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Technical & Strategic Assessment of Aggregate Supply Options in the South West Region5.26 Reducing impacts in those specific locations, however, is not the only factor to be taken intoaccount in the search for a more sustainable solution: consideration might equally be givento policies which seek to avoid the granting of new mineral permissions in all areas whichhave insufficient ‘environmental capacity’ to absorb the associated impacts; or even topolicies which place a temporary embargo on all new permissions, in order toencourage greater substitution between different aggregate sources.5.27 The latter would be at the extreme end of this range of planning options, and is likely tohave many adverse implications, but it is an option that needs to be considered, in view ofthe existence of surplus reserves of crushed rock in many areas and the surplus arisings ofsecondary aggregates at china clay workings. Careful consideration would need to begiven as to how, in practice, this could be achieved within existing planning legislation.Ideally, the embargo would need to be specified in the Regional Spatial Strategy, thustaking precedence as a material consideration over the preferred areas identified in existinglocal plans, and would subsequently need to be reflected in the relevant Local DevelopmentFrameworks. This option would effectively incorporate the avoidance of new permissions insensitive areas, and is considered below as “Scenario 2”.5.28 It must be emphasised that neither this, nor any of the other possibilities outlined below,should be seen as recommended alternatives to Scenario 1: they are merely logicalpossibilities that might be achievable and which therefore need to be considered.5.29 Before any of these alternatives (or indeed Scenario 1 itself) can be recommended fortaking forward for incorporation into the Regional Spatial Strategy, their economicfeasibility, detailed composition and relative sustainability all need to be examined far morethoroughly than has been possible in this study.5.30 Given that Scenario 2, as outlined above, seeks to address the most fundamental of theSWRAWP’s concerns in respect of the baseline scenario of maintaining the status quo, itseems logical that this should also be at the heart of some or all other scenarios that aretested. In other words, these additional scenarios should be framed along the lines of “whatif there were no further mineral permissions and .....”5.31 One of the options that could (theoretically at least) be ‘bolted-on’ to Scenario 2, in order tomake it more effective, would be to provide subsidies for the importation of sea-borneaggregates (especially, but not exclusively from secondary sources) into local portswithin the south west. Such policies would need to provide a specific incentive to landmaterial at ports with economical access to the shortfall areas, rather than just a generalincentive to sea-borne aggregate movements (since that would simply amplify the existingpattern of preferential movement of sea-borne aggregates into higher value markets in SEEngland and NW Europe).5.32 The required effect might, potentially, be achieved by providing subsidies to offset the portcharges for importing aggregates into the South West. Fiscal policies of this sort, which areconsidered below under “Scenario 3”, would almost certainly have a number of unintendedadverse economic, socio-political and environmental consequences, and might well invokethe European commission’s obligation to veto market distortions c . Furthermore, suchpolicies would also need to be funded, and that itself would bring many additional problems.For all of these reasons, it must be further emphasised that Scenario 3 is NOT beingrecommended as a way forward, but merely as an option which logically needs to be testedas part of this study.c As seen, for example, in the Commission’s objection to the subsidy given to Ryan Air by Charleroi airport,which had been given in the interests of stimulating economic activity within a depressed area.Capita Symonds Limited page 35 June 2005
Technical & Strategic Assessment of Aggregate Supply Options in the South West Region5.33 Another option that might be considered as an alternative addition to Scenario 2, in order tostrengthen its intended effects, would be to introduce a policy of prohibiting, revoking ormodifying extant mineral planning permissions located in sensitive or otherwiseprotected areas. Whereas the intended benefits of Scenario 2 would not becomesignificant until existing permitted reserves in those areas are depleted, this variation would,theoretically at least, have more immediate effects. In practice, however, this again wouldbe highly unlikely to occur on any significant scale because of the cost implicationsinvolved: the use of prohibition, revocation or modification orders to prevent or restrict theworking of existing permitted reserves would require compensation to be paid to the quarryoperators for the lost asset value of the affected reserves.5.34 Other potential options that could be considered as modifications to scenario 2 couldinclude:(i) increasing targets for the recycling of C D & E waste (or, more usefully,providing specific policy initiatives that would increase either the overall rate ofarisings - e.g. from brownfield site redevelopment - or the proportion of arisings thatcan substitute for primary aggregates, especially in higher value applications. Thiswould generally require improved segregation of waste materials as they arise onconstruction, demolition and excavation sites, in order to minimise subsequentprocessing costs);(ii) anticipating major objections to future aggregates extraction includingobjections on the grounds of ‘birdstrike’ (i.e. the danger to aircraft fromconcentrations of birds around mineral workings restored to open water or landfill).This has the potential to be of major significance within the Upper Thames valley -the predominant source of sharp sand & gravel in both Wiltshire & Gloucestershire -and could necessitate an increased dependency on alternatives. This, however, iseffectively already covered by the basic premise of Scenario 2, which assumes thatno new permissions will be granted in these areas;(iii) taking account of the implications of emerging and future legislation, such asthe Working Time Directive (implications for road haulage costs, exacerbating thenegative aspects of any change in supply pattern that would involve greatertransport distances); the Water Act 2003 (potential implications for developing ordeepening quarries below the water table in areas important for their waterresources - notably in the Mendips); other aspects of the Water Framework Directive(particularly regarding impacts on water quality and ecological status of waterbodies); and possible changes to HSE requirements regarding maximum benchheights in quarries (with a potential need for new reserves to be permitted if thesafely extractable quantities are reduced at existing sites);(iv) Implementing positive actions to reduce demand (challenging national policieson house building, road construction etc. to reduce the growth in overall demand forconstruction aggregates within the region. More controversially, consideration couldbe given to reducing construction demand within the specific markets supplied fromthe shortfall areas. This would specifically help to reduce the need for substitutematerials to be moved into these areas, but it would distort patterns of futuredevelopment which, in turn, may have adverse consequences overall. Taken to itslogical extreme, this approach could eventually lead to an increase in futuredevelopment in locations within reach of the major quarries, and to a decline indevelopment elsewhere).5.35 One further option that should logically be tested, but as an ‘opposite’ to Scenario 2, ratherthan as a possible addition to it, would be the encouragement of small-scale exploitationof local resources for local use, with the specific intention of reducing the necessity forlonger road haulage from other sites (thereby reducing transport impacts, but at theexpense of more pronounced local impacts, sometimes in highly sensitive areas). This kindCapita Symonds Limited page 36 June 2005
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