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6. Minerals Delivery Strategy

Minerals in Central and Eastern Berkshire

6.1 Until the 20th Century, chalk and clay were the main minerals produced in the area, generally to meet local needs. Chalk and clay continue to be extracted as a by-product at sand and gravel quarries, but now on a very small scale in comparison to previous times.

6.2 The chalk is now mainly used as agricultural lime, and sometimes as ‘fill’ material for civil engineering projects. The clay was formerly used chiefly for brick and tile making, but more recently its main use has been for the lining for waste landfill sites to prevent the spread of pollution and for other engineering applications.

6.3 Since the Second World War, the main type of minerals production in Berkshire has been of aggregates for the construction industry, the bed rock for future development. Construction aggregates are hard granular materials and in the context of the extraction industry of Central and Eastern Berkshire comprise sands and gravels.

6.4 The geology of Berkshire determines where these deposits are available for extraction. Further supplies of aggregate are imported from elsewhere in southern England or obtained by recycling of construction and demolition waste. Most aggregate is processed by the operator, either on-site or at central processing facility nearby and sold direct for use in the construction industry.

6.5 This section sets out the policies relating to the following issues:

  • Managing the supply of aggregate;
  • Safeguarding minerals resources, and minerals infrastructure;
  • The locations for extraction; and
  • Provision of non-aggregate minerals.

6.6 All policies include an explanation of the existing situation, supporting text regarding the policy and details on how the policy would be implemented and monitored.

Sustainable mineral strategy

6.7 Minerals make a significant contribution to the nation’s prosperity and quality of life and are needed to build and maintain local communities.

6.8 The supply of minerals to Central and Eastern Berkshire comprises imports of crushed rock, marine-won and land-won sand and gravel, recycled aggregate as well as locally won sand and gravel.

6.9 Data on the consumption of aggregates (the types of mineral used by the construction industry) as well as the movements of aggregates (imports and exports) is recorded on a Berkshire-wide level rather than by each mineral planning authority. This data is published by the Ministry of Housing, Communities and Local Government (MHCLG) every four years as part of the Aggregate Mineral survey for England and Wales undertaken by the British Geological Survey (BGS)63.

Table 1: Total consumption of Primary Aggregate in Berkshire, 2009 and 2014

Berkshire
Land Won Sand and Gravel

Marine Sand and Gravel Total sand and gravel Crushed Rock Total Primary Aggregates
2009 2014 2009 2014 2009 2014 2009 2014 2009 2014
298 353 98 152 396 505 861 1,161 1257 1,666
Consumption* (Tt) 807 601 98 152 905 753 875 1,161 1780 1,914
Consumption % 45.3% 31% 5.5% 8% 50.8% 39% 42.9% 61% 100% 100%
Imports/ Consumption % 36.93% 58.7% 100% 100% 43.76 67% 98.4% 100 71% 87%

Source: Collation of the results of the 2009 and 2014 Aggregate Minerals survey for England & Wales.
* Consumption is determined by total sold internally plus total imported.

6.10 Table 1 shows the consumption of aggregate both imported and from external areas and supplied from sources within Berkshire. Unfortunately, comparable data is not available for 2005.

6.11 In 2014, Berkshire was producing 1051 Thousand tonnes (Tt) with sales split by 248 Tt sold internally within Berkshire. A further 548 Tt was sold in the South East region, the principal destinations being Surrey and Buckinghamshire (including Milton Keynes) and 255 Tt sold to locations elsewhere (predominately West London).

6.12 There is no marine-won sand and gravel produced within Berkshire as it is land locked nor is there any crushed rock due to geological constraints and therefore, these aggregates are imported into the Plan area. In 2014, Berkshire was also importing 353 Tt of land-won sand and gravel.

6.13 Although it is not possible to determine the amount of these imports that reach Central and Eastern Berkshire, the movements need to be taken into consideration when forecasting future demand.

6.14 Table 1 also shows an overall increase in supply of primary aggregates from sources within Berkshire during this period. The Table does however show that there is an increasing reliance on Primary Aggregate imports within Berkshire.

6.15 Soft sand is found in Central and Eastern Berkshire within the Reading Formation, a bedrock deposit which is predominately clay bearing but also contains sand beds and therefore, the deposits are variable in terms of quality and location. As a result, reliable information about the distribution of commercial reserves of soft sand is not available. This situation reflects the fact that there have been no operational soft sand quarries in over 10 years and only a small level of incidental extraction.

6.16 Soft sand supply in the South East is recognised as an issue by the South East England Aggregate Working Party (SEEAWP). The Mineral Planning Authorities in the South East worked collectively to prepare a Position Statement which provides an agreed source of evidence and current policy on soft sand supply in the South East. The Position Statement will underpin effective cooperation and collaboration between the Minerals Planning Authorities of the South East of England in addressing the strategic cross-boundary matter of soft sand supply.

6.17 Soft sand is currently being supplied to Central and Eastern Berkshire by mineral planning authorities outside of the Plan area. A Soft Sand Study64 has been prepared to explore the options for supply in the short and longer-term. The Study outlines those areas currently supplying the Plan area and those that have potential to supply in the future. The Study concludes that Central and Eastern Berkshire is in an enviable position as it has a number of supply sources and therefore, is not dependent on any single area.

6.18 Demand for soft sand in Central and Eastern Berkshire during the Plan period could be in the region of 1.0 million tonnes (0.065 million tonnes per annum)65.

6.19 Recycled and secondary aggregates can be used as a substitute for some land-won sharp sand and gravel extraction, providing a more sustainable source of supply. These have combined benefits of reducing the need for land won (or marine aggregate) and reducing the amount of waste requiring disposal by landfill.

6.20 When used locally, recycled aggregate can reduce the impact of transport and cut carbon emissions.

6.21 There is no reliable or comprehensive data on the production or use of recycled aggregates. Historically, the production and sales of recycled and secondary aggregate have been recorded on a Berkshire county-wide level. However, sales data for Central and Eastern Berkshire has been recorded since 2014. Sales of recycled and secondary aggregate in Berkshire during this period suggest an overall increase in sales but with a spike in sales in 2016 (see Table 2). Similarly, the wider South East has seen an overall increase but with a spike in 2017. In comparison, Central and Eastern Berkshire has seen a steady increase in sales.

