POLICY P13 Minerals

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Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10729

Received: 07/12/2020

Respondent: The Coal Authority

Representation Summary:

The Solihull area does not contain any recorded risks from past coal mining activity at shallow depth, nor do Coal Authority records indicate any surface coal resource is present. On this basis we have no specific comments to make in relation to the draft Local Plan.

Change suggested by respondent:

None

Full text:

As you will be aware the Solihull area does not contain any recorded risks from past coal mining activity at shallow depth, nor do our records indicate any surface coal resource is present. On this basis we have no specific comments to make in relation to the draft Local Plan.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10809

Received: 12/12/2020

Respondent: Richard Cobb Planning

Legally compliant? No

Sound? No

Duty to co-operate? No

Representation Summary:

Future use of Arden Eco Park for employment purposes and an Energy from Waste facility need to be considered properly and seriously, given the strategic location of this site. The frontage of the site is occupied by a large number of lawful businesses, and should be recognised for future development.

The designation of the Site as RIGS is not realistic in the Plan Period given that the clay extraction and restoration will have been largely compled and no working surface is likely to be visible.

Change suggested by respondent:

Allocate the Arden Eco Park site for employment uses and an Energy from Waste site and delete reference to a RIGS.

Full text:

The wider former Arden Brickworks site, now called Arden Eco Park, covers a total area of around 38.6 hectares (95.4 acres). The Eco Park site is accessed from the A45 via a one-way service road running on the south side of and parallel to the A45 between Stonebridge Island to the east, at the junction of the A45/A452, and M42/J6 to the west.

The Arden Eco Park lies within the M42 Solihull Economic Gateway with additional expansion proposed to this gateway. It is located in the West Midlands Green Belt in the Meriden Gap which separates Birmingham from Coventry and is largely surrounded by agricultural land apart from a large Kennel complex – Top Hat Kennels - on the frontage which is likely to be directly affected by HS2, and Pasture Farm to the east. The HS2 line is due to pass just to the east of Arden Eco Park leading into the new Interchange Station north of the A45.

Birmingham International Airport, the National Exhibition Centre and Birmingham International Station are located around 2 miles to the north west accessed off the A45 to the west of the M42.
The site is within the stategic UK central area.

Future development of the site

As such Arden Eco Park is a major previously developed site in a strategic position and already operates a Materials Recovery Facility (MRF) at the rear of the site alongside the remaining areas of clay extraction. The Local Plan recognises the clay extraction operation as well as the MRF as established facilities.

The major frontage part site comprises a Civic Amenity Facility which has operated for many decades to service the wider Solihull community but is proposed to be relocated to a site near Damson Parkway which for many is likely to be less accessible that the present facility at Bickenhill.

Behind the Civic Amenity site lie a large number of business units used by utility and civil engineering companies for offices and ancillary facilitate as well as open storage (B8) with ancillary facilities mainly covered by a Certificate of Lawful use granted by the LPA in 2007 (ref 2007/ 1171). The site comprises a large area of hardstanding a range of buildings in brick or profiled steel buildings which have largely replaced the former brickwork buildings.

The owners of the land have ambitions to establish a major Power from Waste facility on this site which would make a major contribution to the energy needs of the area around including the Arden Cross development area around the HS2 Interchange with over 5000 new houses as well as business development.

The Arden Eco Park site has been submitted under the Council’s Call for Sites in relation to the Local Plan as land for business and employment uses given into extensive past history. The Local Plan has not recognised that submission and no provision is being made in the plan for the site to contribute positively to needs of the Solihull Economic Gateway which it is well placed to do.

No provision is made in the Plan for dealing with major brownfield sites in the Solihull Local Plan which are included within many other local plans. Leaving it to the development management process is not sufficient to give a proper and appropriate policy framework for considering proposals. In the future.

The Arden Eco Park site should be allocated as a site for energy from waste and other related development.

RIGS Designation

The Local Plan refers to a Regionally Important Geological Site within the minerals working area. As we understand it RIGS are now called ‘Local Geological Sites’ and have a similar status to Local Wildlife Sites, i.e. non-statutory but protected through policy in Local Plans and as a material planning consideration in applications.

