Sites and Policies Plan Consultation Draft

Comment ID 8173345//4
Document Section Sites and Policies Plan Consultation Draft Living within Environmental Limits DM17-18 View all on this section
Respondent Deleted User View all by this respondent
Agent Steve Lamb
Response Date 19 Apr 2013



DM17 Allocation of land at The Spinney, south of Stancombe Quarry, as a preferred area for minerals working.


Policy DM17: There are a number of bullet points listed in the text as requirements for the development of the Spinney.

The second bullet point requires the genuine need for the development to be demonstrated.

It is unclear what is meant by "genuine need".

An assessment of need during the Plan period has been carried out by North Somerset as part of the background evidence for the Sites and Policies Plan. It has been determined that there is a need for additional mineral reserves and the Spinney has been identified as the preferred location for the additional reserves.

It should also be recognised that there will be an ongoing need for minerals beyond the end of the Plan period in 2026.

Mineral sites are long term developments requiring substantial capital expenditure and it is important that sites are able to continue operating beyond 2026.

There should not be a requirement to demonstrate any further need.

Legal advice has also been sought over this matter and comments are provided in the attached letter from Eversheds.

In addition Tarmac has demonstrated in considerable detail to North Somerset why the Spinney development is needed in operational terms in order to allow the full release of the consented mineral at Stancombe, some of this information is included in the Evidence Paper Minerals.

The second bullet point should be deleted in its entirety.


DM18 Identification of Minerals Safeguarding Area for carboniferous limestone


Policy DM18: The aim of safeguarding is to prevent incompatible development on the safeguarded area.

An area has been proposed for safeguarding which includes Stancombe Quarry and Freemans Farm Quarry although it is not clear why these consented quarry areas have been included in the safeguarding area if they are already protected by policy DM16.

Similarly, if these consented quarry areas are to be included in policy DM18, then the consented area at Durnford Quarry should also be included in this policy.

The safeguarding area as proposed does not include land to the west of Backwell Hill Road, namely Hyatts Wood Quarry, which has been extracted for limestone in the past.

Hyatts Wood Quarry and the land to the immediate north of the quarry contain extensive high quality carboniferous limestone resources which should be safeguarded.

The attached plan (Hyatts Wood Quarry) shows the extent of the area which should be included in the safeguarding area.

In addition the safeguarding area does not include the full extent of the limestone resource at Hyatts Wood Farm (east of Backwell Hill Road) and consequently the safeguarding area should be extended towards the south.

The area of Hyatts Wood Farm limestone resource is shown outlined in red on the attached plan (Hyatts Wood Farm).

Furthermore a 500 metre buffer should be included around the safeguarding area to prevent incompatible non-mineral developments from impairing the potential exploitation of minerals in the future (referred to previously under Policy DM16).

The text refers to prior extraction of minerals being encouraged in advance of non-mineral development.

It is acknowledged that the principle of prior extraction appears sensible however it is not practical where limestone deposits are often well over 100 metres thick.

How can any real depth of mineral be extracted in advance of non-mineral development? In addition the timescales for limestone extraction are similarly prohibitive.

Instead there should be a greater emphasis on assessing whether any non-mineral development would impact on potential future limestone extraction and if so to refuse the development.