Table 2: Sales of recycled and secondary aggregate in the Central and Eastern Berkshire, Berkshire, and the South East (thousand tonnes)

Year Central & Eastern Berkshire Berkshire
Sales
South East
2014 85 408 3,628
2015 103 400 4,223
2016 128 498 4,034
2017 131 451 4,875
2018 138 459 4,581
5 Year Average 132 443 4,268

Source: Aggregate Monitoring survey data and South East Aggregate Monitoring Report66

6.22 There are no known commercial resources of oil and gas in Central and Eastern Berkshire. Whilst there is coal present within the Plan area, this resource is not currently prospective for exploitation.

6.23 Both chalk and clay are not currently being extracted for an industrial purpose.

6.24 There are several options available to Central and Eastern Berkshire to supply the Plan area with minerals and there is a need for this to be supported to allow for flexibility in demand and changes in market. Therefore, the Central & Central & Eastern Berkshire: Joint Minerals & Waste Plan 71
Eastern Berkshire Authorities will plan to facilitate minerals of the right type, in the right place and at the right time.

Policy M1
Sustainable minerals development strategy

The long term aims of the Plan are to provide and/or facilitate a steady and adequate supply of minerals to meet the needs of Central and Eastern Berkshire in accordance with all of the following principles:

  1. Work with relevant minerals planning authorities to maintain the supply of aggregate not available within Central and Eastern Berkshire;
  2. Deliver and/or facilitate the identified aggregate demand requirements (Policy M3);
  3. Facilitate the supply of other mineral to meet local demands (Policy M6);
  4. Be compliant with the spatial strategy for minerals development (Policy M4); and
  5. Take account of wider Local Plans and development strategies for Central and Eastern Berkshire.

Implementation

6.25 The Central & Eastern Berkshire Authorities will work jointly to maintain the supply of minerals that serve the wider Plan area. They will also work closely with relevant mineral planning authorities to plan for the provision of aggregates from outside of the Plan area that supply Central and Eastern Berkshire. This will be established through Statements of Common Ground. Aggregate that is not available to Central and Eastern Berkshire includes those not geologically present such as hard rock and those that cannot be sourced from within the Plan area due to constraints on supply. The constraints on supply will be explored within the Statements of Common Ground and monitored through the Local Aggregate Assessment (see Policy M3).

6.26 Statements of Common Ground will be regularly reviewed through the ‘duty to cooperate’ to ensure the issues outlined are still relevant.

6.27 The spatial strategy for minerals development is outlined in Policy M4 which includes allocated sites and locational criteria for new aggregate provision.

6.28 The Joint Minerals & Waste Plan needs to enable minerals and waste development that complements the delivery of the strategies outlined in the wider Local Plans and vice versa.

Monitoring

6.29 Monitoring Indicators:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review

Effective engagement with relevant mineral planning authorities.

Up-to-date Statement of Common Ground and annual ‘duty to cooperate’ (reported in the Local Aggregate Assessment).
n/a

Safeguarding Mineral Resources

6.30 Minerals are a valuable but finite resource that can only be won where they naturally occur. Safeguarding of viable or potentially viable mineral deposits from sterilisation by surface development is an important component of sustainable development. Safeguarding means taking a long-term view to ensure that sufficient resources will be available for future generations, and importantly, options remain open about where future mineral extraction might take place with the least environmental impact. National planning policy67 is that planning authorities should safeguard mineral deposits that are of local or national importance against non-minerals development by defining Mineral Safeguarding Areas (MSAs) in their plans and not normally permit development in Mineral Safeguarding Areas if it constrains their potential future use68.

6.31 Minerals of local and national importance will be safeguarded and defined by the Mineral Safeguarding Area (MSA). This safeguarding will be achieved by encouraging extraction of the underlying minerals prior to development proceeding, where practicable, if it is necessary for the development to take place within the MSA.

6.32 In Central and Eastern Berkshire, clay and chalk are only extracted for local needs and not for industrial purposes. Neighbouring planning areas have not raised a shortfall in provision of clay and chalk and therefore, the minerals are not considered of sufficient importance to warrant safeguarding. The key mineral deposit in Central and Eastern Berkshire is sand and gravel. The deposits of sand and gravel, although widespread, are relatively shallow, and the material can be processed away from the site, where required. The location of sand and gravel often closely coincides with existing settlement patterns. As such, there is a strong potential for new surface development to be proposed on or close to these important mineral deposits.

6.33 For these reasons, it is particularly important to have a firm framework for the safeguarding of sand and gravel resources which are or could be of potential importance.

6.34 The geological deposits in which soft sand is found are much more variable than deposits of sharp sand and gravel. As a result, information about the distribution of commercial reserves of soft sand is not available.

6.35 Neighbouring areas which contain soft sand resources include West Berkshire, Hampshire, Surrey, Buckinghamshire and Oxfordshire. There are also soft sand resources within the wider South East, most notably Kent and West Sussex. However, several authorities have a significant proportion of their soft sand resources located within Areas of Outstanding Natural Beauty (West Berkshire and Surrey) or within the South Downs National Park (Hampshire and West Sussex).

6.36 The presence of such designations restricts the availability of soft sand resources in these areas. As such, soft sand supply issues may occur in the near future, in particular in the wider region (West Berkshire, Hampshire, Surrey and West Sussex) as resources outside of the designated areas deplete.

6.37 Central and Eastern Berkshire is already dependent on soft sand supplies from outside of the Plan area. Therefore, securing future supplies may become more of an issue as other mineral planning authority areas seek to source their supplies from elsewhere (outside of designated areas). As such, it is considered that deposits of soft sand where they are identified, are also safeguarded.

6.38 It is important to note that there is no automatic presumption that planning permission for the winning and working of sand and gravel will be granted in MSAs

Policy M2
Safeguarding sand and gravel resources
  1. Sharp sand and gravel and soft sand resources of economic importance, and around active mineral workings, are safeguarded against unnecessary sterilisation by non-minerals development.
  2. Safeguarded mineral resources are defined by the Minerals Safeguarding Area illustrated on the Policies Map.
  3. Non-minerals development in the Minerals Safeguarding Area may be permitted if it can be demonstrated through the preparation of a Mineral Resources Assessment, that the option of prior extraction has been fully considered as part of an application, and:
    1. Prior extraction, where practical and environmentally feasible, is maximised, taking into account site constraints and phasing of development; or
    2. It can be demonstrated that the mineral resources will not be permanently sterilised; or
    3. It would be inappropriate to extract mineral resources in that location, with regard to other policies in the wider Local Plans.

