Support

Representation ID: 4933

Received: 29/12/2023

Respondent: Mr Andrew Lunn

All mineral extraction sites, ones in use now as well as any new extensions planned should include as standard dust monitoring. These should be fitted close to the site but also on edges of villages or residential areas that are close enough to be effected by dust carried by winds etc..
Also all truck coming out of the quarries should have to go through a cleaning process so that roads are not left in a dangerous state.

Noted. Requirements for dust monitoring and wheel cleaning are addressed during the planning application stage.

Object

Representation ID: 5221

Received: 03/01/2024

Respondent: Mr Frank Brett

Arguably mineral extraction, cement production and the generation of waste together represent the most environmentally damaging activities within Rutland. However, on reading these policies, it seems that there is little that a Local Plan can do to mitigate them. We must look to national legislation and social/cultural interventions to make any impact in this area. This is a real shame and a risk to the wellbeing of all of us.

Policies MIN4, MIN8 and WST2 include criteria that require minerals and waste-related development to be environmentally acceptable and avoid and/or minimise potentially adverse impacts (including cumulative impacts) to acceptable levels.

Object

Representation ID: 6621

Received: 08/01/2024

Respondent: Defence Infrastructure Organisation (DIO)

Agent: Montagu Evans LLP

Comments made on behalf of the DIO as part of a full written response to Rutland Council. Representations should be read in context and not in isolation.
The DIO are cognisant of the Council’s strategy for minerals development within the County, including the designation of part of the undeveloped area of St George’s Barracks. The overall approach is understood, but we question the effectiveness of safeguarding land for extraction which is sterilised by the presence of Listed Buildings. A more refined approach to site selection should be taken to ensure deliverability.

Noted. As per the Mineral Safeguarding Areas Methodology, in creating the MSAs, buffers were applied around all mineral resources, extending outwards from the boundary of the BGS mineral resource linework. Where the MSA includes urban areas, or indeed individual buildings, these were not excluded as it reflects that mineral resources are present and may allow for future extraction where associated with large redevelopments.

Object

Representation ID: 6742

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Chapter 10 does not address many of the potential concerns arising from the mineral activities. Specific policies are necessary for:
i. Realistic quantitative environmental risk assessments based on site specific data which identify the exact nature and extent of potential adverse impacts,
ii. Risk assessments reviews within 3 months of any increases equal to, or greater than 10% of original consented rates of mineral extraction,
iii. Mandatory Health Impact Assessments for any proposed Mineral Application, or where any current activity exceeds consented mineral extraction rates by 10% or more,
iv. Adequate infrastructure to support for this growing industry within Rutland,
v. Reducing the visual impacts of the many quarries to the North Eastern area of, and entrance way to, Rutland,
vi. Progressive restoration of any mineral workings within the County.
vii. Effective and robust enforcement of planning conditions, thereby ensuring this growing industry within the County is operating the highest possible standards of protection for the residents of Rutland.
viii. Mandatory liaison groups between the quarry operator, local residents and the mineral planning authority.

As detailed in Policy MIN4 - Development criteria for mineral extraction, proposals for mineral extraction will only be permitted where it can be demonstrated that the development is environmentally acceptable and avoids and/or minimises potentially adverse impacts to acceptable levels. This includes impacts on the natural and historic environment and on human health, including from noise, dust, visual intrusion. The need for quantitative risk, health and highways impact assessments and reviews, are matters to be addressed through the scoping and planning application process, should a planning application come forward. Policy MIN9 - Restoration and aftercare, requires that restoration should be undertaken in a progressive manor.
The monitoring of planning conditions related to adverse impacts will be undertaken to the highest possible standards to address the risk to health of nearby residents and the neighbouring environment generally, as detailed in Policy MIN4 supporting text. Whilst not mandatory, most operators and many mineral extraction sites have quarry liaison groups through which the public can directly raise and discuss problems and concerns. Such liaison groups are commonly required in minerals planning permission conditions.

Object

Representation ID: 6743

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

The policies within the mineral section of Chapter 10 of the draft Local Plan need to be precise, unambiguous and provide clarity of intent.
Apart from setting standards to proposed developers as to what is an acceptable development, the policies must also provide residents with an absolute assurance that any development will not impact their health or wellbeing nor the environment in which they live.
Over the plan period these policies will be the reference by which quarry operators will construct their future development proposals.
It is imperative that the highest standards are set at this stage giving RCC the greatest control over future development.
As drafted, some of the draft policies are likely to be subject to ambiguity of interpretation, give rise to difficulties for planning development control and possible lack of appropriate protection for residents impacted by mineral workings.

