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INDEX
01 - 'Sir Ralph your’re never going to believe this but….' Paper given at the RTPI/QPA Annual conference May 2005
02 - ‘Living with Minerals’,
Published in Mineral Planning September, 2004
03 - 'Living without minerals is just not a option’ , ECOS - The journal of the British Association of Nature conservationists- article - September 2004
04 - ‘Lingerbay': The future has been cancelled,Published in Mineral
Planning June, 2004
05 - ‘Sleeping with the enemy’, Construction News, 17 June 2004
06 - ‘I’d rather be a regulator than an operator’,Published in Mineral Planning, December 2002, based on paper given at Savills waste management conference
at the Royal Society.
07 - ‘Certain things need to be said’, Published in Mineral Planning, December 2001, based on paper given at the RTPI/QPA conference – ‘A fair deal for mineral’.
08 - ‘MPG 6 – The hangover worsens’ – Quarry management, December 1994, based upon paper given to the Sand and Gravel Association annual conference.
01 - 'Sir Ralph your’re never going to believe this but….' Paper given at the RTPI/QPA Annual conference May 2005
Today I want to provoke you to think about the future and sustainability of the aggregates industry, not for 5 years, not for 10 but for the next 25 years, the next generation.
Why? Because I believe that there is going to be a horrible coincidence of challenges for us all as citizens and practitioners during this period.
Whether it is energy, water, or aggregates these fundamental resources may all display common features of continuing and probably rising demand coupled with increasingly constrained supply.
Consequently I invite you to contemplate how we can best plan our response to the long term need for aggregates in a more strategic way.
But before we look forward I think we need to remind ourselves that this is by no means a novel idea.
Looking Back
Firstly there is the ‘Report of the Advisory Committee on Sand and Gravel’ Chaired by Mr Waters in January 1948, complemented by the report of the ‘Mineral Development Committee’ in July 1949 Chaired by Lord Westwood.
AS you can see there are some quite contemporary sustainability and strategic themes in both of these works even including a reference to a possible aggregates levy by Mr Waters.
In 1967 the Minerals Consultative Committee met under the remit ‘to keep under review present requirements and forecast demands for mineral resources’.
And then in the mid seventies the Stevens report on ’Planning control over Mineral Workings’ and Sir Ralph Verney’s Report on the ‘Advisory Committee on Aggregates ‘The Way Ahead’ hit the streets and between them effectively created the architecture for the minerals and particularly the aggregates industry as we know it today.
And broadly speaking, our world has operated far better post Verney than pre Verney.
However Verney was different from the work that pre dated it.
It really did try to blue sky the future long term provision of aggregates because of the perceived difficulties of maintaining supplies of sand and gravel into the SE.
Verney was seminal, it glimpsed the future, but as with all glimpses what you think you see may not actually be what is really there.
Consequently 30 years on I think there is merit in reminding ourselves of some aspects of Verney to appreciate why we are where we are, to see what lessons can be learned and to help us take a longer term and more strategic view.
Consider this, when Verney was written it could not contemplate the growing influence of the EU, devolution in the UK, sustainable development had not been invented, the environmental movement was in its infancy and the internet and Ant and Dec had not even been heard of.
Whilst the existing system has been extremely effective in contemplating likely levels of demand and components of supply for short and medium term planning and policy work, I believe we need to beef up our understanding of the potentially workable resources we have available and the sustainability of all components of supply to contribute for the long term.
Verney on Resources
Well the good news is there is no need to panic, the only national resource figures that have ever been published were in Verney and indicate that the 30,000 years of caveated and cautioned aggregate resources indicated by the BGS, is now down to just 29,970 years!
The only problem is that for mineral planning purposes 84% now lies in other countries, Scotland and Wales.
Factoring this in would suggest that England now has less than 5000 years of potential resources remaining.
Now I have discussed how these figures were calculated with David Highley at the BGS and he would be the first to point out that they were produced to paint a very broad resource picture and I certainly do not intend to overplay the numbers game, because you can’t.
That is my point.
The fact is we have not identified clearly where or estimated what our potentially workable resources for the long term actually are.
What we can say however is that potentially workable resources are far more abundant than most appreciate but our current approach to constraint management may be giving us the impression that we have a resource problem when in fact what we really have is an access and may be an attitude problem.
Let me give you an example of what resource uncertainty can do.
Verney considered 8 different scenarios for supplying the SE which hinged on the key underlying assumption that notwithstanding the indicative estimate of 30Bn tonnes of aggregate resources available, which represented 6 to 700 years of supply, once you took into account constraints this would reduce to only 10 to 15 years.
So there’s the range 10 to 700 years!
Fortunately,
Serplan 1988 ‘Deposits and Constraints’
SERPLAN picked up this issue some 13 years later and procured an excellent report called ‘Sand & Gravel in SE England, Deposits and Constraints’ which estimated that workable resources of between 2.5Bnt and 13Bnt might be available in the SE which at Verney’s annual drawdown rate would in theory be sufficient for between 63 and 325 years.
What is one to conclude?
Verney contemplated that the SE would have been empty between 1985 and 1990 whereas SERPLAN implies that it would be somewhere beyond 2050.
Verney Scenario 2011
As a result of Verney’s concerns about aggregate supplies, some may recall that the review of MPG6 1989 contemplated that up to 6 super quarries, would be contributing 101mtpa to UK production by 2011.
Indeed Verney anticipated up to 50 mtpa contributing to the south east’s needs from superquarries in Scotland and from underground mining in Kent alone.
This compares to current SE consumption I estimate at around 45mtpa of which just under half is still supplied from land won and marine sand and gravel.
I didn’t buy the scenario at the time. I know because I wrote to Robin Mabey, Lester’s predecessor in 1993 explaining why this was ridiculous.
My conclusion is that it appears that Verney got the timing and dimension of the SE problem wrong, by overestimating demand and underestimating supply.
Nonetheless the work was an important wake up call and stimulated the shift in supply mix more quickly than might otherwise have been the case.
Learning the lessons
The SERPLAN exercise introduced some additional rigour and systematics into the situation.
Whilst it is not an easy exercise I believe it is significant and I think it should become a RAWP best practice preferably underpinned by the BGS’s excellent GIS capability and general expertise and then consolidated at the national level.
If we genuinely want to achieve prudent use of our aggregate resources we may have to accept that whilst Verney may have been premature with some of his conclusions, the big picture and more importantly the process of strategic review remains valid, provided it is based upon reasonable data.
Demand Forecasting
Demand forecasting, probably the one topic area where we can all agree, that we can’t.
I must commend the ODPM however for striking a sensible approach to what has historically been an unnecessarily contentious subject.
We all need some form of estimate of likely demand to be able to form policy guidance.
It need not be unnecessarily mathematical but it needs to be sufficiently rigorous, realistic and quantitative to be credible to the main players.
Whilst the forecast may or may not be regarded as a target to be met, without it we would all be operating in an anarchic vacuum where the tensions would only be worse.