Implementation

6.39 The extent of MSA will be based on information about aggregate sand and gravel resources from the British Geological Survey and other sources of geological information, plus existing mineral working permissions and the nature and duration of any such operations. In some instances, the MSAs will apply to sand and gravel deposits beneath existing built up urban areas. This ensures sand and gravel deposits and the possibility for prior extraction is taken into account when proposals for large scale redevelopment are considered. The broad extent of sand and gravel resources to which the MSA will apply are shown on the Key Diagram and Policies Map.

6.40 In assessing development proposals within the MSA, the Central & Eastern Berkshire Authorities will have regard, amongst other things, to the size and nature of the proposed development, the availability of alternative locations and the need for phasing of the proposed development. Account will also be taken of the quantity and quality of the sand and gravel that could be recovered by prior extraction and the practicality and environmental impacts of doing so. A minimum plot size of 3 hectares69 will apply in the safeguarding process to avoid repeated consideration of prior extraction where this can be assumed to be uneconomic, due to the small size of the parcels of land involved. However, applications will be monitored to ensure a piecemeal approach is not taken which could accumulate to have an impact on resources.

6.41 Developers are responsible for preparing a Mineral Resource Assessment which will need to assess the actual or potential commercial value of the underlying mineral deposit. The developer should determine the type, depth and quality of sand and gravel deposits within the site. In order to demonstrate that prior extraction has been fully considered, the developer must undertake an assessment of the practicality of prior extraction, either for use in the development itself or elsewhere.

6.42 In reviewing the potential for prior extraction developers should consider whether the extraction of part of the sand and gravel deposit within the site can be undertaken, even if removal of the entire deposit appears impractical. This might apply, for example, in a case – perhaps on a site close to land liable to flood where the removal of the upper levels of the deposit could be undertaken, whereas the removal of the entire deposit would render the land unsuitable without the importation of inert material to raise the ground level above flood levels.

6.43 In considering proposals for prior extraction, it will also be important to ensure that the environmental impacts of the development are contained. In most cases, the shallowness of the layers of sand and gravel means it can be extracted without blasting. As a result, it is unlikely that the extraction operation will give rise to additional environmental effects, over and above those of the development operation itself, that would preclude prior extraction.

6.44 Safeguarding does not necessarily mean that other forms of development should not take place where sand and gravel deposits occur. However, developers will need to demonstrate, through the preparation of a Mineral Resource Assessment, that the sand and gravel deposit has no commercial value, or that they have fully explored the use of the underlying sand and gravel in preparing development proposals. Alternatively, the policy includes provision for temporary developments and can allow specific projects of demonstrable overriding importance in the Central & Eastern Berkshire Authorities’ Local Plans to proceed.

6.45 It is expected that, as a minimum requirement, incidental recovery of sand and gravel as part of a non-mineral development will take place.

6.46 The Central & Eastern Berkshire Authorities have produced a Minerals Consultation Area in line with National Planning Guidance70 which will be used to determine whether they need to consult a neighbouring Mineral Planning Authority or each other on an application which could impact mineral resources or supply.

6.47 A list of safeguarded sites (operational and planned) is outlined in Appendix E and will be maintained by the Central & Eastern Berkshire Authorities. This will be updated as permissions are granted, and sites are completed and no longer require safeguarding.

Monitoring

6.48 Monitoring Indicator:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review

Mineral Safeguarding

Area (Hectares) of safeguarded resource sterilised by non-minerals development not subject to prior extraction.
Year on year increase over 5 years.
Amount of sand and gravel (including soft sand) extracted through prior extraction in tonnes per annum. No increase over 5 years.

Managing the supply of aggregate

6.49 The requirement under national planning policy71 is that minerals policies should make provision for ensuring a steady and adequate supply of aggregates for the construction industry and wider economy by means of maintaining a ‘landbank’.

Local Aggregate Assessment

6.50 The Local Aggregate Assessment (LAA) reviews the demand and supply of aggregate in the area and is reported annually. The LAA contains:

  • A forecast of demand for aggregates based on the rolling average of 10-years sales and other relevant local information. The 3-years sales data should also be reviewed as this may indicate an increase in future supply;
  • Analysis of all supply options including land-won, marine-won (dredged) and recycled or secondary aggregate. Imports and exports of aggregate also need to be considered;
  • An assessment of the local issues that may influence the situation such as environmental constraints or economic growth.
  • If there is considered to be a shortage in supply, the conclusions need to outline how this is to be addressed.

Landbank

6.51 A landbank is a stock of mineral planning permissions which together allow sufficient minerals to be extracted to meet a defined period at a given rate of supply. The landbank is recalculated each year and is then reported in the LAA.

6.52 Landbanks are used as a monitoring tool by Mineral Planning Authorities to forecast whether a steady and adequate supply of aggregate can be maintained in their Plan area. If the landbank cannot be maintained, this can act as a trigger to highlight to the Mineral Planning Authorities that the existing sites are not sufficient and therefore, new permissions are required.

6.53 National planning policy72 also requires mineral planning authorities to make provision for the maintenance of a landbank of at least seven years for sand and gravel. Reserves of sand and gravel in Central and Eastern Berkshire with planning permission for extraction (permitted reserves) at 31st December 2018 were 6.053 Million tonnes (Mt).

6.54 Star Works Quarry in Wokingham Borough had a remaining soft sand reserve at the end of December 2018. However, the inactive quarry will require approval of working conditions before any extraction can proceed, and therefore it cannot be included in the total permitted reserves.

6.55 Total permitted reserves are therefore 5.857 Mt (discounting Star Works Quarry). The Central and Eastern Berkshire – Local Aggregate Assessment for the period 2018, determined the LAA Rate as 0.628 Mt73. This LAA Rate has been applied as the Plan Provision rate as it has been robustly justified74 and agreed by the SEEAWP. Application of the LAA Rate results in a landbank of 9.3 years.