The designation for the Brickworks site still exists in the Submission version of the Local Plan and we believe that the citation for the former brickworks describes important exposures of the Triassic, Mercia Mudstone Group which are important for educational purposes. 'The strata consists of irregularly bedded red clay and mudstone, interbedded with green mudstone and green sandstone skerry horizons'.

While the quarry owners are prepared for students to observe the exposure subject to proper prior and safe arrangements, that exposure is not static and mineral working and subsequent landfill n that such exposure is continually on the move. While extraction is ongoing then presumably there will new exposures of these strata created periodically but the requirements of the minerals planning permission require the land to be back filled and returned to agriculture. As such that designation on the site should be removed from the Local Plan.

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 10881

Received: 14/12/2020

Respondent: The British Horse Society

Representation Summary:

Broadly accept.
8. Please include the protection of and opportunities for expansion of Public Rights of Way within the policy.

Full text:

Broadly accept.
8. Please include the protection of and opportunities for expansion of Public Rights of Way within the policy.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13696

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

As stated in our previous consultation response, we recommended that point 8(viii) is amended to specifically provide guidance on how buffers between mineral extraction and rivers should be managed.

Change suggested by respondent:

We therefore recommend the policy is revised to read: Measures for mitigating any environmental, transport or other impacts or for compensation for loss or damage where appropriate, including the provision of buffers between extraction and environmental or other assets, and in respect of river buffers whether these are wide enough to accommodate natural changes to the river’s location’.

Full text:

See Attached Letter.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 13697

Received: 12/12/2020

Respondent: Environment Agency

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

As acknowledged within our 2017 response given your proposed minerals allocations and areas of search, this is most likely applicable to the River Blythe. We welcome the addition of text in supporting paragraph 368 to specifically relate to a 30m buffer. We recommend this is incorporated into the policy itself.

Change suggested by respondent:

Recommend that 30m buffer to River Blythe in supporting text in paragraph 368 is incorporated into the policy itself.

Full text:

See Attached Letter.

Attachments:

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

Representation Summary:

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.

Change suggested by respondent:

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.'

Full text:

See attached

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14247

Received: 12/11/2020

Respondent: Meriden Parish Council

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Hours of Mineral operation should be 7am to 6pm Monday to Friday and Saturday 7am to 1pm. Mineral planning authorities should assess the cumulative impact from quarry developments.

Full text:

Good evening

Please see attached letter from Meriden Parish Council in response to Solihull’s Draft Local Plan consultation.

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14612

Received: 14/12/2020

Respondent: Tarmac Trading (Ltd)

Number of people: 2

Agent: Heaton Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The existing mineral development and associated infrastructure facilities contribute significantly to local, regional and national need. Although these facilities are safeguarded under Policy P13, their importance and role should be given elevated status and recognition within the Plan. The growth/development plans in Solihull and the West Midlands create such a substantial long-term need for aggregate and aggregate related products that the facilities will be required for the duration of the plan period. These are facilities already in situ and have been for a number of years. They are not new development further encroaching on the Green Belt.
The policy relating to safeguarding of mineral resource should cover the whole Plan area, rather than only the Mineral Safeguarding Areas designated on the policies map.
Policy P13 9 should not limit the life of ancillary activities to the life of reserves, as there are clear exceptional circumstances, including objectively assessed need for
mineral development/product.

Change suggested by respondent:

Although mineral development and associated infrastructure facilities are safeguarded under minerals policy, their importance and role should be given elevated status and recognition within the Plan.
The policy relating to safeguarding of mineral resource should cover the whole Plan area.
Remove reference to limiting the life of ancillary activities to the life of reserves in Policy P13 9

Full text:

Introduction and Background
Representations to the above consultation are made on behalf of our clients Tarmac Trading Limited and Tarmac Building Products Limited (Tarmac). Tarmac operate two Readymix (RMX) Plants and a Dry Silo Mortar (DSM) Plant situated off Cornets End Lane, Meriden. All Tarmac plants are strategically important for the supply of mineral product to serve local, regional and national construction needs.
Both RMX plants have permanent planning consent for their continued operation. Planning permission has recently been granted to replace one of the RMX plants to supply HS2. On completion of that contract, the RMX site will revert to serving local construction markets.
Dry silo mortar is a specialised construction material comprised of kiln dried materials and is supplied direct to market in sealed silos, which are typically transported by road. The materials (sand, cement, pigment and additives) at the plant are blended in accordance with each customer’s bespoke requirements. The DSM plant is of national strategic importance. The operation of the DSM plant is time limited to working of the adjacent Meriden Quarry site.
DSM is ideal for housing and commercial developments alike, particularly at larger sites which require larger mortar volumes produced under rigorous factory-controlled conditions. There is no need for onsite mixing given the requisite materials are already contained within a sealed silo
and the required volumes can be produced as and when necessary. This ensures consistency of
mortar colour for the whole construction project and helps to minimise waste caused by adverse
weather conditions when compared with other mortar products (it is mixed as and when
required as opposed to deliveries of wet mix to sites). Such is the specialist nature of the product
that there are understood to be only twenty DSM plants located within the entirety of the United
Kingdom. Tarmac operate five of these plants in the following locations:
• Colchester, Essex;
• Meriden, Solihull;
• Glasgow, Scotland;
• Leeds, West Yorkshire; and
• Croxden, Staffordshire.
In the last five years, sales of DSM have doubled whilst the number of sites has not increased
proportionately. Although aggregate workings generally have a defined market area, DSM plants
do not, owing to the specialist nature of the product and limited locations across the United
Kingdom. The result of this is that one site may supply a number of areas across different
administrative boundaries. For example, Tarmac’s Meriden site is of national importance forming
a key part of the DSM network, supplying customer needs in location as far as Kent, East Sussex,
West Sussex, Hampshire, Dorset, Devon, Cornwall, North and South Wales and East Anglia.
Tarmac supplies two of the top three UK housing developers, a key strategy is to maintain
continuity of supply to sustain and meet future demands for a growing national housing market.
Both the RMX and DSM plants are supplied by sand from the nearby Meriden Quarry and
Berkswell Quarry sites. In addition, sand is imported from Shireoak Quarry (Walsall) for blending
with sand from Meriden Quarry to make it suitable for the DSM process. Whilst fine sand is an
important mineral resource it is not suitable for use as an aggregate required for production of
ready mixed concrete. These quarries are used as they are a local resource, and they produce a
distinctive and popular colour to the mortar.