Those with long memories will remember the planning lottery which pre dated Verney which made it virtually impossible to plan a business or make a good planning decision.
Verney was right to advocate the need for forecasts but the real challenge lies in identifying the means of supply and more important, the location of supply.
Supply solutions
Verney’s supply solution for the SE recommended the release of a lot of sand and gravel bearing land in areas of high demand for 10 to 15 years while other solutions were put in place.
For the longer term he advocated the increased use of waste and more rail born supplies, better restoration to enable the release of higher grade sand and gravel bearing land, more marine aggregates and an examination of underground mining potential and the creation of super quarries.
These were profound conclusions and ideas some of which seem familiar and some which still seem ahead of their time.
Underground mining in Kent still seems far away and we have yet to go plural on coastal superquarries.
But the starting point has moved on and the industry has already evolved from the local production and supply business model of the 70’s to a hybrid model involving local, regional, national and even international supply of primary aggregates with local supply of recycled and regional supply of secondaries.
Furthermore, legitimate and illegitimate concerns about the impacts of supply on communities powerfully expressed by local, regional, national and international organisations means that the justifications for extracting and using aggregates needs to be more forcefully articulated.
Broadly speaking MPS1 can help provide this but neither it nor the anticipated annex is able to address the capacity of each element of supply to contribute beyond 2016, now less than 11 years away and less than half a generation.
So what are the sustainable supply scenarios for the longer term?
Recycled and Secondaries
Let us consider the alternatives first, which the QPA rightly regards as the first component of supply.
It finally appears to be broadly accepted that we are close to maximising the contribution that recycled construction and demolition waste can make, the issue being more about the availability of the waste and obtaining planning in key markets than the philosophy.
What we see now is probably not far short of what we will have to assume going forward.
We are around the 90% level of what is achievable.
Whether the secondary aggregates of slate, china clay, slag and mine waste can make much more of a contribution quickly is uncertain and to what extent remains debatable.
As our coal mining industry in England continues to diminish minewaste’s prospects lessen and with slate tips in north Wales now industrial heritage, some questions may need to be asked about the sustainability of these elements to supply long term.
But the industry has got the message and these materials will continue to make a steadily growing contribution over time but limited by poor infrastructure and logistics constraints.
In spite of the uncertainties QPA believes that achieving an annual contribution of 60mtpa for alternatives within the next 5 years is achievable but then that will be pretty much that.
And once the industry has maximised what can be obtained from alternatives there will only be primary aggregates left.
Now this statement of the blindingly obvious is worth pausing upon particularly if you are from certain environmental organisations and NGO’s.
Nobody can recycle away the need for quarries and primary aggregates.
Whether we like it or not at some point it would be very useful if we could at least agree in principle that once you have maximised alternatives, and unless the Government changes its newly endorsed manifesto of ‘Forward not Back,’ the future remains largely dependent upon primary aggregates. If not, it will be Back not Forward!
If we want to build sustainable communities, we need a sustainable aggregates industry with sustainable supply capacity.
So let’s run through it.
Marine Aggregates
Marine has genuine capacity to increase its contribution provided the licensing system can be made more effective and responsive and potential wharves are safeguarded in key markets.
Certainty is crucial to investment in replacement and new shipping capacity and currently this is not a feature of the existing licensing and planning system.
Marine must remain an essential element of supply but lead times are great and investments are large and assume a long term life is assured.
The industry can deliver the 20mtpa this component can make, and probably more, but to do so it needs more clarity and speed of process to give more certainty.
Which gets us brings us to the fundamental issue of access to our land won resources.
Land Won Sand and Gravel
I believe that if we had regional resource assessments on the lines that SERPLAN produced in 1988 we would discover that abundant potentially workable resources of sand and gravel remain throughout most regions of England.
I also believe that as our sustainable communities become even more effective at fighting each and every planning application for replacement greenfield sites that our ability to access them is likely to diminish.
If we need 80mtpa of land won sand and gravel in the future we can produce it, but only if allowed and only if we can maintain our ability to restore using inert wastes.
The current anti inert agenda practised by DEFRA and parts of the EA is of real concern and may ultimately govern the capacity that sand and gravel can contribute to supply in future.
Lack of inert waste for restoration could well mean no permission to excavate in the first place, especially if bird strike policies preclude water based restoration.
Crushed Rock
And what about the biggest component of supply, crushed rock, which currently represents nearly 50% of primary supply and nearly 40% of total supply?
Whilst we are fortunate that we have many significant rock quarries and many have latent extension potential, not all do and not all can make a contribution beyond their regional boundary.
Who understands this sufficiently well for us to be able to judge whether there is no problem and that existing supply patterns are secure for the long term or whether in fact many are entering the last chance saloon?
It is now over 25 years since any genuinely new major greenfieldrock quarry was permitted. In that time we have probably consumed the best part of 2.0Bnt of permitted rock reserves without meaningful greenfield replenishment.
Hands up all those with planning applications in preparation for new large inland greenfield rock quarries in middle England?
Imports
But there is no need to worry, Sven will sort it. Oh he will, will he?
So let us assume that Norway is a completely homogeneous lump of granite, which it is not, let us assume that its current level of exports of 11 mtpa of which the UK takes only 1.6mtpa increased tenfold to say 16 mtpa, then what?
Where could you get it in to England? Which ports could handle it? Which rail paths could handle it because our congested roads could not?
Imports have a role to play, they are part of a solution but it will be limited and limited by the capacity of the coastal infrastructure to receive and distribute to markets at acceptable amenity and environmental cost.
Even the Norwegian Government is saying and I quote ‘it can no longer be said that Norway has unlimited quantities of sand and gravel and hard rock’.
Conclusions
My conclusion for some time has been that like our national energy policy we need to keep all our supply options open.
No one component of supply has the capacity on its own to solve our long term supply needs.
There is no silver bullet.
We can not pretend that we can supply our long term aggregate needs without a lot more marine, local land won sand and gravel and crucially permitting some new large inland greenfield rock resources.
At the very least we should y recognise that existing rail connected quarries deserve to be regarded as nationally significant and if they can be extended they should be.
These issues can not be dealt with on an application by application basis. They can be touched on at LDF’s but only so far.
Only the RAWPS can gather the building blocks and enable the bigger picture to be established at a national level.
We need to be honest about resources, about the need to replenish them and the difficulties of doing so.
We need to be realistic when considering the capacity of alternatives to supply and the continuing imperative for around 200mtpa of primary aggregates, about 75% of our needs, to be produced year on year up to 2016 and in all probability for the next 25 and probably 50 years.
Pretending that recycling can do the job is like pretending that windmills can replace coal and nuclear power.
It will therefore take a more forceful political will than that which is currently fragmented in Government to stamp the national foot and say needs must in the future.
But to help build more confidence amongst a generally sceptical public the industry will have to continue to improve its environmental performance.