Policy MIN4 - Development criteria for mineral extraction provides a range of development and assessment criteria which proposals for minerals development must satisfy before planning permission is granted. Any minerals development must be environmentally acceptable and avoid and/or minimise potentially adverse impacts (including cumulative impacts) to acceptable levels, this includes impacts on human health, including from noise, dust and visual intrusion. It is expected that monitoring of planning conditions related to adverse impacts will be undertaken to the highest possible standards to address the risk to health of nearby residents and the neighbouring environment generally.

Object

Representation ID: 6745

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Mineral policies should include Effective Risk Appraisal. Scale of proposed mineral workings means the area will be subject to significant impact if not properly understood and controlled. As the size of the industry increases within this area, so do the risks. It is extremely important there is proper understanding of risk. This is the clearly defined in the Governments recently published Environmental Principles Policy Statement of 2022.
Policies are required for quantitative assessments of air quality and potential risks which are based on actual real time monitoring, rather than the current practice of theoretical emission levels.
Additionally policies are necessary to ensure that any significant changes to mineral practices, including where current mineral extraction exceeds consented rates by 10% or more, are subject to mandatory review of the original risk assessments

Policy MIN4 - Development criteria for mineral extraction, requires mineral extraction proposals to be environmentally acceptable and avoid and/or minimise potentially adverse impacts (which includes cumulative impacts) to acceptable levels. The need for quantitative risk assessments and reviews should extraction exceed consented rates are matters to be addressed through the scoping and planning application process, should a planning application come forward.

Object

Representation ID: 6746

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Policies required to cover Health Impact Assessments.
Over recent years there has been greater understanding of the impacts of
the harmful PM10 dust particulates associated with breathing difficulties. Modern day research has shown limestone quarries are a major source of PM 10 arisings however, based on historic assumptions that such particles have limited travel, offsite monitoring data from mineral workings is very limited.
Health Impact Assessments consider the potential damage to local residents health from this growing industry and needs to be fully assessed and understood to allow effective preventative measures to be taken. This is in accord with the Precautionary Principle.
Health Impact Assessments for any proposed Mineral Application, or where any current activity exceeds
consented rates by 10% or more should be mandatory.

Noted. Policy SC5 requires a health impact assessment for all mineral extraction proposals

Object

Representation ID: 6747

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Additional policies required for supporting infrastructure for mineral activities.
The creeping piecemeal development of 5 individual quarries will, over the plan period, have significant impacts on infrastructure and services within the local area.
Robust Policies are needed to ensure adequate supporting infrastructure for this growing industry within Rutland.
Finally, the visual impacts of the many quarries to this area of, and entrance way to, Rutland needs to be properly planned to ensure the area does not degenerate into an industrial wasteland.

Policy MIN4 - Development criteria for mineral extraction, requires mineral extraction proposals to avoid and/or minimise potentially adverse impacts (including cumulative impacts) to acceptable levels. This includes impacts on highways and visual impacts. The need for a highways and transport assessment is more appropriate to be developed through the scoping and planning application stage for individual sites.

Object

Representation ID: 6748

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

The draft plan lacks policies for mineral site restoration.
This has been a significant weakness of previous local plans and has led to the inability of the Mineral Planning Authority to enforce restoration requirements on many historic worked out quarries within the region.
The plan must provide policies to require progressive restoration of any mineral workings within the County.
Wherever possible the restoration should meet the requirements of the Leicestershire, Leicester and Rutland Biodiversity Plan objectives for increasing the area of calcareous grasslands within the region. The Biodiversity plan identifies worked out limestone quarries as one of the
main types of habitat needed for achieving this key objective.

The emerging Local Plan addresses the restoration of minerals development in Policy MIN9 - Restoration and aftercare. It states: All temporary minerals development must include a restoration scheme to secure delivery of high-quality restoration and aftercare, including provisions for ongoing management and maintenance where necessary. Restoration should be undertaken in a progressive manor and provide a net-gain in biodiversity. It outlines that where appropriate; restoration should contribute towards the aims of the Leicester, Leicestershire and Rutland Biodiversity Action Plan.

Object

Representation ID: 6750

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Policies are required which ensure that planning conditions are written in such a way that enforcement is possible.
There is ample evidence that planning conditions are not being adequately enforced. The basic problem is that some quarry operators have little regard for the public interest. When issues have been raised, the response
by the Minerals Authority has been slow and effective measures have not been taken. It would appear that the presumption is permitting operators to minimise their costs, rather than protect public health and amenity.
This is due partly to planning conditions being ambiguous and partly to inadequate enforcement resources.