The Local Plan Consultation
All Tarmac plant sites situated at Cornets End Lane are within land designated on the emerging
Plan Policy map as ‘Mineral Safeguarding Areas’ and ‘Areas of Search for Waste Management
Facilities’. They are in proximity to land designated as ‘Preferred Areas for Minerals
Development’. This whole area is designated Green Belt.
Emerging Policy P17 (Countryside and Green Belt) seeks to retain land permanently open unless
very special circumstances have been demonstrated in accordance with the NPPF. Part 4 of the
policy identifies very special circumstances which may be considered when assessing proposals
for ‘inappropriate’ development. One of those very special circumstances for development is the
provision of waste management operations, providing that the development accords with the
waste management policy of the plan. Waste Management development is to be determined in
accordance with the requirements of Policy P12 (Resource Management).
Part 3 of Policy P12 identifies the strategy for waste provision and the sites preferred for waste
management and uses. The policy seeks to ensure that an equivalent tonnage is provided for
within waste management facilities to that arising within the Borough. To achieve this, a
sequential approach is proposed to determine the appropriate location for new waste
management facilities as follows:
i. On-site management
ii. Consolidation or expansion at strategic waste management sites
iii. Suitable industrial areas or sites allocated for industrial or employment uses
iv. Co-location of complementary waste management operations at Berkswell and
Meriden quarries
v. Area of Search for waste management facilities.
Part 5 to Policy P12 identifies strategically important waste management sites within the
Borough, where waste management activities will be supported in principle. These sites include
the site of the former Arden Brickworks in Bickenhill, which contains the household waste
recycling centre, and a range of other waste management operations, the materials recovery
facilities at Berkswell and Meriden Quarries, the composting facilities in Berkswell, and the Moat
Lane and Chapelhouse Depot waste transfer stations in the Mature Suburbs and North Solihull.
As identified above, these preferred areas for new waste management facilities are collocated
with mineral development at Berkswell and Meriden Quarries. Some of which have permanent
consent. The justification for allowing permanent forms of waste development that would go
against the principles of maintaining openness in the Green Belt is objectively assessed need for
waste capacity and the difficulty in finding suitable locations for such uses on land not designated
as Green Belt. In addition to proximity to demand/need, the highway network and the ability of
these areas to accommodate the traffic generated.
With consideration of potential/future waste facilities, the emphasis is on managing indigenous
requirements (equivalent tonnage within waste management facilities to that arising). It is
Tarmac’s view that objectively assessed need for mineral development and associated
infrastructure needs have been overlooked. The existing facilities contribute significantly to local,
regional and national need. This goes far beyond only the local requirements within the Borough
that are the necessary exception tests for new waste development. As a result the support and
retention of minerals associated development should hold equal weight if not greater weight
within these areas. The LAA (2015) identifies, ‘the main issue for local plans is to ensure that the
role of the existing network of manufacturing plants is recognised’ (paragraph 3.5.5 Heatons
emphasis). Although these facilities are safeguarded under minerals policy, their importance and
role should be given elevated status and recognition within the Plan.
Very special circumstances precedent has already been accepted/demonstrated in the case of
permanent waste management operations permitted adjacent to the Tarmac’s existing
operations. The early review of the Plan has been triggered by the need for Solihull to find land
to meet its own housing needs, as well as helping to address the housing shortfall occurring in
the wider Housing Market Area. The growth/development plans in Solihull and the West
Midlands create such a substantial long-term need for aggregate and aggregate related products
- that will, by virtue of the location of the Meriden sand and gravel Area of Search, involve mineral
extraction and associated infrastructure in the Green Belt for the duration of the plan period –
such that these considerations substantially outweigh the level of potential harm to the Green
Belt. Particularly as these are facilities already in situ and have been for a number of years. They
are not new development further encroaching on the Green Belt.
In view of the above comments, it is considered that the policy relating to Resource Management
(P12) and exceptions within the Green Belt (P17) is not an effective or positively prepared
strategy for managing mineral product supply over the Plan period. The policy should also give
due consideration to the need and support for the permanent retention of mineral infrastructure
to meet anticipated demand as well as maintaining existing supply. It is questioned whether this
area being retained as Green Belt is appropriate given the proximity to land being released to
accommodate large scale development, historic industrial activity as well as the long term
strategy for waste management/industrial uses being accepted in this area.
Policy P13 identifies, ‘Mineral Safeguarding Areas (MSAs) for sand and gravel aggregate
resources between Berkswell, Hampton and Meriden and east of the NEC and M42, including
sites for important associated infrastructure and to meet potential needs are defined on the
Policies Map’. As drafted Policy P13 is not in accordance with the NPPF. The NPPF paragraph
204c states that planning policies should safeguard mineral resources. The policy reads as though
safeguarding of mineral resource is only applicable to the above identified areas and shown
designated on the policies map. The approach to resource safeguarding should cover the whole
Plan area and the policy wording and associated mapping should not exclusively identify
resource in only one specific area.
Part 9 of Policy P13 states that, proposals for ancillary uses will be permitted where they are
located within the extraction site, are limited to the life of the permitted reserves and minimise
the impacts on environmental assets, transport infrastructure and surrounding occupiers and
uses. The Council will support proposals for complementary recycling facilities, which should be
as close as possible to the point of extraction or disposal’. The above comments have clearly
demonstrated that the minerals infrastructure already in place (some of which have permanent
consent) are essential to meeting the objectively assessed need for mineral products over the
Plan period. Policy P13 should remove reference to limiting the life of ancillary activities to the
life of reserves in order to be positively prepared to manage forecasted demand for mineral
product. If there are clear exceptional circumstances, including objectively assessed need for
mineral development and mineral related product, these should not be life limited.

