Regulation 18 draft Local Plan

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.

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.

Object

Representation ID: 6744

Received: 03/01/2024

Respondent: Rutland Quarry Forum

Agent: Rutland Quarry Forum

Representation suggest changes to the wording of policy MIN4 to reduce ambiguity and establish more rigorous criteria (such as replacing should with must) and adding the following final paragraph:
Should extraction rates at site exceed 110% of original consented rates the operator must, within 3 months of increased rates, review the risk assessments and mitigation measures supporting the original application to
determine the validity of assumptions used and whether the mitigation measures remain appropriate.

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

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.

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.

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.

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.