6.56 The Plan period is up to 2036. If the LAA rate is projected forward from 2018 to 2036 a total of 11.304 Mt of sharp sand and gravel would be required over the course of the Plan. Taking into account that current permitted reserves for Central and Eastern Berkshire are 5.857 Mt (not including Star Works Quarry). This means that there is a total requirement of 5.447 Mt of sharp sand and gravel (0.628 Mt per annum).

6.57 A change in local circumstances will have an impact on demand and therefore, the landbank. The proposed Heathrow airport expansion, subject to ongoing legal challenges and consultations, is such an example which would create a local increase in demand for aggregate. However, there is currently a significant level of uncertainty over the proposals for the Heathrow airport expansion with regard to timings and construction methods which would influence demand.

6.58 It is accepted that the provision rate may change over the Plan period in order to maintain the landbank and a steady and adequate supply of aggregate. This will be monitored through the Local Aggregate Assessment and reviewed within three years, where necessary. If sufficient sand and gravel is not provided within the Plan area, there will be a reliance on imports from other Mineral Planning Authority areas until such time development is delivered within Central and Eastern Berkshire. Imports will be regularly monitored. Taking into account existing reserves, the permitted throughput of these sites and the proposed allocations, it is anticipated, that there will be a remaining requirement for sand and gravel to be delivered from outside of the Plan area throughout the Plan period at the following rates75:

  • 0.228 Mt at 2026;
  • 0.378 Mt at 2031; and
  • 0.628 Mt at 2036.

6.59 Soft sand and crushed rock are provided from outside of the Plan area and the continuation of this supply will be enabled in cooperation with other Mineral Planning Authorities (as outlined in Policy M1).

6.60 Due to geological constraints, the supply of crushed rock over the Plan period will all be met from outside the Plan area, most notably Somerset. The security of supply is established through Local Aggregate Assessments76.

Policy M3
Sand and gravel supply
  1. Provision will be made for the release of land to allow a steady and adequate supply of sand and gravel for aggregate purposes in Central and Eastern Berkshire at an average rate of 0.628 million tonnes a year to 2036, subject to the impact of local circumstances on demand.
  2. A landbank of permitted reserves for the winning and working of sharp sand and gravel sufficient for at least 7 years’ supply will be maintained through the Plan period.

Implementation

6.61 The policy seeks to ensure a steady and adequate supply of sand and gravel during the Plan period and maintain at least 7 years of permitted reserves.

6.62 Annual monitoring will be undertaken by the Central & Eastern Berkshire Authorities and reported in the Local Aggregate Assessment to ensure that, if required, permissions can be granted for mineral extraction before the landbank falls below 7 years.

6.63 It should be noted that the mineral extraction sites have been identified as locations where planning permission is most likely to be granted to maintain the landbank and where policies to ensure extraction in these locations and others, likely to come forward during the course of the Plan, do not have a significant impact. However, the Central & Eastern Berkshire Authorities cannot dictate that acceptable applications are submitted, and the required level of production is maintained.

6.64 It is recognised that the landbank can only be maintained if industry comes forward with planning applications in acceptable locations. The implementation of Policy M3 is therefore, reliant on the aggregate industry as well as the Central & Eastern Berkshire Authorities as the relevant Minerals Planning Authority.

6.65 Soft sand supplies that arise within the Plan area, will be addressed by Policy M4.

6.66 The effectiveness of the policy will need to be carefully monitored through the Local Aggregate Assessment including import levels to ensure that changes in local circumstances are reflected in any future provision rate. Local circumstances include issues specific to the Plan area which may impact either demand or supply such as a major infrastructure project or delivery constraints associated with quarries or minerals infrastructure supplying Central and Eastern Berkshire. However, it should also be recognised that these changes maybe time-limited due to their association with specific large-scale infrastructure projects such as the proposed Heathrow airport expansion, rather than a long-term trend.

Monitoring

6.67 Monitoring Indicators:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review

Steady and Adequate Supply

Sand and gravel sales fail to achieve provision rate. Breach over 3 consecutive years.
Sand and gravel sales exceed provision rate. Increasing trend in sales (above provision rate) over 3 consecutive years.
Landbank falls below 7 years of permitted reserves. Breach over 3 consecutive years.
Imports of sand and gravel increase. Increasing trend over Plan period.

Locations for sand and gravel extraction

6.68 There are a number of existing sites which currently extract sharp sand and gravel. There are no soft sand sites but there has been incidental soft sand extraction and a former soft sand quarry which has not been operational for a number of years. These sites have a role in the supply of sand and gravel during the Plan period.

6.69 Star Works is inactive but retains approved soft sand reserves. The site now forms a landfill which is due to close in the near future and there are no current plans to extract the remaining reserves. Waste uses continue to operate on other parts of the site.

6.70 There is a requirement to provide an additional 5.447 Mt of sharp sand and gravel (0.628 Mt per annum) during the Plan period. As such, there is a need to identify sites for local land-won aggregate.

6.71 The new sites identified in Policy M4 have been nominated by industry and have been assessed to be appropriate for development subject to the relevant development considerations outlined in Appendix A. The allocations seek to provide 0.4 Mt in terms of contribution to supply.

6.72 The exact timings of sites coming forward will depend on the market conditions, extraction rates at existing sites and planning permission being granted. However, it is anticipated that the allocations are likely to be delivered at the following points within the Plan period, subject to planning permission being granted:

  • Horton Brook & Poyle Quarry Extension, Horton (MA1) – from 2024+;
  • Poyle Quarry Extensions, Horton (MA2) – from 2024+.

6.73 Despite new site allocations and the existing reserves, the permitted throughputs of these sites means that the ability to provide 0.628 Mt per year will cease from 2023 and there will be a shortfall in supply for the remainder of the Plan period77. This shortfall amounts to 2.5 Mt. The aggregate industry has not identified sufficient sites to plug this gap at present. The minerals industry is market-led, and it is recognised that there is likely to be a need for future requirements, particularly considering major infrastructure projects in the area such as the proposed Heathrow airport expansion.