Whilst tremendous progress continues to be made there can sometimes be a gap between some of what we say and what occurs on the ground.
If the industry wants a long term future there can be no gap.
Clean roads, tidy entrances, good perimeters, no dust, no unnecessary noise, clean and professional haulage and good community engagement are the issues that matter to neighbours not corporate spin.
I believe that as an industry we need to become collectively intolerant of poor behaviour and performance.
It will take time to achieve best practice but as I said to this audience 4 years ago we must at the very least eliminate worst practice.
Equally there needs to be more recognition that we do a good job and when we do, it is normally very good. We have so much to be proud of.
In briefly revisiting the origins and heritage of our licence to operate I have learned a lot.
Some things never change but plenty of things do!
It is interesting that over time, about every 25 to 30 years, some form of strategic review takes place in the industry and it is now 30 years since Verney.
This is a long term business. These days we reckon that it takes up to 10 to 15 years to convert an exploration find into production.
When you buy a ship it is for 20 years when you open a quarry it can be for 40.
We are all familiar with the need to make local plans, 5 and 10 years is long for some businesses but for us it is now short to medium term.
The regional policy formulation currently in hand does seem to want to address the generational dimension and this is to be welcomed, but it needs to add up to a bigger more national picture.
Conclusions
Personally I do foresee serious potential production capacity shortfalls emerging as older quarries, mainly rock demise over the next 10 to 15 years.
I think I am thinking what Verney was thinking.
Whilst this does not mean that we need to panic it does mean that we need to be thinking about the possibility now.
Whilst Verney may have been a generation premature with his detailed demand and supply model for the SE, his view of the big picture was probably right and shifted the strategic thinking in the industry to ensure that supplies have not been a problem.
If we were to discover over the next 10 to 15 years that some 30 to 40mtpa of replacement annual capacity is required how would we respond?
Can we assume that Scotland or Norway could necessarily provide?
Abundance of resource does not necessarily convert into abundance of supply capacity. And even if it could, would it be right?
Surely we should look inward at what resources lie within our own continental shelf and coastline before we dump our NIMBYISM on somebody else’s doorstep.
Nobody has the answers to all these and many other pertinent questions but the question is are we best organised as an industry, and by that I mean all of us operators, planners, civil servants and some environmental organisations, or can we do better?
I believe we can.
Currently NCG is the only and arguably best place for a more strategic approach to be ndertaken.
I believe that we need to develop NCG into a better resourced and more energetic strategic body possibly a National Aggregates Forum which regularly contemplates the longer term and which continues to recognise the benefit of the work that Waters, Westwood, Stevens, and Verney did and develop it forward for the next generation.
The next 25 years will be crucial, I suspect it will be the time we all have to pay for the excesses of the past, certainly in energy and water and probably in waste.
I hope however that when it comes to aggregates we can look back and say Sir Ralph you are never going to believe this but….. we appreciated what you did and whilst you didn’t get it all right you did us all a favour and we are going to learn the lessons for the next generation.
02 - ‘Living with Minerals’, Published in Mineral Planning September, 2004
The Confederation of British Industry (CBI) Minerals Group is the only forum that exists that represents all the major land based mineral extraction
industries in the UK. Its membership spans the 2 major extraction sectors by tonnage, aggregates and coal and also the high value sectors of silica sand, cement, china clay, ball clays and other industrial minerals such as barytes and fluorspar. This represents virtually all of the 306Mt of land won minerals currently extracted in the UK. As such the minerals industry is the largest heavy manufacturing industry by tonnage left in this country and yet its existence, let alone its role and contribution is hardly recognised by the general public for whom the vital link between minerals and their quality of life has not yet been made and possibly never will. The CBI Minerals Group has 3 principal aims:
• To promote the role and importance of the UK Minerals Industry,
• To champion the UK Mineral Industry’s ability to meet the development needs of the economy in a sustainable manner,
• To influence proposed UK and EU legislation and regulation which significantly affects the Minerals industry and its licence to operate.
To achieve these aims we have to make sure that our key stakeholders recognise us, our role and our aims and be given the opportunity to listen to what we think and say. Hence the conference in June, which was intended to build upon the achievements of previous CBI Minerals Group initiatives such as Minerals 98 and ‘Minerals making more of life’ in 2002. This is not so much about the challenges or agenda of any particular product sector but about the industry as a whole. It is about recognising the role, value and contribution the entire industry makes to UK plc and more significantly how this can be maintained for the next 25 years, for the next generation, in the face of what the CBI Minerals Group believes is the big issue facing the industry, that of maintaining our ‘licence to operate’ over the long term. The conference title was a deliberate attempt to energise the industry’s stakeholders into recognising that our minerals are of local, regional or national importance and to ensure that the mineral needs of our economy can continue to be met for the next 25 years. This is a long term industry which has long lead times and whilst we have the current security of short and medium term supplies it is a good time to look further into the future, particularly over the next 10 to 25 years, to ensure that our current approach to accessing minerals is itself sustainable. It appears to us that too often the vital and intimate link between our mineral resources, the planning system and the economy is not well or widely understood and the advent of the new Planning Act is likely to constrain our access to our minerals even more in the future. We hope therefore that we can help all stakeholders appreciate this link better so that it is clearly understood that ‘Living without Minerals’ is just not an option.
It is our intention going forward to present more specific position papers pro-actively as a counterbalance to the largely unchallenged and often erroneous propaganda to which our industry is subjected. We recognise that we need to work harder to ensure that future policy decisions are based upon better balanced inputs which are more rigorously
challenged prior to policy formulation. One of the aims of the conference was to advise that our commitment to continuing stakeholder engagement is real, is growing and will be long term. Planning for future events such as this are already in hand, because quite
simply if we do not speak up for ourselves and try and get on the front foot no one else will. In short we do have our own open agenda and our aim is to promote it positively.
The minerals industry Let me make some short statements that are a blend of old chestnuts and some more contemporary sentiments which may serve to express some of our current positioning:
• Health and safety is our first priority.
• We are committed to the principles and practice of Sustainable Development.
• Our overcrowded island and its seas are still blessed with a wide range of
important and abundant mineral resources.
• We can only dig minerals where they lie, the closer to the end user the
better.
• We only borrow the land or sea bed.
• All industries, not just ours, give rise to impacts.
• Wherever you extract mineral whether at home or abroad it has an impact.
• We want to be good neighbours.
• We all need rules, preferably good and proportionate, reasonably and
consistently implemented.
• We are judged by our worst sites not by our best.
• The industry must become collectively intolerant of poor operational
performance.
• Profit is not a dirty word, provided it is a safe, clean, responsible and
sustainable one.
I have explicit instructions from my colleagues; we wish to be seen for what
we would like to think we are:
• Essential: living without minerals is not an option.
• Professional and competent: but with no sense of complacency.
• Responsible: its our world too and we have a duty of care for our people,
the environment and the communities within which we operate.