Planning conditions and issues of enforcement are handled via the development management process and undertaken in accordance with the Town and Country Planning Act and National Planning Policy Framework (NPPF). The National Planning Practice Guidance (NPPG) provides an overview of enforcement processes and options: http://planningguidance.communities.gov.uk/blog/guidance/ensuring-effective-enforcement/planning-enforcement-overview/. The Councils Planning Enforcement Policy document can be viewed at https://www.rutland.gov.uk/sites/default/files/2022-10/Planning%20Enforcement%20Policy%202020.pdf. To provide further information on managing the implementation of minerals and waste development, include an additional section in the minerals and waste chapter of the Local Plan. Include information on planning conditions and obligations, monitoring, local liaison groups and a policy on implementation.

Object

Representation ID: 6778

Received: 05/01/2024

Respondent: Barrowden Parish Council

We support the views expressed in the paper prepared by the Rutland Quarry Forum.

Noted.

Object

Representation ID: 6967

Received: 06/01/2024

Respondent: RCC Expert Panel on Carbon Reduction

All temporary minerals and waste development should have, at least, a five year programme of aftercare, including provisions for ongoing management and maintenance where necessary.
There is an opportunity to increase biodiversity through mineral and waste aftercare programes for example:
* creation of woodland cover by planting of new broadleaved woodland
*Floodplain wetland as a good choice of habitat for restoring sites used for sand and gravel extraction, for example in the Welland Valley.
*Limestone operations provide opportunities to create limestone grassland habitat and to expose features of geological interest.
*Restoration to agricultural use should only be for lightly grazed pasture. Light grazing is often desirable in old quarries to prevent species rich grassland reverting to scrub.

Noted. Policy MIN9 - Restoration and aftercare, provides a guide to those types of after-uses that are supported, including: biodiversity and nature conservation, native woodland, forestry and geodiversity. Restoration schemes incorporating types of wetland habitat are discouraged in Rutland as they have the potential to attract large and flocking bird species, increasing the potential threat of bird strike to air traffic.
The length of after-care is dealt with at the planning application stage via planning condition. The National Planning Policy Framework (NPPF) requires a 5-year aftercare period for restored mineral extraction sites (or longer if agreed between applicant and the Mineral Planning Authority).
Restoration to agriculture is supported where it safeguards the long-term potential of best and most versatile agricultural land and conserves soil resources. The type of agricultural land use will be assessed on a site-by-site basis, in line with the Local Plan policies and other relevant policies.

Object

Representation ID: 6994

Received: 06/01/2024

Respondent: Greetham Parish Council

Minerals and Waste
Greetham Parish Council are members of the Rutland Quarry Forum (RQF).
We fully endorse the separate RQF response to the Local Plan which was submitted on
3rd January.

Noted.

Object

Representation ID: 7464

Received: 07/01/2024

Respondent: Cottesmore Parish Council

problems occur around the enforcement of quarrying operations - this is twofold, requiring both having clear and unambiguous conditions designed to be enforceable, including such conditions as operators paying for more frequent inspections throughout the active life of the quarry. It is obvious that if there are not sufficient resources available to do this, either because of costs or shortage of expertise, then uncontrolled quarrying will have massive impact on both public health and amenity.

Noted.

Object

Representation ID: 7485

Received: 05/01/2024

Respondent: The British Horse Society

Where mineral extraction sites are identified, PRoW and the informal off-road network should be considered and protected through all phases of the extraction and processing.

Noted.

Object

Representation ID: 7755

Received: 08/01/2024

Respondent: Anglian Water

At page 258, reference is made to wastewater. However there does not appear to be a policy or consideration of wastewater recycling at WRCs, for example. We would recommend that wastewater development is included with waste policy and map on page 244 as well in the waste needs assessment. Alternatively, it could be specifically excluded in waste policy and then covered in more general policy or more probably addressed in Chapter 11 – Infrastructure. We would comment that our development is different from other waste development and as indicated above further investment will be required at Oakham WRC from 2025 onwards in part to address P-TAL. We would comment that the function and operation of WRCs means that works cannot always avoid flood zones given their requirements.

Agreed in-part. Update the Waste Needs Assessment and Local Plan to include consideration of agricultural wastes and waste water. It is not necessary to add waste water development to the Spatial Strategy map.