6.74 In order to provide flexibility in supply and to allow industry to bring forward appropriate sites, Policy M4 (3) outlines a contingency criteria-based approach to ensure that the landbank is maintained and therefore a steady and adequate supply. Sites will be expected to come forward within the Area of Search for sand and gravel which demonstrates the potential resource in the Plan area. This approach is supported by a Statement of Common Ground with neighbouring mineral planning authorities as outlined in Policy M1. Preferred Areas cannot be provided due to the lack of evidence, and it is considered that this may limit the potential for proposals to come forward across the Plan area.

Policy M4
Locations for sand and gravel extraction

A steady and adequate supply of locally extracted sand and gravel will be provided by:

  1. The extraction of remaining reserves at the following permitted sites:
    1. Horton Brook Quarry, Horton
    2. Riding Court Farm, Datchet
    3. Sheephouse Farm, Maidenhead
    4. Poyle Quarry, Horton
    5. Water Oakley, Holyport
  2. Extensions to the following existing sites, provided the proposals address the relevant development considerations outlined in Appendix A:
    1. Horton Brook & Poyle Quarry, Horton (MA1) – 0.15 Mt
    2. Poyle Quarry, Horton (MA 2) – 0.25 Mt
  3. Proposals for new sites not outlined in Policy M4 (1 and 2) will be supported, in appropriate locations which comply with all relevant policies in the Plan, where:
    1. They are situated within the Area of Search (as shown on the Policies Map); and
    2. They are needed to maintain the landbank; and/or
    3. Maximise opportunities of existing infrastructure and available resources; or
    4. At least one of the following applies:
      1. The site contains soft sand;
      2. The resources would otherwise be sterilised; or
      3. The proposal is for a specific local requirement.

Implementation

6.75 The allocation of sites does not convey that planning permission will be automatically granted but indicates the locations that could provide sustainable development subject to the development considerations being addressed (see Appendix A).

6.76 The Area of Search is shown on the Policies Map. The Area of Search78 is based on the presence of soft sand, sharp sand and gravel resources but excludes designations (including SPAs, SACs, Ramsar sites, SSSIs, Ancient Woodland, Listed Buildings and Conservation Areas, Scheduled Monuments, Historic Parks and Gardens, and Registered Battlefields) which are identified in the NPPF as areas that should be avoided for development to be sustainable. The settings of designations could not be excluded as these are not clearly defined. However, built up areas and those areas of remaining resource of less than 3 hectares was excluded as being unlikely to be viable79.

6.77 It is recognised that the Area of Search will change as land uses change and new designations are made or amended. However, the application of the criteria (the presence of sand and gravel resources and the exclusion of designations, built up areas and any remaining areas of resource less than 3 ha) will remain constant and will determine the extent of the Area of Search. Sites identified within the Area of Search will still be subject to planning permission.

6.78 Proposals for new sites will be supported where they are in ‘appropriate locations’ and therefore, comply with all relevant policies within this Plan and M4 (4a, b or c).

6.79 Minerals extraction is not considered inappropriate in Green Belt locations subject to certain provisions (see DM6).

6.80 Landbanks can be used as an indicator for whether additional provision needs to be made for new aggregate extraction. Applications for the extraction of sand and gravel will not necessarily be refused if the landbank stands at over 7 years. National planning policy80 states that provision should be made to maintain the landbank at ‘at least’ 7 years for sand and gravel. However, consideration should also be given to the productivity of existing sites and the need to ensure that large landbanks are not bound to only a few sites which could lead to the stifling of competition.

6.81 Conversely if the overall landbank of aggregates at the time of an application for mineral extraction stands at less than 7 years, this does not mean that an application will inevitably be approved. Government guidance confirms that landbank policies do not remove the discretion of Mineral Planning Authorities to refuse applications which are judged to have overriding objections. Whilst Mineral Planning Authorities should use the size of the landbank as an indicator for when new permissions for extraction of aggregates are likely to be needed, consideration should be given to other allocations and policies in the Plan.

6.82 The acceptability of extending existing quarries will be assessed on a case-by-case basis and will include the assessment of cumulative impacts which may be associated with continued working and other economic considerations such as market areas.

6.83 The performance of operators will be a material consideration in decision-making as outlined in Policy DM15.

6.84 Due to the variable nature of soft sand deposits in the Plan area, where suitable resources are identified in appropriate locations, these should be exploited to supplement supply, provided that the development is undertaken in accordance with the relevant Development Management policies.

6.85 Opportunities for prior extraction should be fully considered as part of an application for non-minerals development within the Minerals and Waste Safeguarding Area in accordance with Policy M2.

6.86 A ‘specific local requirement’ as referenced in M4(3)(diii) is defined as a project within Central and Eastern Berkshire or a neighbouring planning authority area and may include beneficial uses where the primary purpose for its extraction is not for the mineral and it takes place to support other non-mineral developments in a given location e.g. creation of agricultural reservoirs, recreational lakes or borrow pits for a special localised need.

6.87 Although borrow pits are not generally supported, there are some circumstances where they are the only sustainable way of providing aggregates for another planned local development project such as the construction of new roads or major built development. This is particularly likely to be the case where a borrow pit would minimise the potential impacts on local communities and the environment. Borrow pits can help to safeguard resources of higher-grade material for primary uses. Proposals for borrow pits will only be permitted where there is a clearly identified need, where the aggregate extracted is for use only within the specific construction projects in which it is related to, and the site is located on land surrounding the construction project, within a ‘corridor of disturbance’ which would be determined on a case-by-case basis.

6.88 Significant infrastructure projects, such as the Heathrow airport expansion proposal, are likely to require borrow pits. Where these sites are already identified in the Joint Minerals & Waste Plan the development considerations should be taken into consideration in the delivery of the Nationally Significant Infrastructure Project.

Monitoring

6.89 Monitoring Indicators:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review

Sand and gravel supply

Landbank falls below 7 years of permitted reserves. Breach over 3 consecutive years.

