Regulation 18 draft Local Plan

Support

Representation ID: 6372

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

The 'small scale' nature of building stone operations’ is not defined and risks restrcting important sources of stone. The wording 'small scale' should be removed.
The supporting text references clay extraction at Little Casterton however this site has not operated for a considerable period of time and extraction is unlikely to resume.
The supporting text references annual production of 9,700 tonnes of building stone. Actual production levels are significantly higher and accordingly it is considered that greater consideration should be given to the importance of building stone production.

The small-scale nature of building stone extraction is defined through reference to the average annual amount (9,700 tonnes) of building stone produced by operators in Rutland over the last 10 years. This figure was derived from annual monitoring survey returns data collected between 2013 and 2022. It is considered to be small-scale when compared with crushed rock extraction in Rutland for example (which averages 283,000 tpa over the last 10 years).
The NPPF para 217 states: ‘In considering proposals for mineral extraction, minerals planning authorities should: recognise the small-scale nature and impact of building and roofing stone quarries, and the need for a flexible approach to the duration of planning permissions reflecting the intermittent or low rate of working at many sites.’
The permission at Little Casterton for clay extraction expires at the beginning of the plan period and therefore clay can be extracted from the site up-to this point. On investigation however it does appear the site is now permanently closed and so references to the site being active will be removed from the plan.

Object

Representation ID: 6374

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

MIN2 (c) supports the supply of building stone, but specifically refers to use within Rutland. Given the limited geographical extent of the County, it is inevitable that a proportion of building stone extracted will be used outside the County (principally within neighbouring counties). To ensure the adequate provision of regionally importance sources of stone it is suggested that this wording be expanded to ‘Rutland and the surrounding region’.

Agreed in part. Amend MIN2 c) to: ‘support the supply of minerals where necessary for conservation purpose and / or maintaining the local distinctiveness of the built environment within Rutland and the surrounding sub.

Support

Representation ID: 6379

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

The proposals in respect of the safeguarding of limestones, clays for use in cement manufacture, and sand and gravel are supported however there appears to be no justification for the safeguarding of fireclay.
The supporting text confirms that ‘A realistic judgment about the resource viability, practicability and potential environmental impacts will be made; the MPA will not seek to prevent development where it is unlikely that prior extraction is feasible’. This is of paramount importance to the successful application of Policy MIN3 and consideration should be given to reinforcing this approach or potentially including similar wording within the Policy itself.

Fireclay is safeguarded as it is a mineral resource of local and national importance. This is specified in Policy MIN3 para 1, bullet point 2. Para 14 of the Spatial Strategy for Minerals Development also states that fireclays are exported from Little Casterton quarry, Rutland, and used in the making of a specialist brick - Little Casterton facing brick - that is used to repair listed buildings.
It is not necessary to reiterate the supporting text in Policy MIN3. This reduces bulk and makes for a more reader-friendly document. When a MPA decides if a non-mineral development proposal is suitable within an MSA, Policy MIN3 and supporting text are both taken into account, with the plan read as a whole.

Object

Representation ID: 6385

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

Within MIN4 b) iii, reference to ‘Rutland’ should be amended to ‘Rutland and the surrounding region’.
The preference for proposals at allocated sites risks prejudicing other applications, particularly if the sole proposed allocation is not brought forward. This may have a detrimental impact on material supply (particularly in relation to building stone), competition and the local economy. In order to support the continuation of existing operations, proposals for the extension/direct replacement of existing sites should be given equal importance to allocated sites.

Agreed in part. Amend MIN2 c) to: ‘support the supply of minerals where necessary for conservation purpose and / or maintaining the local distinctiveness of the built environment within Rutland and the surrounding sub-region’.
Amend Policy MIN4 a) to build in flexibility for non-allocated building stone sites to come forward: ‘Preference will be given to proposals for mineral extraction at allocated sites. Proposals on unallocated sites or outside of the areas identified in the spatial strategy will be considered where: a) the proposal relates to extraction of aggregates, building stone, or cement materials (limestone and clay) and cannot reasonably or would not otherwise be met from committed or allocated reserves, or from within the cement primary and secondary materials Area of Search; or

Object

Representation ID: 6394

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

In order to avoid unnecessarily preventing non-mineral development where historically permitted mineral extraction is unlikely to resume, MIN6 b) should make it clear that a realistic judgment about the viability, practicability and potential environmental impacts of extraction at a permitted site should be made.

At the planning application stage for a non-minerals development (that is adjacent to a committed minerals extraction site) there is opportunity to demonstrate that the proposed development would not prevent or unreasonably restrict the future extraction of minerals from the adjacent site – this could include for example an assessment of whether, where extraction has ceased, it will likely commence in the future. This is something that will be considered on a site-by-site basis, in line with Local Plan policies.

Support

Representation ID: 6396

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

It is important that the restoration policy recognises the potential range of restoration opportunities within the County and contains sufficient freedom to ensure that future restoration schemes can be tailored to meet emerging trends/objective (as external factors may dictate).

Noted.

Object

Representation ID: 6510

Received: 08/01/2024

Respondent: Hughes Craven Ltd.

The scale of the proposed allocation is excessive and extraction is likely to extend well beyond the Plan period.
There is uncertainty around its delivery/the extinguishment of the extant Thistleton permission.
The inclusion of such a large scale allocation undermines the spatial strategy set out in MIN1 and may prejudice other mineral applications within the Plan period. This may have a detrimental effect on minerals supply and stifle competition.
An alternative site has been proposed at Hooby Lane North which would replace the proposed allocation - and detailed comments have been made about the Mineral and Waste Site Assessment Report conclusions on the both sites.
In light of the above it is considered that the allocation should not be taken forward and instead replaced by the alternative site at Hooby Lane North.

The allocated site Land off New Road, Hooby Lane has been assessed and is considered to be a viable and deliverable site. It meets emerging Policy MIN 1 – compliant as located within limestone for aggregate and building stone Area of Search and operations include recovery of building stone to service the local market for new and historic buildings and Policy MIN2 Mineral provision - Supports the supply of minerals for conservation purposes and / or maintaining the local distinctiveness of the built environment within Rutland. The yield of building stone is unknown at present, as such is the annual extraction rate and length of operations. The extraction of building stone is however typically small-scale and often intermittent. The surrender of the Thistleton permission in exchange for Hooby Lane is supported by industry and landowners and they are committed to the bringing the site at Hooby Lane forward for development.