• Positive: we are far from perfect but neither are we demons, we want to
improve and we are improving.
• Engaging: we work in the community, we are part of it, we are not afraid of
it but we need to accountable if we are to earn the trust of communities.
• Sustainable: if all 4 pillars of sustainable development are taken properly
into account.
The industry’s aspirations are to be:
• Recognised: too few of our achievements are recognised,
• Valued: in terms of civilising life, creating jobs and wealth and contributing to bio and geo-diversity, and of course
• Maintained: to help build sustainable communities. Our starting point is that Society creates the markets which generate the demand for all products and services which in turn creates the ‘call upon our natural resources’ of which minerals is but one, but which like food and water is a necessity for civilised lif. Demand needs to be supplied unless the Government dictates otherwise. Demand management is not a lever of the industry it is primarily a political and economic tool for the Cabinet and the Treasury. Pre- supposing that it is accepted that whatever the level of demand, it will be supplied, the challenge for us all is from where and how. The industry’s role is that of responding to demand by proposing and providing sustainable supply solutions to its customers of which the Government on behalf of the public is by far the largest accounting for nearly half of all
demand. Planning It is the job of the planning system to balance the issues of need against social and environmental considerations to identify the location of the sources of supply and how they will reach markets. This is the delicate fulcrum upon which our entire industry depends, it is a complicated, subjective and uncertain tool with which to plan long term businesses and one which is prone to continual change. Planning decisions crystallise the link between demand and supply and quite simply for us ‘no planning means no business’. You might care to reflect upon some of the changes that have occurred over the last 10 years which all touch upon the architecture or implementation of the mineral planning system or our ‘licence to operate’ in some way:
• Removal of the presumption in favour of development to the plan led system.
• An increase in the presumption against development by local communities and
NGO’s and NIMBYISM.
• Continuous restructuring eg DOE to DETR and then DTLR, splitting of DTLR
into ODPM and DEFRA, sponsorship moving to DTI.
• Devolution.
• The advent of creeping Regionalisation.
• Environmental taxation.
• Growth in the need for environmental assessments.
• EU Directives on Noise, Vibration, Water, Mine Waste, Landfill, RTD, WTD.
• Growth in the power and influence of the Environment Agency.
• 10 different Ministers with the minerals planning portfolio.
• etc. etc.
Now if you are concerned with building conservatories or small house extensions this is not very profound. If, however, you are part of a primary industry which underpins the economy and you want to extend an existing mineral operation or start a new one, it is. The growing matrix of influences and increasing costs which now bear down upon just one planning application, which has to be determined by just one planning committee on a rainy Wednesday night in February is frankly overwhelming. We accept that it is never going to be easy to secure our permits but what is really scary is if it is this tough now, where will we be in 10, 15, 20 and 25 years time? Will we be looking back saying these are the good old days in the same way as I now look back with fondness to 1994. I thought it was bad enough then! With hindsight I realise that having all ones eggs in the DOE basket may not have been quite so bad after all. Perhaps it is time for the precautionary principle to be applied to this industry: not to constrain it further but to ensure that we are able to sustain it for the long term. We tend to be in damage limitation mode far too often because we are in a regulatory maze which just keeps getting bigger and where the hedges keep being moved by more and more gardeners! What can be done? I do not think it is unreasonable to consider whether the downside of the cumulative impact of endless disjointed regulation is beginning to outweigh the intended benefits. So what could be done, what do we really want and how could this be achieved?
Firstly what we can’t change:
• The growth of the influence of the EU.
• The growth of the influence of international NGOs.
• Continuing devolution within the UK and growing parochialism.
• A slower and more uncertain planning system.
• Continuing and more effective opposition locally to extensions and
particularly green-field sites.
• More liaison between local, national and international green groups and
local communities. So what do we want?
• A better strategic debate about the future use of UK mineral resources,
starting with a statement of what resources we have got, where they are and
how they can continue to be used to meet continuing demand.
• At the conference Lester Hicks launched a key document ‘The Economic
Importance of Minerals to the UK’ which could help inform this process and
which could be based upon the Royal Commission which Sir Ralph Verney chaired
with regard to the aggregates industry in 1976 which provided the blueprint
for the current mineral planning system.
• A more effective interface between the industry and Government. Whilst we
recognise that it is unrealistic to believe that all mineral issues could be
discharged through one national minerals agency we do believe that there is a
case for some form of National Minerals Forum which brings together the
industry, the County planners, the minerals teams in ODPM, DEFRA, DTI, and
also from the Welsh Assembly and the Scottish Executive to try and establish a
more coherent national overview of the industry.
• More effective Government sponsorship of the industry across all mineral
product groups. Currently sponsorship is fragmented and under-resourced, it
would benefit from consolidation into one focal point to strengthen the
interface with industry.
• Develop the excellent response by Government and Industry with regard to the
Mine Waste Directive as the best practice model for influencing future EU
Directives
• Clarify the way the proposed changes to the planning system will actually work, particularly between the Regions and the Counties especially if Regional Governments exist in some areas but not others and if by default the new regime institutionalises parochialism. The current permutations going forward are creating great uncertainty for all stakeholders.
• Strengthen and make permanent the role of the ODPM minerals and waste team and ensure that it survives in any subsequent departmental changes. Without this team the interests of the industry would be severely setback.
• Audit the cumulative impact of endless disjointed regulations which work against each other and jeopardise the contribution the industry makes to sustainable development particularly with regard to the restoration of mineral workings and the link to the future release of mineral resources.
• Improve the training of elected representatives in the Regions and Counties in mineral matters. The industry would be happy to invest in such a process in liaison with other key stakeholders.
• Increase the funding and resourcing of County mineral planning departments, these people deserve a better deal and less uncertainty. They represent a valuable asset and pool of expertise which whilst often infuriating is nonetheless precious and difficult to replace.
• Create a joint Government - Mineral authority - Industry best practice guide to remove endless debates application by application on technical issues relating to operational management. Let’s agree the gold standard and just get
on with it.
• Create Regional and County mineral stakeholder forums to enable communities
and other stakeholders to ventilate their concerns within an informed and organised environment.
These are just a selection of the proposals that the Industry believes are
available to improve the way we manage mineral planning issues compared to the
ever changing and very fragmented approach which we have to deal with currently. Our suggestions are intended to send out the message that whilst we want engagement, it needs to be more effective at all levels. We want to play our part in delivering the Governments agenda for building sustainable communities but to achieve this we need to re-engineer the interface between the industry and Government whether nationally, regionally and locally and also with other stakeholders and communities.
If changes are not made we will begin to witness supply difficulties emerging over the longer term. Waiting for possible supply problems to emerge is not a prudent approach to resource management and conflicts with this important element of the UK’s policy for sustainable development. To be able to progress these issues it is vital that an urgent review takes place now and in a way that is more resistant to the continual changes within the planning system on the scale that have been witnessed over the last ten years. I am confident that more effective engagement on the lines I have outlined on behalf of the industry would increase the likelihood that the valuable contribution that this wonderful industry makes to this nation’s quality of life can be maintained in a sustainable way for the next 25 years and hopefully beyond so that we are all able to not only live with minerals but continue to live the way we do because of minerals. If we get it right anything is possible.