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14620

Received: 14/12/2020

Respondent: Tarmac Building Products Limited

Number of people: 2

Agent: Heaton Planning Limited

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The existing mineral development and associated infrastructure facilities contribute significantly to local, regional and national need. Although these facilities are safeguarded under Policy P13, their importance and role should be given elevated status and recognition within the Plan. The growth/development plans in Solihull and the West Midlands create such a substantial long-term need for aggregate and aggregate related products that the facilities will be required for the duration of the plan period. These are facilities already in situ and have been for a number of years. They are not new development further encroaching on the Green Belt.
The policy relating to safeguarding of mineral resource should cover the whole Plan area, rather than only the Mineral Safeguarding Areas designated on the policies map.
Policy P13 9 should not limit the life of ancillary activities to the life of reserves, as there are clear exceptional circumstances, including objectively assessed need for
mineral development/product.

Change suggested by respondent:

Although mineral development and associated infrastructure facilities are safeguarded under minerals policy, their importance and role should be given elevated status and recognition within the Plan.
The policy relating to safeguarding of mineral resource should cover the whole Plan area.
Remove reference to limiting the life of ancillary activities to the life of reserves in Policy P13 9

Full text:

Introduction and Background
Representations to the above consultation are made on behalf of our clients Tarmac Trading Limited and Tarmac Building Products Limited (Tarmac). Tarmac operate two Readymix (RMX) Plants and a Dry Silo Mortar (DSM) Plant situated off Cornets End Lane, Meriden. All Tarmac plants are strategically important for the supply of mineral product to serve local, regional and national construction needs.
Both RMX plants have permanent planning consent for their continued operation. Planning permission has recently been granted to replace one of the RMX plants to supply HS2. On completion of that contract, the RMX site will revert to serving local construction markets.
Dry silo mortar is a specialised construction material comprised of kiln dried materials and is supplied direct to market in sealed silos, which are typically transported by road. The materials (sand, cement, pigment and additives) at the plant are blended in accordance with each customer’s bespoke requirements. The DSM plant is of national strategic importance. The operation of the DSM plant is time limited to working of the adjacent Meriden Quarry site.
DSM is ideal for housing and commercial developments alike, particularly at larger sites which require larger mortar volumes produced under rigorous factory-controlled conditions. There is no need for onsite mixing given the requisite materials are already contained within a sealed silo
and the required volumes can be produced as and when necessary. This ensures consistency of
mortar colour for the whole construction project and helps to minimise waste caused by adverse
weather conditions when compared with other mortar products (it is mixed as and when
required as opposed to deliveries of wet mix to sites). Such is the specialist nature of the product
that there are understood to be only twenty DSM plants located within the entirety of the United
Kingdom. Tarmac operate five of these plants in the following locations:
• Colchester, Essex;
• Meriden, Solihull;
• Glasgow, Scotland;
• Leeds, West Yorkshire; and
• Croxden, Staffordshire.
In the last five years, sales of DSM have doubled whilst the number of sites has not increased
proportionately. Although aggregate workings generally have a defined market area, DSM plants
do not, owing to the specialist nature of the product and limited locations across the United
Kingdom. The result of this is that one site may supply a number of areas across different
administrative boundaries. For example, Tarmac’s Meriden site is of national importance forming
a key part of the DSM network, supplying customer needs in location as far as Kent, East Sussex,
West Sussex, Hampshire, Dorset, Devon, Cornwall, North and South Wales and East Anglia.
Tarmac supplies two of the top three UK housing developers, a key strategy is to maintain
continuity of supply to sustain and meet future demands for a growing national housing market.
Both the RMX and DSM plants are supplied by sand from the nearby Meriden Quarry and
Berkswell Quarry sites. In addition, sand is imported from Shireoak Quarry (Walsall) for blending
with sand from Meriden Quarry to make it suitable for the DSM process. Whilst fine sand is an
important mineral resource it is not suitable for use as an aggregate required for production of
ready mixed concrete. These quarries are used as they are a local resource, and they produce a
distinctive and popular colour to the mortar.
The Local Plan Consultation
All Tarmac plant sites situated at Cornets End Lane are within land designated on the emerging
Plan Policy map as ‘Mineral Safeguarding Areas’ and ‘Areas of Search for Waste Management
Facilities’. They are in proximity to land designated as ‘Preferred Areas for Minerals
Development’. This whole area is designated Green Belt.
Emerging Policy P17 (Countryside and Green Belt) seeks to retain land permanently open unless
very special circumstances have been demonstrated in accordance with the NPPF. Part 4 of the
policy identifies very special circumstances which may be considered when assessing proposals
for ‘inappropriate’ development. One of those very special circumstances for development is the
provision of waste management operations, providing that the development accords with the
waste management policy of the plan. Waste Management development is to be determined in
accordance with the requirements of Policy P12 (Resource Management).
Part 3 of Policy P12 identifies the strategy for waste provision and the sites preferred for waste
management and uses. The policy seeks to ensure that an equivalent tonnage is provided for
