Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 14109
Received: 10/12/2020
Respondent: Mr Andrew Freeman
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Policy P13. Fails to distinguish between Mineral Safeguarding Areas and the safeguarding of minerals-related infrastructure sites, which should be safeguarded wherever they are. The criteria concerning prior extraction should include environmental considerations. Policy concerning alternative materials is unclear and should reference related treatment facilities, major rather than significant development, distinguish between temporary and permanent facilities, which should not be encouraged in Green Belt but in acceptable locations throughout the Borough. The quantity of aggregate to be provided over the Plan period is not justified by proportionate evidence, as the sales data is dated and could be unreliable, takes no account of demand or secondary/recycled materials, and the area is reliant on imports, and is not Solihull-specific. Landbank provisions have been applied incorrectly or not at all for silica. Designations referred to in the policy and the justification are not shown on the Policies Map. There is confusion over the criteria for mineral working and regarding restoration and aftercare, biodiversity should be covered and coal-related considerations removed, whilst paragraph 9 could be covered in justification.
Policy P13
Delete reference to infrastructure from paragraphs 1-3 and re-order 2 and 3.
Add new paragraph 4 on minerals-related infrastructure sites:
'Minerals-related infrastructure sites, as identified, are also safeguarded from incompatible development. Redevelopment for unrelated purposes or encroachment by incompatible development will not be permitted unless alternative provision in the vicinity can be made in accordance with the development plan or there is no longer a need for the facility at this location.'
Reword paragraph 4:
'5. In all new development within the Borough, the Council will actively promote the use of alternative materials such as secondary and recycled aggregates and minerals waste. Subject to other development plan considerations, temporary facilities for the treatment of such materials will be encouraged at major development sites, including mineral workings. Permanent facilities will be encouraged at Strategic Waste Management Sites and other appropriate locations.'
Reword paragraph 5 and revisit quantum:
'6. Provision for primary sand and gravel resources will be made through a mixture of specific sites, preferred areas and/or areas of search to meet the identified requirement of XX million tonnes for the West Midlands Metropolitan Area over the plan period or such lesser amount as may be required following the Black Country Core Strategy Review. The provision will include sites already granted planning permission where not included in the current sub-regional landbank. In addition, the Council will seek to maintain a landbank of permitted reserved of at least 7 years.'
Delete paragraph 7.
Amend sub-heading to 'Criteria for mineral working', delete reference to underground extraction in paragraph 8 criterion v. and criteria ix, x and xi.
Add new sub-heading 'Restoration and aftercare' and replace paragraph 9 with:
'The Council will require restoration to a safe and high-quality condition with appropriate aftercare in accordance with agreed restoration and aftercare schemes and within an agreed period following the cessation of extraction. Reclamation to an agreed use shall prioritise the contribution the site could make to green infrastructure, the conservation and enhancement of biodiversity, including Local Biodiversity Action Plans, the enhancement and restoration of the Arden landscape, flood risk management, appropriate recreation uses and agriculture, as well as the availability of suitable infill material if appropriate.'
See attached