Supply of recycled and secondary aggregates

6.90 Recycled aggregates are those derived from construction, demolition and excavation activities that have been reprocessed to provide materials or a product suitable for use within the construction industry. It includes materials such as soils and subsoil, concrete, brick or asphalt for re-use that would otherwise be disposed. On the other hand, secondary aggregates are usually by-products of other construction or industrial processes. For example, Incinerator Bottom Ash (IBA) at energy recovery facilities is a by-product of the incineration process that can be processed into a secondary aggregate for road construction. Other secondary aggregates include spent railway ballast, recycled glass, plastics and rubber (tyres).

6.91 Highway maintenance work has the potential to comprise a relatively large source of recycled aggregate through recycled road planings, asphalt, concrete kerbs and soils.

6.92 A significant amount of recycled and secondary aggregate is processed on development and construction sites, but an increasingly large amount is processed at free standing sites or sites located within existing minerals and waste activities such as mineral extraction, waste transfer, materials recovery and landfilling.

6.93 No secondary aggregate is produced within Central and Eastern Berkshire.

6.94 National policy requires the ‘contribution that substitute or secondary and recycled materials and minerals waste would make to the supply of materials, before considering extraction of primary materials whilst aiming to source minerals supplies indigenously’81. The Central & Eastern Berkshire Authorities do not control how much aggregate is recycled but can enable and encourage recycling facilities to meet demand.

6.95 Given the urbanised nature of much of Central and Eastern Berkshire and the development required as part of future development plans, the main source of non-primary aggregates will be recycled aggregates. It will therefore be important that adequate recycling facilities are available to enable aggregates to be recovered from construction and demolition waste.

6.96 It is estimated that, based on operator returns to the Aggregate Monitoring survey and Environment Agency permits, the recycling capacity for aggregate in 2018 was 0.39 Million tonnes (Mt). However, due to the temporary nature of the operations and the reality of operations taking place at the sites, the capacity is likely to be more in the region of 0.05 Mt. The operations will be safeguarded (see Policy M8) and the capacity should be considered as a minimum to be maintained.

Policy M5
Supply of recycled and secondary aggregates
  1. Recycled and secondary aggregate production will be supported, in appropriate locations which comply with all relevant policies in the Plan, to encourage investment in new and existing infrastructure to maximise the availability of alternatives to local land-won sand and gravel.
  2. The supply of recycled aggregate will be provided by maintaining a minimum of 0.05 million tonnes per annum.

Implementation

6.97 Proposals for new sites will be supported where they are in ‘appropriate locations’ and therefore, comply with all relevant policies within this Plan and W4 (2).

6.98 Recycling capacity can be provided by mobile plant operating on construction sites, but further permanent facilities will be necessary to increase the capacity baseline.

Monitoring

6.99 Monitoring Indicators:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review
Aggregate recycling capacity
Aggregate production capacity reduced by more than 5000 tonnes or 10% whichever is greater.
Breach over 2 consecutive years.

Energy minerals

Oil and Gas

6.100 Oil and gas are nationally important mineral resources and it is government policy that exploration should be supported, and resources exploited subject to environmental considerations.

6.101 Oil and gas resources (known as ‘hydrocarbons’) are classed as either ‘conventional’ or ‘unconventional’. Conventional resources are situated in relatively porous sandstone or limestone rock formations. Unconventional sources are found where oil and gas has become trapped within a non-traditional reservoir such as shale rock and as such will require non-traditional methods of extraction.

6.102 As shale is less permeable (or easily penetrated by liquids or gases), it requires a lot more effort to extract the hydrocarbons from the rock. However, recent technological advancements have resulted in horizontal drilling which has made tapping into shale deposits more financially viable.

6.103 Hydraulic fracturing (sometimes referred to as ‘fracking’) is a technique used in the extraction of oil or gas from shale rock formations by injecting water at high pressure. This process has caused some controversy. Whilst the government identified a pressing need to establish (through exploratory drilling) whether or not there are sufficient recoverable quantities of unconventional oil and gas present to facilitate economically viable full-scale production, hydraulic fracturing will not proceed in England following the publication of new evidence82 highlighting that is not currently possible to accurately predict the probability or magnitude of earthquakes linked with the operation.

6.104 There are no known commercial resources of oil and gas in Central and Eastern Berkshire, although viable conventional resources of oil and gas have been identified and are being exploited in neighbouring counties, such as Hampshire.

6.105 Oil and Gas licences are granted by the Oil and Gas Authority and confer rights for persons to search for, bore and produce petroleum resources. Oil and gas activity comprise a number of different stages including the exploration of oil and gas prospects, appraisal of any oil and gas found, production and distribution. The production and distribution of oil and gas usually involves the location of gathering stations which are used to process the oil and gas extracted. All stages require planning permission from the relevant mineral planning authority. The development of gathering stations requires more rigorous examination of potential impacts than exploration or appraisal.

6.106 There are currently no licence areas within Central and Eastern Berkshire. A former licence area within Windsor (PEDL 236) was relinquished in 2014.

6.107 There have also been two exploratory wells within the Central and Eastern Berkshire area, but these were completed in 1966 and 1974 respectively.

6.108 The lack of a current licence area and the fact that earlier exploratory wells did not lead to further appraisal or production suggests that there are no opportunities presently for the provision of oil and gas.

6.109 It is considered that should technology advances and more information on geological conditions become available, and the situation changes; there are sufficient policies within national planning policy83 to determine any application for oil and gas.

Coal

6.110 There is a significant coal seam in West Berkshire which runs into the western edge of Central and Eastern Berkshire. It is deep underground and not considered to be viable for extraction. Due to the depth of the deposits, open cast mining would be impractical, and any exploitation would need to be by underground mining. The coals are present in a thin gas seam and the coal measures are considered as not prospective for coalbed methane.

6.111 Whilst it is considered unlikely that an application will come forward for coal extraction, in such event, national planning policy84 would provide sufficient guidance in determining any such application.

Other non-aggregates

Chalk

6.112 In Berkshire, chalk was of some local importance and the use of chalk for agricultural purposes dates back to Roman times.

6.113 The geological outcrops of chalk in Berkshire are fairly extensive, but demand for new workings is very limited.

6.114 The continuing demand for chalk as agricultural lime is very low. The last active chalk pit in Berkshire, at Pinkneys Green (Hindhay Quarry) near Maidenhead is currently being restored. Some of the chalk from this pit was also used as bulk fill.

