Question 1: Do you think that the Regional Guideline outlined in Table 1 can be met at an acceptable environmental cost?
Table 1
Regional Guidelines for Aggregates Provision in West Midlands 2005 – 2020 (million tonnes)
Guidelines for land-won production | Land-won Sand & Gravel | 165 Mt |
Land-won Crushed Rock | 82 Mt |
Assumptions | Alternative Materials | 100 Mt |
Net Imports | 23 Mt |
Answer: No
It is considered that the current guidelines as shown in Table 1 do not provide the most sustainable balance of supply of aggregate materials within the West Midlands region.
Options 2 and 3a should be considered to provide a more sustainable balance of supply of aggregate material.
Question 2: Please rank (from 1 to 3) which of the Options you think would provide both an adequate and steady supply of materials and the most sustainable supply in the region up to 2020 (1 is the most sustainable, 2 is the second most sustainable and 3 is the third most sustainable)
Answer: see table below (n.b. Options A to E are primarily supported as an alternative method of apportionment to that used previously which was based on past sales trends).
| Please rank the 3 most sustainable apportionment options for the region |
Option 1a: Past Trends - 3 Year Average Sales (6.74Mt) |
|
Option 1b: Past Trends - 5 Year Average Sales (6.73) |
|
Option 1c: Past Trends - 10 Year Average Sales (6.72) |
|
Option 2: Substitution of Sand and Gravel - with 25% increase in recycled aggregates (5.70) | 2 |
Option 3a: Substitution of 10% Sand and Gravel - with crushed rock (6.05) | 3 |
Option 3b: Substitution of 10% Crushed Rock - with sand and gravel (7.01) |
|
Option A: Supply-Led (2.80) | 1 |
Option B: Growth-Led (2.47) | 1 |
Option C: Environment-Led (2.71) | 1 |
Option D: Equal Weighting (3.34) | 1 |
Option E: Demand and Resource (2.64) | 1 |
Question 3: Are there any Options which you consider would not provide either an adequate or sustainable supply of aggregates to 2020?
Answer: Yes
Options 1a; 1b; and 1c based on past sales trends; and Option 3b that would increase the requirement for sand & gravel provision as a substitute for crushed rock.
For background detail…
CONSULTATION ON SUB REGIONAL APPORTIONMENT OF GUIDELINES FOR THE PROVISION OF AGGREGATES IN THE WEST MIDLANDS
Further to the details of the above consultation by the West Midlands Regional Assembly lease find below notes to assist in responding to the consultation questions.
The supply of aggregate minerals and in particular, sand & gravel, are the most significant minerals planning issue in Staffordshire. Aggregates provide the raw materials to make construction products such as mortar, asphalt and concrete. Within the West Midlands region, Staffordshire currently provides:
- 65.2% of the region’s sand & gravel; and
- 24.2% of the region’s crushed rock.
The new guidelines for the provision of aggregates relate to the period 2005 up to the end of 2020 (16 years). The guideline figures for the West Midlands are:
Sand & gravel | 165 million tonnes (10.3 million tonnes per annum) |
Crushed rock | 82 million tonnes (5.12 million tonnes per annum) |
These guidelines are based on the assumption that there will be a contribution of 100 million tonnes from alternative aggregates such as recycling construction & demolition waste; and a net import of primary aggregates to the region from outside England of 23 million tonnes. These figures are provided in Table 1 as referred to under question 1 of the consultation.
Question 1: Do you think that the Regional Guideline outlined in Table 1 can be met at an acceptable environmental cost?
- It is considered that the current guidelines as shown in Table 1 do not provide the most sustainable balance of supply of aggregate materials within the West Midlands region.
- The guidelines should be re defined so as to secure the long term conservation of important aggregate mineral resources and minimise the environmental impacts associated with quarrying.
- Sales figures for sand & gravel indicate that over the period 1998 to 2007, Staffordshire has produced between 64% to 68% of the region’s sand & gravel. Consequently, there are concerns about the environmental impact associated with this level of provision in Staffordshire. Firstly, there are the temporary impacts on the environment e.g. noise, dust, visual intrusion & traffic affecting local communities which can be of long duration particularly in concentrated areas of working. Secondly, there are permanent impacts in terms of changes to landscape and land use.
- The current guidelines rely too much on the contribution to be made from the sand & gravel resource from the region and in particular, from the remaining sand & gravel resources to be found within Staffordshire if past trends for supply are maintained.
- Aggregate minerals are finite resources and suitable opportunities to extract aggregate minerals are restricted. Therefore, the guidelines should be more challenging and encourage a greater use of recycled waste materials and industrial by products as alternative sources of aggregate materials.
- Option 2 that requires increased recycling of construction and demolition waste to produce aggregate should be considered on the basis of preparing to meet the challenges of meeting construction material requirements beyond 2020.
- Crushed rock quarries are capable of producing materials that could be used to substitute the fine aggregate derived from sand & gravel resources. This would involve technological changes in the processing of rock and would not apply to all rock resources but given the extent of operational and non operational crushed rock quarries and the extent of reserves associated with these quarries, the region should consider Option 3a to alter the balance of supply and encourage greater use of existing crushed rock resources.
- The forecasting model used by Government for the guidelines takes into account that certain types of construction are less intensive in terms of the use of aggregate but does it fully take into account the changes that might be required to meet the requirements of sustainable construction and in particular the requirements of reducing the carbon footprint of our buildings?
- As a consequence of the current downturn in construction activity, the WMRA should request that Government re-run the model for forecasting guidelines taking into account more up to date evidence & forecasts of construction activity as well as the consequent impact on the consumption of aggregate materials. Recent evidence in Staffordshire, for example indicates that sales of sand & gravel decreased by 17% from 2007 to 2008.
Question 2: Please rank (from 1 to 3) which of the Options you think would provide both an adequate and steady supply of materials and the most sustainable supply in the region up to 2020 (1 is the most sustainable, 2 is the second most sustainable and 3 is the third most sustainable)
- In view of Staffordshire’s concerns about the method of apportionment based on past sales trends, support should be given to the alternative method of apportionment as explained in the Land Use Consultants report (Options A to E). In particular, Option E would be favoured because the principal weightings should be a balance of factors reflecting the need to supply demand with local supply.
- The method provides a means to consider key factors relevant to future provision of aggregate minerals and to apply a fair and logical balance to the factors used.
- It is noted that Option E was recently accepted as a basis for apportionment of the sand & gravel guideline in the south-east region by Inspectors considering the review of sub regional apportionments in that region.
- As discussed in response to question 1, there is also merit in Option 2 and Option 3a on the basis that these options provide an opportunity to achieve a more sustainable balance of supply through the guidelines.
Question 3: Are there any Options which you consider would not provide either an adequate or sustainable supply of aggregates to 2020?
- Options 1a/ 1b/ 1c - Past sales trends: It is considered that options based only on past sales trends do not afford opportunity to consider supply options that might meet future needs and provide a more sustainable pattern of supply.
- These options would maintain the concentration of sand & gravel working in Staffordshire. As quarries are exhausted, the options would exert pressure to replace production capacity within other areas of Staffordshire that could be either subject to the impacts of quarrying or in areas not ideally located to serve areas of demand.
- Option 3b - Increasing sand & gravel to replace crushed rock production: This option is not considered sustainable on the basis that it would involve increasing reliance on the sand & gravel resource which is already required to contribute 67% of aggregate minerals. There needs to be an appropriate balance between the exploitation of sand & gravel and crushed rock resources given that the extent of impact from working sand & gravel resources is more extensive. Furthermore, there are more extensive remaining permitted reserves of crushed rock. (This is the worst option of the lot!)