Living with minerals may be challenging, but living without them is not an option. Now, more than ever, there is a need for debate about where the building materials of the future will come from.
Who really creates the demand?
Facing up to supply realities
Time for a better debate
What does the industry want?
The existing tension between the minerals industry and those opposed to mineral extraction is largely unproductive and undesirable. Mineral developers are typically perceived as heartless capitalists with no respect for communities and the environment, and environmentalists are seen as opposed to anything and everything. Whilst neither perception is really justified there is little evidence to suggest that this relationship is evolving into something more constructive. Given the importance of sustainable mineral supply to each and everyone of us, our economy and our way of life there is an urgent need for better mutual engagement on the key issue of access to minerals. The steady provision of our mineral needs is vital but is potentially in jeopardy over the longer term as the cumulative impact of ill-considered or fragmented legislative constraints and local opposition increasingly stifle the industry’s ability to provide sustainable supply solutions to meet our demand.
Who really creates the demand?
My starting point is that Society - that is each and everyone of us, creates the markets which generate the demand for all products and services. It is this demand which creates the ‘call upon our natural resources’ of which minerals are but one, but which like food and water are a necessity for the way we live in the UK. Demand needs to be supplied unless the Government dictates otherwise. Demand management (ie. managing society’s need for minerals rather than supplying whatever is demanded) is not a lever of the industry it is primarily a political and economic tool for the Cabinet and the Treasury. The industry does not create our demand. Pre-supposing that it is ultimately accepted that whatever the level of demand, it will be supplied, the challenge for us all is from where and how.
The industry’s role is that of responding to demand by proposing and providing sustainable supply solutions to its customers of which the Government, on behalf of the public, is by far the largest. Delivering the Government’s social and economic agenda accounts for nearly half of all demand as a result of improving our national infrastructure, ie. our roads, railways, schools, hospitals and social housing. It is the job of the planning system to balance the issues of need for mineral against social and environmental considerations to identify the location of the sources of supply and how they will reach markets sustainably. This is the delicate fulcrum upon which our entire industry depends. It is a complicated, subjective and uncertain tool with which to plan long-term businesses and one which is prone to continual change. Planning decisions crystallise the link between demand and supply and quite simply for us in the industry, ‘no planning means no business’.
Facing up to supply realities
The recent planning decision at Rodel on the Isle of Harris is but one example of such decisions. The fact that Lafarge Aggregates has since terminated its interest in the Rodel site does not mean that the problem of sourcing medium and long-term supplies of mineral to meet the UK’s future demand has gone away. Indeed, without numerous new greenfield quarry sites being currently identified for the longer term the problem is compounded. Now, more than ever, there is an urgent need for a serious debate about where the building materials of the future will come from. The aggregates industry is finding that it is becoming increasingly harder and taking longer to secure permissions for major extensions, and in particular new greenfield sites, for extraction.Currently annual total UK demand for aggregate is around 260m tonnes, approximately 60m tonnes of which is obtained from recycled and secondary aggregate material. Of the 200m tonne demand for primary aggregate, 120m tonnes is rock and 80m tonnes is sand and gravel.With demand likely to continue at these levels for the next 15 years or beyond, long term sustainability of supply is emerging as an issue due to the constraints placed upon sources of supply as a result of the cumulative impact of increasing regulation and legislation and local opposition.
Securing new rock quarries to replace the future decline in production capacity of existing rock quarries is already extremely difficult and will only become more difficult over time. Local land-won sand and gravel is already a highly controversial issue and will only become more so. Securing marine sand and gravel is not without its own environmental challenges and, notwithstanding the potential availability of significant resources, there are infrastructure and logistical constraints which prevent the ability of marine sources to fully offset any future decline in land won sand and gravel. As for recycled aggregates, it is recognised by Government that the industry has now reached about 90 per cent of what can usefully be recycled; indeed, the issue for the industry now is securing sufficient material of the right quality to recycle.Whilst there are significant resources of secondary aggregate potentially available they remain distant from key markets. Quality issues and logistical and economic challenges will also inhibit the ability of these sources to make a dramatic increase in the contribution that they can make to meeting emand.Importation of material from other countries is not the great hope that many would like it to be due to geological, quality, and logistical issues which mean that whilst overseas sources can make a contribution, this may not be as significant in capacity terms as some would have thought. Irrespective of these technical and economic considerations can we really justify exporting our environmental costs when we have so much undeveloped resource of our own? Consequently all existing components of supply have constraints and limitations going forward which means that no single supply element in itself has the ability to solve any future declines in production capacity.
Time for a better debate
The industry’s stakeholders and Government need to understand the critical distinction between the superficially abundant level of consented reserves that exist in the UK and the actual geographical distribution and sustainability of production capacity around the country. Only then can we really start to appreciate that a potential supply issue in 10 to 15 years time requires addressing now, particularly in the light of the imminent changes to the planning system, which whilst well-intended are likely to slow down and further complicate the existing mineral planning process.If it has taken Lafarge Aggregates 15 years not to be able to replace just one of its major quarries, so how long will it take to replace the production capacity of all the major quarries in the UK in future? The aggregates industry underpins the delivery of the Government’s, and both the local authority and the private sector’s development objectives. It is vital therefore that all stakeholders who have a genuine interest in the sustainability of these agendas engage in a more mature public debate to ensure that the collective development interests of the UK are sustained for the next generation. It is not acceptable any longer for this important component of our economy and our way of life to be debated in the tabloid terms which seem to accompany all new mineral planning applications. We all deserve better. Consider some of the changes that have occurred over the last 10 years which touch upon the mineral planning system in some way, such as the removal of the presumption in favour of development to the plan led system, the advent of devolution, growing regionalisation, environmental taxation, and more and more EU Directives. This is in addition to the endless changes within Government with regard to the management of minerals and at least 10 different ministers in as many years!
Is it any wonder that the industry feels as if it is having to run faster and faster just to stand still? We accept that it is never going to be easy to secure our permits but what is really scary is if it is this tough now, where will we be in 10, 15, 20 and 25 years time?
What does the industry want?