6.115 Due to lack of demand for chalk for industrial processes there is no requirement to make 15 years provision of chalk (as cement primary) as outlined in national planning policy85. As such, no allocations for chalk extraction are required and any future proposals can be determined using Policy M6.

Clay

6.116 Common clay was one of the main minerals produced in Berkshire until the 20th century. The most important were the land clay pits of the Lambeth Group and some of these were worked for over 200 years.

6.117 Some clay is dug intermittently from deposits near Reading and elsewhere for use as bulk fill or for sealing sites which are to be filled with putrescible waste. These are generally ‘one-off’ operations, and there appears to be no demand for claypits to be established to serve these markets on a long-term basis.

6.118 In the past, Berkshire had numerous small workings for clay for making bricks and tiles, but the mass production of bricks at much larger brickworks elsewhere in the region and the more general use of concrete tiles, has led to the closure of all the brick and tile works within the Berkshire area.

6.119 The last remaining brick and tile works was located at Star Works, Knowl Hill, between Reading and Maidenhead. Although the site contains extensive permitted reserves of clay, the manufacture of bricks and tiles ceased during the 1990s.

6.120 There have not been any operational claypits permitted to support industrial processes for over 10 years.

6.121 Due to the lack of current brick and tileworks within Central and Eastern Berkshire, there is no requirement to make 25 years provision of brick-making clay as outlined in national planning policy86. As such, no allocations for clay extraction are required to support the supply and any future applications can be addressed by Policy M6. However, demand for these minerals will be monitored in case demand increases and markets change.

Policy M6
Chalk and clay
  1. Proposals for the extraction of chalk and clay to meet a local requirement will be supported, in appropriate locations which comply with all relevant policies in the Plan, subject to there being no other suitable, sustainable alternative source of mineral including substitute or recycled secondary material available.

Implementation

6.122 Proposals for the extraction of non-aggregate minerals will be supported where they are in ‘appropriate locations’ and therefore, comply with all relevant policies within this Plan. Sustainable alternative sources should include substitute or recycled and secondary materials, where suitable87. Chalk and clay in particular will be assessed to consider whether the material concerned is needed to meet a specific local requirement which would supply Central and Eastern Berkshire or the immediate surrounding planning authority areas.

6.123 The supply of clay to landfill sites outside the Plan area would not be favoured because it would likely result in transportation over greater distances. The policy does not seek to establish a maximum or guide distance because there is insufficient evidence available to define such a figure, and criteria may vary. However, in practice it is considered unlikely that a proposal to supply a landfill beyond the ‘local requirement’ range would be promoted, because the practicalities of distance and alternative supplies closer to the point of use would preclude such proposals being commercially realistic. Similar considerations apply to the supply of chalk for production of agricultural lime.

Monitoring

6.124 Monitoring Indicators:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review
Chalk extraction Amount of chalk extraction in tonnes per annum. Increase in sales over 5 years.
Clay extraction Amount of clay extraction in tonnes per annum. Increase in sales over 5 years.

Aggregate wharves and rail depots

6.125 Central and Eastern Berkshire has many close functional interrelationships with its neighbouring authorities. Minerals won and processed in Central and Eastern Berkshire are not necessarily used within the Plan area. Some are likely to be transported elsewhere and at the same time minerals, such as crushed rock, which is not found within Central and Eastern Berkshire, are supplied from elsewhere.

6.126 All movements of mineral within the Plan area are undertaken by road as there are currently no aggregate rail depots or wharves within Central and Eastern Berkshire.

6.127 National policy encourages the use of sustainable transport88. During the life of the Plan, opportunities to utilise navigable stretches of the Thames, or canals or waterways within Central and Eastern Berkshire for water-based transportation of minerals may arise.

6.128 Central and Eastern Berkshire is well connected by rail, but it is dependent on rail depots at Theale in West Berkshire. However, establishing aggregate rail depots is difficult due to the limited locations. Freight path capacity, including the timetabling for Crossrail, will also be a restricting factor in supply. The rail depot in neighbouring Slough currently supplies the immediate operations and no further material is transported from the site. However, should the proposed Heathrow airport expansion proceed, the site may provide an opportunity for an aggregate rail depot which could supply the Plan area.

6.129 The Kennet & Avon Canal which joins Bristol and Reading via Newbury is a small waterway and is not considered to have significant potential for freight movement89. It is currently unknown whether the River Thames is suitable for freight from Windsor Bridge to Staines Bridge although large barges are able to use this waterway90. However, this may be limited as the river is non-tidal from Teddington Lock.

6.130 The potential for a rail depot or aggregate wharf in the Plan area could reduce local road impacts, although the likelihood of this opportunity is dependent on a number of factors including location of minerals, connectivity and cost.

Policy M7
Aggregate wharves and rail depots
  1. Proposals for aggregate wharves or rail depots will be supported:
    1. At Monkey Island Wharf, Bray (TA 1) provided the proposal addresses the relevant development considerations outlined in Appendix A; and
    2. In appropriate locations which comply with all relevant policies in the Plan, with good connectivity to:
      1. The Strategic Road Network; and/or
      2. The rail network; and/or
      3. Minerals infrastructure.

Implementation

6.131 The allocation of sites does not convey that planning permission will be automatically granted but indicates that the locations could provide sustainable development subject to the development considerations being addressed (see Appendix A),

6.132 Proposals for new sites will be supported where they are in ‘appropriate locations’ and therefore, comply with all relevant policies within this Plan.

6.133 In order to ensure that the proposal allows for the sustainable movement of materials, the site would need to have good connectivity to strategic transport infrastructure or minerals infrastructure such as a quarry or processing plant. Good connectivity is defined by Policy DM11.

Monitoring

6.134 Monitoring Indicators:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review

Aggregate rail depot capacity

Capacity (tonnes per annum).
A reduction in capacity over 5 years.
Aggregate wharf capacity Capacity (tonnes per annum). A reduction in capacity over 5 years.

Safeguarding other minerals development infrastructure

6.135 Safeguarding minerals infrastructure that supports the supply of minerals is just as important as safeguarding mineral resources. Safeguarding minerals infrastructure is a requirement of national planning policy91 which states that Mineral Planning Authorities should safeguard: “existing, planned and potential sites for: the bulk transport, handling and processing of minerals; the manufacture of concrete and concrete products; and the handling, processing and distribution of substitute, recycled and secondary aggregate material’’.

