Written evidence submitted by the Mineral Products Association [FPS 050]

About MPA

1. The Mineral Products Association (MPA) is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries. It has a growing membership of 520 companies and is the sectoral voice for mineral products. 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 2016, the industry supplied £18 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 £169 billion in 2018. Industry production represents the largest materials flow in the UK economy

2. Our response focuses on the minerals planning system, an often-overlooked part of the wider land use planning system. The steady and adequate supply of essential minerals and mineral products needed to deliver the housing, infrastructure, other developments and manufacturing we all rely upon, cannot be assumed.  Aggregates are essential for construction, whilst industrial minerals supply construction and manufacturing.  The supply of minerals needs to be planned for, monitored and managed. We have urged policy makers to make the link between development and the materials needed to build, for the long term.

Q1. Is the current planning system working as it should do? What changes might need to be made? Are the Government’s proposals the right approach?

3. The current planning system is not working well for minerals, despite the basic architecture being in place to allow it to do so. Over the period 2009-18, only 63% of sand and gravel sales and 75% of crushed rock sales were replaced by newly permitted reserves. This low and falling level of replenishment is a consequence of the planning system which our members find slow, expensive and inconsistent. This not only slows down new mineral reserves being approved to replace those worked but presents a barrier to investment for new sites and infrastructure being brought forward.

4. The challenges facing the minerals planning system play out over several key areas. Specialist mineral planning skills and resources are very stretched at local level, with some authorities coping and others less so. The lack of skilled planning professionals makes the process less predictable, increasing the chance of councillors misunderstanding or ignoring the vital role of minerals when making planning decisions, especially in the face of local opposition.

5. The whole mineral planning system is underfunded, but it would not cost much to change this. In MPA’s submission to the Aggregates Levy Review[1], we called for a small proportion of the levy, which generates c. £400 million per year, to be spent on supporting the mineral planning system. We also call on mineral planning fees to be ring fenced to the mineral planning system to ensure an applicant can have confidence that they are receiving the service they have paid for, rather than subsidising other local government services or functions.
6. For construction aggregates, the Managed Aggregates Supply System (MASS) has been in operation for many years, in recognition of the uneven distribution of minerals and areas of demand, the time it takes to secure new reserves and produce material for the market, and the need for strategic planning to maintain a steady and adequate supply of materials. However, the central government funding that underpins the delivery of MASS has significantly reduced, leaving the ability to maintain a ‘steady and adequate supply’ of essential minerals vulnerable. A strong national ‘statement of need’ for minerals, including production of up-to-date National and sub-national Guidelines for aggregates, continued support for national data collation and support for the operation of the regional Aggregates Working Parties (AWPs), are essential components of MASS and would further strengthen strategic planning for, and consequent supply of sufficient minerals for the economy.  The statement(s) of need, and the Guidelines, are also critical in providing forecasts of demand for minerals that reflect government ambitions for housebuilding and delivery of infrastructure. Local authorities do not have the resources or expertise, to undertake such work and a larger-scale strategic approach is required.

7. MPA proposed a number of changes in a document we published[2] ahead of the Government’s White Paper:
1. Better resourcing of minerals planning authorities, using a small proportion of the substantial revenues generated by the Aggregates Levy.
2. Streamline the plan-making process, with a focus on simpler plans that can be produced more quickly, that address genuinely local issues and spatially specific policies. These would include site specific allocations, preferred areas and areas of search, providing an appropriate mix of certainty and flexibility for investment and development. 
3. Development management policies for minerals should be set at national level and not duplicated or translated locally to provide consistency. Issues settled during the plan making process such as suitability in principle of allocated sites and preferred areas for minerals development, as well as access design and other technical matters should be ‘banked’ and not require a fresh start as part of the application unless the applicant chooses to apply material changes.
4. Ensure that information requirements are material, reasonable and genuinely necessary to formulate sound policies and make decisions
5. The Environmental Impact Assessment and Strategic Environmental Assessment processes should be streamlined and the scope for vexatious legal challenges reduced.

8. The proposals for planning reform outlined in the Planning White Paper unsurprisingly centre on increasing delivery of new housing, but unfortunately to the extent of excluding consideration of any other aspect of the land-use planning system. Local planning is about more than housing delivery alone, and it is vital for policymakers to make the link between their ambitions on housing and the steps needed to enable the supply of the essential minerals that are required to support not only house building, but also Government’s wider ambitions around economic recovery, including the delivery of schools and hospitals along with transport, energy and water infrastructure.

9. We support a number of the proposed reforms in the White Paper including deadlines for adoption of local plans, speeding-up decision making, and the proper resourcing for planning departments. But overall it only really addresses one output of the planning system, and neglects key parts of the overall system and in that sense it represents a missed opportunity.

Q2. In seeking to build 300,000 homes a year, is the greatest obstacle the planning system or the subsequent build-out of properties with permission?