within waste management facilities to that arising within the Borough. To achieve this, a
sequential approach is proposed to determine the appropriate location for new waste
management facilities as follows:
i. On-site management
ii. Consolidation or expansion at strategic waste management sites
iii. Suitable industrial areas or sites allocated for industrial or employment uses
iv. Co-location of complementary waste management operations at Berkswell and
Meriden quarries
v. Area of Search for waste management facilities.
Part 5 to Policy P12 identifies strategically important waste management sites within the
Borough, where waste management activities will be supported in principle. These sites include
the site of the former Arden Brickworks in Bickenhill, which contains the household waste
recycling centre, and a range of other waste management operations, the materials recovery
facilities at Berkswell and Meriden Quarries, the composting facilities in Berkswell, and the Moat
Lane and Chapelhouse Depot waste transfer stations in the Mature Suburbs and North Solihull.
As identified above, these preferred areas for new waste management facilities are collocated
with mineral development at Berkswell and Meriden Quarries. Some of which have permanent
consent. The justification for allowing permanent forms of waste development that would go
against the principles of maintaining openness in the Green Belt is objectively assessed need for
waste capacity and the difficulty in finding suitable locations for such uses on land not designated
as Green Belt. In addition to proximity to demand/need, the highway network and the ability of
these areas to accommodate the traffic generated.
With consideration of potential/future waste facilities, the emphasis is on managing indigenous
requirements (equivalent tonnage within waste management facilities to that arising). It is
Tarmac’s view that objectively assessed need for mineral development and associated
infrastructure needs have been overlooked. The existing facilities contribute significantly to local,
regional and national need. This goes far beyond only the local requirements within the Borough
that are the necessary exception tests for new waste development. As a result the support and
retention of minerals associated development should hold equal weight if not greater weight
within these areas. The LAA (2015) identifies, ‘the main issue for local plans is to ensure that the
role of the existing network of manufacturing plants is recognised’ (paragraph 3.5.5 Heatons
emphasis). Although these facilities are safeguarded under minerals policy, their importance and
role should be given elevated status and recognition within the Plan.
Very special circumstances precedent has already been accepted/demonstrated in the case of
permanent waste management operations permitted adjacent to the Tarmac’s existing
operations. The early review of the Plan has been triggered by the need for Solihull to find land
to meet its own housing needs, as well as helping to address the housing shortfall occurring in
the wider Housing Market Area. The growth/development plans in Solihull and the West
Midlands create such a substantial long-term need for aggregate and aggregate related products
- that will, by virtue of the location of the Meriden sand and gravel Area of Search, involve mineral
extraction and associated infrastructure in the Green Belt for the duration of the plan period –
such that these considerations substantially outweigh the level of potential harm to the Green
Belt. Particularly as these are facilities already in situ and have been for a number of years. They
are not new development further encroaching on the Green Belt.
In view of the above comments, it is considered that the policy relating to Resource Management
(P12) and exceptions within the Green Belt (P17) is not an effective or positively prepared
strategy for managing mineral product supply over the Plan period. The policy should also give
due consideration to the need and support for the permanent retention of mineral infrastructure
to meet anticipated demand as well as maintaining existing supply. It is questioned whether this
area being retained as Green Belt is appropriate given the proximity to land being released to
accommodate large scale development, historic industrial activity as well as the long term
strategy for waste management/industrial uses being accepted in this area.
Policy P13 identifies, ‘Mineral Safeguarding Areas (MSAs) for sand and gravel aggregate
resources between Berkswell, Hampton and Meriden and east of the NEC and M42, including
sites for important associated infrastructure and to meet potential needs are defined on the
Policies Map’. As drafted Policy P13 is not in accordance with the NPPF. The NPPF paragraph
204c states that planning policies should safeguard mineral resources. The policy reads as though
safeguarding of mineral resource is only applicable to the above identified areas and shown
designated on the policies map. The approach to resource safeguarding should cover the whole
Plan area and the policy wording and associated mapping should not exclusively identify
resource in only one specific area.
Part 9 of Policy P13 states that, proposals for ancillary uses will be permitted where they are
located within the extraction site, are limited to the life of the permitted reserves and minimise
the impacts on environmental assets, transport infrastructure and surrounding occupiers and
uses. The Council will support proposals for complementary recycling facilities, which should be
as close as possible to the point of extraction or disposal’. The above comments have clearly
demonstrated that the minerals infrastructure already in place (some of which have permanent
consent) are essential to meeting the objectively assessed need for mineral products over the
Plan period. Policy P13 should remove reference to limiting the life of ancillary activities to the
life of reserves in order to be positively prepared to manage forecasted demand for mineral
product. If there are clear exceptional circumstances, including objectively assessed need for
mineral development and mineral related product, these should not be life limited.

