UPSVLP 0419
2.2.2
Reword the policy to plan positively: ?Development will only be permitted within the Manchester Airport 13km Safeguarding, where it would not adversely affect the operational integrity of the airport of the Manchester Radar. Also para 7.6.3 must recognise that minerals extraction need not be inappropriate development within an airport safeguarding area.
This policy and the supporting text in paragraph 7.6.3 appear to infer a blanket ban on mineral extraction within the 13km safeguarding of Manchester Airport or the Manchester Radar. Firstly the policy is not worded positively and secondly we object to this. We recognise the safety requirements associated with airports but the Safeguarding zones do not preclude mineral extraction.
7.6.3
We seek clarification that sandstone and clay reserves are now being safeguarding and trust the Council will avoid confusion between a minerals resource and a mineral reserve.
We note that Clay and Sandstone ?reserves? are not mapped as a resource, however, Figure 14 appears to include an element of clay and sandstone safeguarding which we support. It is important that the Council appreciates the difference between a ?reserve? and a ?resource?. We seek clarification on the evidence that the resources occur ?in isolated pockets; are of variable quality and thickness?. It is important that mineral resources are not unnecessarily sterilised.
9.3.1
We seek clarification as to whether or not the Council is or isn?t proposing to safeguard clay and sandstone resources. If the latter, we must maintain an objection as this approach does not accord with the NPPF and would render the plan unsound.
Figure 14 appears to include some element of mineral safeguarding for Sandstone and Clay at Southworth Quarry and Clay Pits.
Whilst we support the buffer zones, it is not clear if these represent the extent of the resource, or a zone simply drawn around the quarry. We reaffirm our need to ensure sandstone and clay resources.
It is unclear if the boundaries shown on Figure 14 represent mineral safeguarding areas or the buffer zones referred to in Table 9.
Table 9
Clarification sought.
We again question if the Council has considered identifying Areas of Search in order to address the recognised shortfall, given no new sites for Mineral extraction have been identified.
9.4.2
We suggest amending the wording to read ?The developer can provide evidence to support the need for extraction.?
We query the use of the word 'departure'. A proposal for mineral extraction outside of a mineral safeguarding area is not considered a ?departure? in land use planning terms.
2a
Reword this paragraph to reflect the PPG ?The NPPF introduced a requirement for MPAs to forecast the demand for aggregates through the preparation of an annual Local Aggregates Assessment (LAA) ?????????????.."
The PPG requires that LAAs must also include a forecast of the demand for aggregates. The wording should be amended to reflect the PPG.
9.4.5
Amend the wording to read ?National policy requires that a stock of permitted reserves of at least 25 years be provided?
The wording does not truly represent the wording of the NPPF which requires at least 25 years or brick clay reserves.
9.4.6
Amend the paragraph accordingly. These may include:
Other forms of development may be appropriate on former mineral sites, and this may include built development. It should be made clear that the list provided is not exclusive.
9.6.6
Support changes to this paragraph from previous wording.