6.136 A particular problem that mineral infrastructure faces is the encroachment of incompatible land uses, such as housing, into the locality which may give rise to additional complaints about the existing mineral operations. This may result in a hindrance to operations and restrictions placed on the mineral site which impacts on supply.

6.137 Safeguarding potential sites for rail depots and wharves prevents future decisions being made without consideration of potential minerals and waste interests on appropriate sites.

6.138 Safeguarding also allows the Central & Eastern Berkshire Authorities to resist other types of future development which could be incompatible with existing minerals infrastructure and operations.

Policy M8
Safeguarding minerals infrastructure
  1. Facilities for the bulk transport, handling and processing of minerals; the manufacture of concrete and concrete products; and the handling, processing and distribution of substitute, recycled and secondary material within the Plan area will be safeguarded for their on-going use.
  2. Where this infrastructure is situated within a host quarry, wharf or rail depot, they will be safeguarded for the life of the host site.
  3. Existing, planned and potential sites that enable the supply of minerals in Central and Eastern Berkshire will be safeguarded against development that would prejudice or jeopardise its operation by creating incompatible land uses.
  4. Non-mineral development that might result in the loss of permanent mineral infrastructure will only be supported in the following circumstances:
    1. The site is relocated with appropriate replacement capacity being provided within the Plan area; or
    2. New capacity is provided within the Plan area which allows for the closure of sites; or
    3. The requirements of the need for the alternative development are set out in wider Local Plans and development strategies outweigh the need for safeguarding.

Implementation

6.139 Any existing or planned mineral operation including rail depot or wharf will be automatically safeguarded and a list of safeguarded sites will be maintained by the Central & Eastern Berkshire Authorities.

6.140 New or replacement capacity would only be considered to satisfy the circumstances outlined in Policy M8 if the capacity is provided within the Plan area.

6.141 In line with the “agent of change” principle in national planning policy92, potentially encroaching development will need to provide adequate mitigation measures to avoid prejudicing or jeopardising the safeguarded site or provide evidence that the safeguarded site will be unaffected.

6.142 There may be circumstances where the continued safeguarding of the site may be undesirable due to potential redevelopment opportunities such as regeneration. In these cases, some circumstances may enable the release of existing safeguarded sites.

6.143 In cases where aggregate rail depots or aggregate wharves in other Minerals Planning Authority areas provide a supply of aggregate to Central and Eastern Berkshire and are under threat of losing their safeguarding status which would result in a loss of capacity, the Central & Eastern Berkshire Authorities will provide support to defend the safeguarding or support the replacement of the capacity.

6.144 Statements of Common Ground with relevant Mineral Planning Authorities will regularly reviewed through the ‘duty to cooperate’. Support will be provided through information sharing, where relevant.

Monitoring

6.145 Monitoring Indicator:

Monitoring Issue Monitoring Indicator (Threshold) for Policy Review

Safeguarded permanent mineral sites.

Safeguarded permanent minerals and waste sites developed for other development uses without replacement capacity..
Number of safeguarded permanent minerals and waste sites developed for other development uses without replacement capacity > 0
Loss of permanent mineral capacity. Amount of capacity lost (in tonnes) through developed safeguarded permanent mineral sites.

63 A further survey is scheduled for 2020 but this may be subject to delays due to the Corona Virus.

64 Soft Sand Study (March 2020) - www.hants.gov.uk/berksconsult

65 Minerals: Background Study (July 2020) - www.hants.gov.uk/berksconsult

66 South East Aggregate Monitoring Report 2018 - https://documents.hants.gov.uk/see-awp/SEEAWP-annual-report-2018.pdf

67 National Planning Policy Framework (Para. 210(c)) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

68 National Planning Policy Framework (Para. 212)

69 Minerals and Waste Safeguarding Study (February 2022) - www.hants.gov.uk/berksconsult

70 National Planning Practice Guidance (Paragraph: 003 Reference ID: 27-003-20140306)

71 National Planning Policy Framework (Para. 213) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

72 National Planning Policy Framework (Para. 213(f))

73 Central and Eastern Berkshire: Local Aggregate Assessment 2019 - www.hants.gov.uk/berksconsult

74 The Assessment was undertaken following SEEAWP LAA: Supplementary Guidance - https://documents.hants.gov.uk/see-awp/SEEAWP-SuppLAAGuidance-July2019.pdf

75 Minerals: Background Study (July 2020) - www.hants.gov.uk/berksconsult

76 Somerset Local Aggregate Assessment (Fourth Edition, 2016) - http://www.somerset.gov.uk/EasySiteWeb/GatewayLink.aspx?alld=124408. 28.4 years of supply of crushed rock.

77 Minerals Background Study (July 2020) - www.hants.gov.uk/berksconsult

78 Minerals: Background Study (July 2020) - www.hants.gov.uk/berksconsult

79 Minerals and Waste Safeguarding Study (February 2022) - www.hants.gov.uk/berksconsult

80 National Planning Policy Framework (para. 213(f)) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

81 National Planning Policy Framework (Para. 210(b)) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

82 Oil and Gas Authority Report - https://www.ogauthority.co.uk/exploration-production/onshore/onshore-reports-and-data/preston-new-road-pnr-1z-hydraulic-fracturing-operations-data/

83 National Planning Policy Framework (most notably Para. 211) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

84 National Planning Policy Framework (most notably Para. 217)

85 National Planning Policy Framework (Para. 214(c)) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

86 National Planning Policy Framework (Para. 214(c)) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

87 National Planning Policy Framework (Para. 210 (b))

88 National Planning Policy Framework (Para. 104) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

89 WA Policy on Freight on Inland Waterways (2012) - www.waterways.org.uk/pdf/freight_policy

90 The River Thames and Connecting Waterways 2013-2014 - www.gov.uk/government/uploads/system/uploads/attachment_data/file/289796/LIT_6689_3e9c5e.pdf

91 National Planning Policy Framework (Para. 210(e)) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf

92 National Planning Policy Framework (Para. 187) - https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1005759/NPPF_July_2021.pdf



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