10. There are a number of challenges. Ensuring the supply of essential mineral products needed for construction and other downstream uses, through a system that is not currently delivering replacements of the resources that are being consumed by society, is a fundamental issue that needs to be addressed before supply becomes unnecessarily scarce. To build any level of housing requires mineral products. However, newbuild housing only represents 25% of overall construction aggregate demand, and constraints in supply have the potential to impact Government’s wider ambitions around economic recovery, including the delivery of schools and hospitals along with transport, energy and water infrastructure.

11. The Letwin Review found little evidence that the planning system was the problem in tackling housing shortages, and we have not seen evidence that would strongly challenge this conclusion. Consequently, there is a sense that the reforms set out in the White Paper are attempting to address the symptoms of this failure, rather than perhaps tackling the root causes.

Q3. How can the planning system ensure that buildings are beautiful and fit for purpose?

12. There are several ways to build beautifully, but an important aspect is to support the use of local products with identifiably local character. From the yellow Millstone Grit of the Pennines to Lakeland Slate or Cornish Granite, dimension stone is a beautiful, traditional and local material that should be valued in the planning system because it imparts the local character and vernacular of each area. The inherently local industry that supplies stone is currently discriminated against due to misinterpretation on National Planning Policy which will prevent it contributing as it should the building of beautiful buildings. This sector needs some policy support, including safeguarding quarry sites and known geological resources.

13. Making a building fit for purpose includes thermal efficiency, especially as the climate warms. Building materials with high thermal mass, such as concrete and traditional bricks and mortar, reduce the need for heating in winter and, importantly, reduce the need for air conditioning in hot weather which will become increasingly important. Fitness for purpose also includes resilience, where heavyweight building materials outperform lightweight, especially timber on fire safety, flood resilience and rot. Given the resilience of masonry and concrete in particular, structures can be designed as “long life, loose fit” to enable repurposing over their lifetime rather than demolition. Buildings constructed from these products are also recyclable, with 29% of Great Britain’s needs for construction aggregates currently being provided from recycled and secondary aggregate sources – the highest contribution in Europe.[3]

Q4. What approach should be used to determine the housing need and requirement of a local authority?

14. Around a quarter of newbuild construction is housing. While we do not have a position on determining housing need it is vital that the future needs of the wider construction sector are not forgotten – including transport and energy infrastructure. This supply cannot be assumed, and the local planning system, supported by MASS, has a key role to play in planning for, monitoring and managing the delivery of these long term needs.

15. This is one of the limitations of delivering planning solely at a local level. In the case of minerals, a strategic view is required to consider the flows of essential materials between the areas where mineral resources exist, and the areas where they are being consumed – some areas being net producers, while others are net consumers.  Maintaining a ‘steady and adequate supply’ of minerals requires a more strategic oversight of supply and demand which cannot be achieved through local planning alone – hence the importance of a well-resourced and functioning Managed Aggregate Supply System.

Q5. What is the best approach to ensure public engagement in the planning system? What role should modern technology and data play in this?

16. There are many ways to engage the public, which our industry already does when developing plans for a new quarry and throughout the lifetime of a site’s operation. Technology may change the medium but it does not substitute for taking the time to explain properly a proposal and to meaningfully engage with communities who may be in the vicinity of a site.

17. We are sceptical that the public will necessarily engage at the appropriate stage in the planning process, or that this will speed up the process beyond the effects of administrative efficiency. We also have concerns about whether there are the skills and technology in local authorities to deliver the new ways of working that will be required. There would be potential efficiency savings if all local authorities used the same digital systems.

Q6. How can the planning system ensure adequate and reasonable protection for areas and buildings of environmental, historical, and architectural importance?

18. The existing planning system already does this effectively, in the case of minerals, and does not need to change in this regard. Tests in the system are well-designed, with different tiers of protection in place to ensure only appropriate development is permitted. For our sector, this is important because some protections which may constrain other forms or development actually allow our industry to proceed with due conditions in place, for instance quarrying in National Parks and sand and gravel extraction in flood risk areas. This reflects both the temporary nature of the work, its compatibility with water, and the high-quality restoration and aftercare that will be a standard requirement for such developments.

Q7. What changes, if any, are needed to the green belt?

19. For mineral development, the main change that would be beneficial would be to improve the consistency of activities that are permitted.  Mineral extraction need not be inappropriate development in the green belt as mineral operations are temporary and can only be worked where the minerals are found, but often conveyor belts or other equipment essential for the work may be deemed inappropriate, preventing a site from being worked. Again, the temporary nature of our industry must be emphasised here because it does not represent a permanent development.

Q8. What progress has been made since the Committee’s 2018 report on capturing land value and how might the proposals improve outcomes? What further steps might also be needed?

20. No response.

October 2020