our cement and concrete roadmap to net negative[2], and delivered by means including the new version of BS8500 enabling lower carbon concretes as standard. It is also vital that carbon emissions are reduced over the whole life of a structure, including sourcing and manufacture of materials, transportation, construction, operational energy use, end of life and beyond. Resilience of structures provided by their materials is also important with increased rainfall in winter and heat in summer. Concrete and masonry deliver resilient, safe and comfortable homes.

 

  1. Rather than enabling sustainable development, the performance, capacity and capability of the Environment Agency is currently a bar to investment and growth while not delivering for the environment. Similarly, local planning authorities are typically under-resourced to operate as they should, not helped by the perverse decision of the previous government to raise planning fees but not ring-fence this income to support service delivery. We welcome the initial extra funding and the more strategic view being taken under the new Government and encourage them to apply the same thinking to mineral planning as they have to planning for housing and infrastructure.

 

Q5. What contribution can the NPPF make to meeting Government targets for the reduction of greenhouse gas emissions? What account does the NPPF take of advice from the Climate Change Committee on reducing the use of embodied carbon as well as operational carbon in the built environment?

 

  1. Greenhouse gas emissions from the built environment occur throughout a structure’s life cycle, from the production of materials, construction, operation, demolition and re-use or disposal. The NPPF should require that for projects of sufficient scale to be practical to do so, whole life carbon analysis should be carried out to inform design.

 

  1. Whole life cycle analysis is an important means to carefully designing structures, including making appropriate material choices. It is important that it is not prejudged, so a material-neutral approach is best. Different structures will require different mixes of materials and it is not helpful to make blanket assumptions in favour of a material when analytical tools are available to properly assess each structure. It is possible to reduce embodied carbon from concrete structures by using a variety of techniques, with guidance available from The Concrete Centre on how to specify and design efficiently.

 

  1. It is essential that this whole life analysis captures all emissions. Different materials have different distributions of their carbon emissions over their lives and should be compared fairly. Emissions from concrete are largely from the production of cement, and it actually absorbs some carbon dioxide over time due to recarbonation. Concrete structures save operational emissions from structures due to thermal efficiency. Conversely, timber emissions depend heavily on disposal method, and the indirect impacts, for example emissions from soil as a result of harvesting.

 

  1. Beyond carbon, there is growing interest in embodied biodiversity impacts, which are important to understand thoroughly. It is important to note that mineral products are overwhelmingly domestic in scope, and are therefore subject to significant, thorough regulation and BNG rules. Many quarries are restored to very high-quality habitat after extraction. This may not be the case for imported products, depending on their source. Policies aimed at increasing the use of timber in particular risk indirect impacts, because the UK is a huge net importer already, relying on a global timber market that includes both sustainable and unsustainable sources. 

 

  1. The planning system, as shaped by the NPPF, should seek to deliver homes fit for the future. These should be resilient to changing environmental conditions from climate change and provide safe, healthy homes. Having the structure of a home that can remain in use for a long time is fundamental to circular economy thinking and a sustainable built environment

 

Q7. What (if any) trends are observable in (a) delivery of environmental improvements (b) the purchase and trading of credits arising from the Environment Act requirement for developments to yield biodiversity net gain (BNG)? How are planning authorities using BNG in the planning process to deliver environmental improvements from housing development?

 

  1. It is early days with regard to implementation of BNG. Few applications will have been prepared, submitted and determined since the BNG requirement become mandatory in February 2024.  Unlike other development, mineral extraction is temporary and routinely delivers substantial gains in biodiversity through careful management of sites and their progressive restoration.  BNG was designed largely with housing in mind, rather than to address any problems with mineral extraction development and minerals planning, and as such the process and its tools and components do not work well for mineral extraction sites. 

 

  1. There is a danger that the calculation of biodiversity units, the values and multipliers in the Metric, and the way the process is being applied by planning authorities, will lead to worse outcomes for biodiversity than before it was mandatory given the penalties that apply to creation of some habitats that take time to develop and are regarded as difficult to deliver. This is extremely frustrating for the industry as we have a long, proud and proven track record of delivery. The previous Government refused to recognise the unique characteristics, opportunities and challenges of applying BNG to mineral extraction in sector-specific guidance or a modified Metric.

 

Q8. How will the revised NPPF operate to promote the Nature Recovery Network and the implementation of local nature recovery strategies by responsible authorities?

 

  1. Mineral extraction presents a major opportunity to achieve the change in land use necessary to deliver nature recovery, including at landscape-scale.  Allocating mineral extraction sites in plans in areas of ‘opportunity’ for nature would assist in ensuring a steady and adequate supply of minerals for the economy while delivering biodiversity and wider environmental objectives.

 

Q10. What environmental regulatory arrangements within Defra’s remit which relate to the planning process are likely to be under review as potential inhibitors of growth? What effect on environmental protections would reform of these regulations be likely to have?

 

  1. A key issue for our sector is the capacity and competence constraints of regulators, which significantly inhibits planning applications before a site is worked as well as posing challenges in operation. This is a serious issue at the Environment Agency, whose chief executive has previously been candid to Select Committees about the organisation’s challenges. The EA frequently delays consideration of planning by either failing to issue assessments or repeatedly asking for extra information. The performance of the EA is a significant disincentive to investment in the UK for any business that interacts with it.

 

  1. This will not be solved by another round of deregulation or red tape challenge. The rules are generally appropriate or serviceable, but the capacity of the regulator to actually regulate against them is lacking. This is a very expensive way to deliver little for the environment, especially when regulating a sector with a large net positive contribution to nature such as quarrying.

 

  1. The best way to address this is to demarcate much more clearly which issues are for consideration under planning and which under permitting. Planning departments are also under-staffed, so it makes no sense at all for both systems to duplicate each other’s functions.

 

  1. Regulators have had a growth duty since 2017 but this has not yet had a noticeable impact on their behaviour. It would be a good point to approach the issue from, since it should drive focus on areas where the regulator is currently a barrier to growth and investment. 

 

  1. As outlined above, BNG is a major additional cost and source of delay for development, including mineral development.  Recognition of how mineral extraction differs from other types of development, and the track record for delivering high quality biodiversity through working and restoration of quarries, should be made in specific guidance and greater flexibility in how BNG is applied to mineral extraction development.

 

 

 

December 2024

 

[1] for example see https://mineralproducts.org/Publications/Natural-Environment/Quarries_and_Nature_50_Year_Success_Story.aspx

[2] https://mineralproducts.org/MPA/media/root/Publications/2020/MPA-UKC-Roadmap-to-Beyond-Net-Zero_Oct20.pdf