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14672

Received: 10/12/2020

Respondent: Association of Black Country Authorities (ABCA)

Representation Summary:

SMBC approach generally supported and BC acknowledge that Solihull provides for over 90% of the recent-most Local Aggregate Assessment (LAA) production target for the Metropolitan Area. BC note SMBC that policy may need to be reviewed, but is should acknowledge that the review should consider increased demand.

Full text:

See Attached Document

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14699

Received: 14/12/2020

Respondent: IM Land - North of Main Road, Meriden

Agent: Stansgate Planning LLP

Representation Summary:

IM Land support removal of the Minerals Safeguarding Area from the Plan. The Minerals safeguarding topic paper accords with the case submitted on behalf of IM Land to the previous stages of the local plan preparation in that as Daw Mill Colliery from which coal was being extracted, has closed and there are no plans for working of the coal resource. It also concurs that alternative sources of energy are now sought to meet climate change targets. The minerals safeguarding area for coal is rightly no longer in the Plan.

Full text:

See attached Land North of Main Road, Meriden

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14704

Received: 14/12/2020

Respondent: Warwickshire County Council

Representation Summary:

In regard to Policies P12 (Resources) and P13 (Minerals) WCC is supportive of the policies which appear to be in conformity with national minerals and waste policy guidance.

Full text:

See Attached Document

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14742

Received: 14/12/2020

Respondent: Worcestershire County Council

Representation Summary:

WCC support the plan’s intention to aim for equivalent self-sufficiency for waste management development and to aim for the maintenance of a 7-year landbank for sand and gravel from identified areas.

Full text:

See Attached Document

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Representation ID: 14881

Received: 14/12/2020

Respondent: L&Q Estates - Land at Berkswell Road

Agent: Pegasus Group

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

The MSA boundary extends to the edge of the southernmost part of Meriden, encompassing our client’s site off Berkswell Road which is being promoted as an extension to the existing settlement. It is considered inappropriate to allocate a minerals safeguarding area which runs so close to the boundary of an existing settlement. It would not be appropriate for minerals extraction to operate so close to existing residential development, nor would it be appropriate to potentially sterilise land which could provide much needed housing growth in a sustainable location

Change suggested by respondent:

L&Q Estates object to the extent of the identified Minerals Safeguarding Area to the south of Meriden. This should be redrawn so that the boundary is away from the settlement to protect the amenity of the residents (in line with policy P14: Amenity) and to avoid sterilising sites which could provide sustainably located growth.

Full text:

LAND AT BERKSWELL ROAD, MERIDEN see attached documents