Sites and Policies Plan Consultation Draft

Comment ID 8173345//2
Document Section Sites and Policies Plan Consultation Draft Living within Environmental Limits DM15 View all on this section
Respondent Deleted User View all by this respondent
Agent Steve Lamb
Response Date 19 Apr 2013



DM15 Minerals exploration, extraction and processing


Policy DM15: Reference is made in the text to measures being taken to minimise the waste of resources and that any waste generated is used for a productive purpose.

There must be recognition of economic viability in the minimisation of waste. In addition the requirement for "any" waste generated to be used for a productive purpose is both onerous and unrealistic. There will always be some waste that cannot sensibly or economically be used for a productive purpose.

Reference to "where economically viable" should be included.

Revised text for the policy is provided below:


Adequate measures must be taken to ensure minimum waste of resources during extraction and processing, and that any waste material generated is used for a productive purpose where economically viable, to the satisfaction of the council.


Policy DM15: The last paragraph in the text refers to companies with more than one site ensuring that activity is suitably integrated to ensure that sites are not left unworked and unrestored for long periods and that appropriate agreements may be sought.

There are strong objections to this text.

It is not clear what "suitably integrated" means.

It appears that North Somerset want more sites to be worked rather than fewer sites.

There are many reasons why sites may be worked to a greater or lesser extent at any one time, including the level of sales in the local area at a particular time, the type of material available, the plant and equipment at each site, agreements with landowners, etc.

The reasons are generally related to commercial aspects rather than planning matters.

If operators are forced to reopen sites they may be at an economic disadvantage and unable to compete in the market.

When planning permission was granted for each quarry site there was never any requirement for integration or phasing with other sites and just because one company controls more than one site it cannot be a necessity now.

This text implies that it is acceptable to leave sites unworked if they are operated by separate companies but not if a company operates more than one site.

The last paragraph should be deleted in its entirety.

Legal advice has been sought over the ability for North Somerset to seek to influence such matters.

Attached to this submission is a letter from Eversheds, solicitors acting for Lafarge Tarmac, which questions the legitimacy of a planning authority trying to control commercial activities and suggests that a Planning Inspector would find the policies unsound.