So what do we want, what do we think would make a difference? Here are some suggestions which the industry is promoting in an attempt to take the issue forward in a positive and pro-active way.A strategic debate about the future use of UK mineral resources, which could be based upon the 1976 Verney Royal Commission on the future the provision of aggregates and which provided the blueprint for the current mineral planning system.A more effective interface between the industry and Government involving some form of National Minerals Forum to try and establish a more coherent national overview of the industry.More effective Government sponsorship of the industry; currently sponsorship is fragmented and under-resourced, it would benefit from consolidation into one focal point to strengthen the interface with industry.Clarification of the way the proposed changes to the planning system will actually work, particularly between the Regions and the Counties in England, especially if Regional Governments exist in some areas but not others and if by default the new regime institutionalises parochialism.An audit of the cumulative impact of endless disjointed regulations which work against each other and jeopardise the contribution the industry makes to sustainable development, particularly with regard to the restoration of mineral workings and the link to the future release of mineral resources.Improve the training of elected representatives in the Regions and Counties in mineral matters to improve their understanding of minerals issues. The industry would be happy to invest in such a process in liaison with other key stakeholders.Increase the funding and resourcing of County mineral planning departments. They represent a valuable asset and pool of expertise which whilst often infuriating is nonetheless precious and difficult to replace.
Create a joint Government/Mineral authority/Industry best practice guide to remove endless debates, application by application, on technical issues relating to operational management. Let’s agree the gold standard and just get on with it.Create Regional and County mineral stakeholder forums to enable communities, NGOs and other stakeholders to ventilate their concerns within an informed and organised environment.
These are just a selection of the proposals that the Industry believes would improve the way we manage mineral planning issues compared to the ever changing and very fragmented approach which we have to deal with currently. The industry wants to play its part in delivering the Government’s agenda for building sustainable communities but to achieve this we need to re-engineer the interface between the industry and Government whether nationally, regionally and locally, and also with other stakeholders and communities. If changes are not made we will begin to witness supply difficulties emerging over the longer term. Waiting for possible supply problems to emerge is not a prudent approach to resource management and conflicts with this important element of the UK’s policy for sustainable development.More effective engagement on the lines I have outlined would increase the valuable contribution that our industry makes to this nation’s quality of life. If such an approach can be maintained for the next 25 years we will all be able to not only live with minerals, but continue to live the way we do because of minerals.
04 - ‘Lingerbay': The future has been cancelled,Published in Mineral
Planning June, 2004
“The Rodel decision does not mean that the problem of sourcing medium and long-term supplies of mineral to meet the country’s demand has gone away. Indeed, without sites like the one proposed on Harris the problem is now compounded. Now, more than ever, there is an urgent need for a serious debate about where the building materials of the future will come from.“The aggregates industry is finding that it is becoming increasingly harder and taking longer to secure permissions for major extensions, and in particular new greenfield sites, for extraction.“Annual UK demand for total aggregate is around 260Mt, approximately 60Mt of which is obtained from recycled and secondary aggregate material. Of the 200M demand for primary aggregate, 120Mt is rock and 80Mt is sand and gravel. With demand likely to continue at these levels for the next 15 years or so the
issue of longer-term sustainability of supply is beginning to emerge.“Securing new rock quarries to replace future declining capacity of existing rock quarries is already extremely difficult and will only become more difficult over time. Local land-won sand and gravel, which is already highly controversial, will only become more so over time. Securing marine sand and gravel is not without its own environmental challenges and, notwithstanding the potential availability of significant resources, there are infrastructure
constraints which prevent the ability of marine sources to fully offset any future decline in land won sand and gravel.“As for recycled aggregates, it is now acknowledged by Government that the industry has reached about 90% of what can be usefully recycled. Whilst there are significant secondary aggregate resources they remain distant from key
markets and therefore have logistical and economic challenges.“Importation of material from other countries is not the great white hope that many would like it to be due to geological, quality and logistical issues which mean that whilst it can make a contribution, this may not be as significant as some would have thought. “Consequently all existing components of supply have constraints and limitations going forward which mean that no single element in itself has the ability to solve any future declines in production capacity.
“The industry’s stakeholders and Government need to understand the distinction
between consented reserves that exist in the UK and the geographical distribution and sustainability of production capacity around the country. Only then can we really start to appreciate that a potential supply issue in 10 to 15 years time requires addressing now, particularly in the light of the changing planning system, which whilst well-intended is likely to slow down and further complicate the existing mineral planning process.“This situation is further compounded by challenges to the sustainability of land won sand and gravel, for which abundant resources remain within the UK but which are seriously at risk due to the ‘triple-grip’ created by the Environment Agency’s landfill location policy, its implementation of the EU Landfill Directive which amounts to an anti-inert landfill policy, and the Civil Aviation Authority’s new bird strike policy.“These three measures potentially sterilise the release of sand and gravel resources in river valleys by preventing both conventional progressive restoration using inert soils and clays, and restoration to wetland
conservation and recreation because of the understandable risks to the interests of aviation. Not only is this a mineral resource availability issue but is also jeopardises the excellent record of the industry to recycle land for beneficial afteruse which will significantly reduce the contribution to biodiversity which the industry currently makes.
“The aggregates industry underpins the delivery of Government, local authority and private development and infrastructure schemes – it is vital therefore that all stakeholders who have a genuine interest in the sustainability of the industry engage in a more mature public debate to ensure that the collective development interests of UK plc are sustained for the next generation."
05 - ‘Sleeping with the enemy’, Construction News, 17 June 2004
Construction News17/06/2004
Alasdair Reisner
In April this year Lafarge Aggregates finally pulled out of plans to develop a coastal 'superquarry'on the Isle of Harris in Northern Scotland, bringing to an end the longest public planning inquiry in Scottish history. Alasdair Reisner talks to Lafarge Aggregates executive director Nigel Jackson about the decision and his plans for the firm's future CONSTRUCTION had an interesting year in1991.The Channel Tunnel reached a key point as French and British workers broke through on the project's final tunnel.Hopes were raised of a boom in work in the Middle East following the end of the first Gulf War, while at home the industry suffered the worst of the early 90s recession.
1991 also saw Redland Aggregates lodge a planning application for a massive quarry on the Isle of Harris in Scotland. It is unlikely that those involved would have guessed that there would be another Gulf War, start of work on a high-speed link to the Channel Tunnel and that Redland Aggregates would cease to exist by the time any conclusion would come from the application. If they had known what the outcome would be they probably would not have bothered in the first place.
"It was a major disappointment that a near 15-year case didn't result in approval, " says Lafarge Aggregates' executive directorNigelJackson. In April the firm he heads up, which bought out Redland in 1998, finally pulled the plug on the Harris application in the face of stiff opposition from environmental lobby groups.
At the time MrJackson sounded a warning that the decision could contribute to a falling-off in the minerals industry to supply sufficient aggregates to meet the demand of the UK construction industry.
Is this still his feeling now?
"The Harris case casts a shadow over the role coastal sites will be able to make going forward. The question for the Government over the next 10-20 years is whether it thinks capacity in the industry is sustainable in the long term, given that it is becoming harder and harder to secure permissions, " he says.
It is understandable that MrJackson is unhappy about how things panned out for the Harris superquarry. As it stands Government policy promoted the development of coastal quarries to replace many of the industry's largest inland operations. While many of these inland quarries are still producing material at an impressive rate, the current planning system means that few new green field sites are likely to be given the go-ahead.