Object

Representation ID: 7836

Received: 08/01/2024

Respondent: Alicia Kearns

Chapter 10 of the Plan requires greater detail setting out how RCC as the Mineral Planning Authority will work with developers and industry to mitigate specific threats to both the environment and human health.
There should be mandatory liaison groups established with local communities affected by mineral developments to ensure constant communication and channels for residents to raise concerns.
As part of this, enforceable policies – with monitoring and accountability mechanisms - are required to cover:
- nuisance dust and PMD
- Maximum quarry output limits (tonnage) for the County
- Environmental impacts of quarry transport in relation to Rutland’s climate change objectives
- Conditions applicable to each quarry application are designed and documented for public consultation before any quarry application is approved.
- Conditions for site restoration to nature at the end of quarry life are made enforceable under all circumstances.
The current Local Plan does little to recognise the concerns or priorities of our communities with regard to extractive industries, and there must be significantly more work done around liaison with communities, community power over proposals, and compensation packages.

Policy MIN4 - Development criteria for mineral extraction, sets out a range of requirements that proposals for minerals extraction should meet including that the development is environmentally acceptable and avoids and/or minimises potentially adverse impacts (which includes impacts on the natural and historic environment and on human health) to acceptable levels.
Whilst not mandatory, most operators and many mineral extraction sites have quarry liaison groups through which the public can directly raise and discuss problems and concerns. Such liaison groups are commonly required in mineral site planning conditions.
The need for dust and traffic impact assessments and associated monitoring are more appropriate to be developed through the scoping and planning application stage for individual sites rather than being included in the plan.
With regards to quarry output limits, any proposal for extraction will be required to take into account the current reserve and supply position, provision rate (where relevant) and landbanks, which are monitored and reported annually in the Local Aggregates Assessment. Included in the supporting policy text of Policy MIN2 is reference to limits on annual sales to ensure quarries are not overworked, with more mineral extracted annually than originally planned.
There is opportunity to make representations on a planning application during the period of consultation however once a planning application and associated planning conditions have been determined, no further consultation is undertaken.
A developer is required to submit proposals for restoration as part of the planning application and regular site inspections will be carried out to ensure any related planning obligations or legal agreements that are associated with the operation are carried out.
To provide further information on managing the implementation of minerals and waste development include an additional section in the minerals and waste chapter of the Local Plan. Include information on planning conditions and obligations, monitoring, local liaison groups and a policy on implementation.

Object

Representation ID: 7977

Received: 07/01/2024

Respondent: CPRE Rutland

With the increased quarrying in the County, it is imperative that appropriate safeguards are in place to protect the environment and minimise the risks to public health. The policies proposed in the draft plan do not, however, go far enough to achieve this objective.

Much stronger controls than are provided by the proposed polices will be needed on health and safety grounds with respect to pollution from quarry workings and associated transport operations, that measures to maintain relevant levels of biodiversity are included, and that appropriate restoration of land once such workings are complete is both planned and enforced.

Enforceable policies are required to ensure that:
• Nuisance dust and PMD particulate generation are subject to specified and declared limits which are accurately
measured, monitored correctly and can be effectively enforced by Development Control.
• Maximum quarry output limits (tonnage) are planned for the County in accordance with national targets and
limits and are also limited by local environmental improvement targets.
• Environmental impacts of quarry transport are weighed in relation to Rutland’s climate change objectives which
must be prioritised above quarry operator output targets
• Conditions applicable to each quarry application are designed and documented for public consultation before
any quarry application is approved. Conditions for site restoration to nature at the end of quarry life are made
enforceable under all circumstances.

Policy MIN4 - Development criteria for mineral extraction, sets out a range of requirements that proposals for minerals extraction should meet, including that the development is environmentally acceptable and avoids and/or minimises potentially adverse impacts (which includes dust, noise and vibration, safe site access, highway safety and cumulative impacts) to acceptable levels.
Policy MIN9 - Restoration and aftercare, requires that restoration of minerals development provides Biodiversity Net Gain (BNG), which is a mandatory requirement under the Environment Act (2021). A developer is required to submit proposals for restoration as part of the planning application and regular site inspections will be carried out to ensure any related planning obligations or legal agreements that are associated with the operation are carried out. There is opportunity to make representations on a planning application during the period of consultation however once a planning application and associated planning conditions have been determined, no further consultation is undertaken.
The need for dust assessments and monitoring and traffic impact assessments are more appropriate to be developed through the scoping and planning application stage for individual sites rather than being included in the plan. With regards to quarry output limits, any proposal for extraction will be required to take into account the current reserve and supply position, provision rate (where relevant) and landbanks, which are monitored and reported annually in the Local Aggregates Assessment. Included in the supporting policy text of Policy MIN2 is reference to limits on annual sales to ensure quarries are not overworked, with more mineral extracted annually than originally planned.
To provide further information on managing the implementation of minerals and waste development include an additional section in the minerals and waste chapter of the Local Plan. Include information on planning conditions and obligations, monitoring, local liaison groups and a policy on implementation.