Extensions to the existing sites are also still an option but clearly there are limits to how far you can extend even the largest sites. New alternatives must be found.
The wind seemed to be behind Redland when, following the planning inquiry, the inspector found in favour of the Harris quarry. But, with devolution in the late 1990s, the new Scottish Executive declined the inspector's recommendation, finally leaving Lafarge to exit the battlefield rather than fight on in vain.
In May the new Planning and Compulsory Bill Act received its royal assent, promising to smooth the way for future planning applications, including those for new quarries. Something to rejoice about for the aggregates industry surely? MrJackson is not so sure.
He says: "The Act is supposed to make the system simpler, quicker and more responsive. The industry supports all of those objectives but the Act calls for more community involvement in line with the Office of the Deputy Prime Minister's policy on sustainable communities. I have no problem with working with communities but it will mean the process is not quicker and probably not easier."
MrJackson fears the regulations will usher in red tape that will slowly strangle the industry.
He says: "There is talk that you could have a public inquiry about the statement of community involvement, which will detail how local people and businesses will be involved in local authority strategic planning.
Theoretically you could have a public inquiry for the mineral development framework, one for the statement of community involvement and still end up in another over your actual application. That does not sound quicker."
Yet, if MrJackson sounds frustrated by the system, he is surprisingly unwilling to turn his guns on one major source of his problems - the environmental groups.
"I understand environmental groups expressing deep concerns about the potential impact the industry may have on specific sites in certain areas. It is the job of the planning system to balance the issue of the need for materials with environmental and social issues. The only thing I would ask for from people who are opposed to our business are legitimate and reasoned arguments, as opposed to rhetoric and emotion, " he says.
So, post-Harris, where does the future lie for Lafarge Aggregates?
"The number one objective is to keep the business we have sustainable, while creating value for money for our shareholders. We create that value through better products and services for our customers and by taking materials up the value chain, " says MrJackson.
MrJackson says that the aggregates industry in general is quite prepared to move towards a more sustainable future.
He says: "The world is changing and the industry is changing with it. Opposition is growing and I think we have to take it on.
We should not do this by tackling our critics head-on but by leading them to an understanding of our needs and by our understanding theirs.
Everyone just has to get on board."
While the idea of forging closer links with those organisations that have done everything possible to prevent further quarry development may seem unusual, it is clear that such a move is essential if the UK quarrying industry is going to have a successful future.
Whether the environmental lobby is prepared to make a similar commitment remains to be seen
06 - ‘I’d rather be a regulator than an operator’,Published in Mineral Planning, December 2002, based on paper given at Savills waste management conference
at the Royal Society.
My inspiration for the title, if inspiration it be, is borne of frustration
after nearly 20 years of fighting for the ability to continue to landfill
inert waste to enable the restoration of mineral workings or as I would prefer
to call it the ‘recycling of land’ and the apparent blind spot our national
Waste Strategy has in failing to acknowledge our real achievements as a result
of inert landfilling and recycling whilst at the same time legitimising
ridiculously high levels of unlicensed waste disposal.
My waste management emphasis will be confined to inert waste as I believe the
subject gets too little attention given it’s significance both to the minerals
and waste management industries and to the nation’s commitment to sustainable
development.
My context is landfilling within the aggregate industry, mainly sand and
gravel, and the obvious but apparently invisible thread which weaves
extraction, inert landfilling and ultimately sustainability together. I also
have one or two observations to make with regard to the recycling of
construction and demolition waste.
Why would ‘I rather be a regulator than an operator’? What I really mean is
that if once upon a time it was an operator’s world those days are now over
and it is now definitely the era of the auditor and the regulator.
Let me show you life through the lens at my end of the waste management
telescope in the hope that you will appreciate that it is not necessarily a
distorted view, merely an observation of what I see and what I experience as
an operator trying to deliver my planning and waste management obligations.
To be able to operate an inert landfill in this country will normally
necessitate the creation of a void typically as a result of some type of
mineral extraction. We all know the minerals mantra that we ‘can only dig
minerals where they lie’ but few seem to have picked up the landfill mantra
that we ‘can only landfill where we have extracted’.
The vast majority of surface extraction is for aggregates of which
approximately 210Mt is dug each year of which 85Mt of sand and gravel, my main
focus, is extracted from around 750 sites, typically located on river gravels
or glacial and plateau gravels.
Consequently before one can even contemplate the prospect of inert landfilling
the full rigour and torment of the mineral planning system must first be
overcome.
We could of course bemoan the inadequacies of the current planning system and
the politics of minerals, and dwell on the implications of the current
planning Green paper, which I believe will throw all the old cards in the air
in the certainty that however they land it will only make life worse for the
waste and minerals industry but I do not, you will be relieved to know,
propose to go there.
But you should be reminded that from a waste and mineral operator’s
perspective we are currently only governed by some: 30 Acts of Parliament; 30
sets of regulations; 24 PPGs; 13 RPGs; and 15 MPGs.
In the last 18 months or so we have only had to consider 50 consultation
documents, 150 development plans, and 50 LEAPs, whilst monitoring progress in
35 counties and 260 districts not to mention what is happening in Cardiff,
Edinburgh and Brussels.
According to the Waste Strategy the waste industry itself is only regulated by
21 Acts of Parliament; 38 waste related directives and 3 major waste policies.
Not to mention the much loved European noise, vibration, groundwater,
environmental liability, mining, chemical and landfill directives all of which
are live and stressful issues.
I could go on, but by this point I am so exhausted that as an operator I am
not sure whether I really care about the finer points of the UK Waste Strategy
as it is unlikely to make our primary task of obtaining planning permission
for void creation any more likely or any quicker.
In my business world we are now having to plan 10 to 20 years ahead to allow
for the democratic inertia we have created to grind its inexorable course
before we even get to really play the waste management licensing game.
At this point you can imagine how absolutely delighted we feel to discover
that the landfill directive has precipitated the need for information already
provided to be reformatted and resubmitted as a site conditioning plan which
may, as I understand it, be determined sometime before 2007.
Please do not misunderstand me, I have no particular beef about the principles
of operational and environmental continuous improvement and seeking and
sharing best practice. These are powerful enough forces within the corporate
sector in their own right.
But add to this measure after measure each of which in its own way can
jeopardise years of effort and planning and you end up with a regulatory
burden which is frankly overwhelming given the dimension of the process
actually being regulated ie unloading a lorry load of mainly clay into a void.
The regulations intended to contribute to our sustainability are now so
convoluted and disconnected that they are beginning to jeopardise one of the
best environmental stories our industry has tried hard to tell but one to
which it seems no one is listening.
It appears to me that the cumulative impact of a seemingly endless succession
of fragmented initiatives and regulations is never taken into account as noone
within the regulatory framework either needs to or is suitably positioned
to be able do so.
Regrettably being on the receiving end the operator is only too well aware.
Even if my science is good, my integrity is intact and my heart is in the
right place I find it difficult to keep up with everything that is expected of
us.
In reality the emphasis needs to focus on the practical measures in place
during the phase between unloading a lorry and the moment the waste enters the
void. Notwithstanding the Duty of Care it is on site waste management and
inspection that is and will remain a large part of the thin blue line that
separates us all from damaging our environment with your waste arisings.
Whilst I am happy to invest reasonable resource in preventative management
measures I am almost at the point where I would be happy if we had one
universally enforced rule for all sites which said the operator will employ at
least say10 more competent persons on the landfill itself rather than invest
any more time and effort on the theoretical, scientific and administrative
side of the process.
I am not sure that the empirical evidence justifies the extreme lengths the
industry is having to go to given the job it is having to do, particularly in
the light of the complete lack of meaningful regulation of the unlicensed
sector. Surely a better balance is both necessary and justified?
I have referred to the obvious but invisible thread that weaves its way
between sand and gravel extraction, inert land-filling and sustainability.
Consequently I have a problem. I disagree with some of the philosophy and
thinking which underpins the UK Waste Strategy in relation to Construction and Demolition (C&D) wastes and inert land-filling.
I also think that it is deeply regrettable that minerals and waste issues now
reside in two Government departments as opposed to one as this formally
confirms the lack of understanding and recognition within Government as to the
hand in glove relationship that exists between the two sectors particularly
with regard to inert wastes.
Incidentally I do not think it is satisfactory that the Strategy document
which is supposed to provide the basis for waste management thinking in this
country does not even provide an all embracing summary of all waste arisings
at the outset. Furthermore I think it needs to be right up front that there are actually two
waste management industries operating side by side. One which is licensed and
operates under the full weight of regulation and environmental control and one
which is legitimately unlicensed and does not. If we are genuinely concerned
about the environment in a post landfill tax world this important distinction
should be clearly identified if the Strategy is to have any credibility at
all.
My main focus however is the 73Mt of C&D waste we produce or 17% of our total
waste stream of which 20Mt goes to unlicensed sites representing 28% of the
total C&D waste stream and a very significant ‘missed opportunity’.
Just to remind you, C&D waste is defined in the Strategy as ‘mostly brick,
concrete, hardcore, subsoil and topsoil’ and inert waste is defined as waste
which when deposited in a landfill does not undergo significant physical,
chemical or biological transformations. Note the absence of the word ‘clay’, a
topic to which I shall return.
The main thrust of the thinking behind the Strategy is to reduce our reliance
upon landfilling as it is a missed opportunity, there may be better options,
the materials could be usefully recovered and we need to improve our overall
resource efficiency ie squeezing more and more from less and less.
In general terms this is difficult to argue with and I certainly would not in
relation to non- inert wastes.
Where I part company with the Strategy is with the inference that all landfilling
is the same, the insinuation that it is all equally bad and the
failure to recognise the major benefits that can arise as a result of the
land-filling of inert wastes and the better than admitted achievements of the
industry in relation to the recycling of C&D waste.
Now I am sure that there may be some weasel words lurking somewhere deep in
the text to deal with all this. But why isn’t it up front and why aren’t the
good news stories set out properly so that these landfill and recycling
stories are put in context and have accuracy and balance?
On an overcrowded island such as ours where we are challenged by difficult
environmental and economic choices such as nuclear energy versus carbon, urban
renewal or rural decline, organic agriculture versus engineered I think we
deserve a more informed and honest debate about waste management than that
currently prevailing.
In my opinion the land-filling of inert wastes can be and normally is a good
thing provided it is done properly and provided we only dispose of the non
recyclable elements of the inert waste stream. I am proud of the projects I
have been involved with and I have no shame in showing the public what we do
and how we do it. We receive industry awards for many of our schemes, awards
given out by Ministers who congratulate us on the one hand and legislate
against us on the other.
What is one to make of it? My proposition goes like this.
Society needs primary resources, food, water, energy and raw materials.
Currently it remains Government policy that the Construction industry receives
the steady and adequate supply of the minerals it needs.
We extract 85Mt of sand and gravel each year and although this represents less
than 0.20% of our surface area it is still a big earthmoving challenge if we
are to fulfil our planning permission obligations each year.
We do not refill all quarries and we do not completely refill those we do so
let us assume that overall we need to refill say 65% of the sand and gravel
void created by extraction to enable restoration to take place.
I crudely estimate that based on the above assumptions the industry requires
approximately 47Mt of ‘something’ each year if it is to be able to sustain its
existing acknowledged but largely unrecognised restoration achievements.
The key to this is the supply of inert wastes it has historically received,
supplemented by quarry waste where it is available.
According to the only reasonably authoritative quantitative work done to date
on Construction and Demolition wastes undertaken by Symonds we are currently
land-filling somewhere between 18 and 30Mt per annum if we include materials
used for engineering and restoration.
I estimate therefore that we are between 17 and 29Mt per annum short of where
we really need to be unless we are going to return to the typical restoration
solutions of the 1970’s of low level restoration or lakes which we were so
roundly criticised for.
Whatever the actual detailed figures are we basically need every tonne we can
get which accords with our experience on the ground with regard to the
creeping restoration backlogs that have emerged post landfill tax and still
exist even since the exemption for restoration of mineral workings took effect
in 1999.
The shortfall in waste required by the licensed sector is directly
attributable to the loss of the 20Mt per annum being driven out of the
regulated system to unlicensed sites since the landfill tax came in.
This material has been driven over the last 6 years to the now well documented
tax avoiding activities such as golf course construction, acoustic and
landscaping bunds and good old agricultural improvement better known as landraising.
All legitimate activities exploiting paragraphs 9 and 19 of the Waste
Management Licensing regulations of 1994.
Prior to the introduction of the landfill tax the industry warned the
Government that with a two tier waste management framework (ie licensed and
unlicensed sites) the tax would drive waste, and not just inert waste, out of
the regulated part of the industry into the unregulated sector and so it has
proved to be.
As one of the industry team who fought with and finally negotiated with the
Government to secure the exemption for inert material required for the
restoration of mineral workings I thank them for listening but be aware that
it was Customs & Excise who really did the hard work and not the then DETR.
However the new exemption was only ever going to do part of the job. The
remaining issue was to try and get the exemptions in the Waste Management
Licensing regulations sorted out to close off these loopholes. Well so far we
have made no progress but like most things in this Government I believe the
situation is under review!
I find it very disappointing however that the Strategy does not enshrine the
hard lessons learned between 1996 and 1999 and acknowledge the difficulties
being created by the exemptions and recognise the importance of inert waste in
relation to the restoration of mineral sites.
Society needs aggregates, and aggregate sites, mainly sand and gravel sites,
need inert waste to deliver restoration as its crowning contribution to the
UK’s sustainability agenda. This chain of benefits is in jeopardy because of
ill thought through and disconnected regulation which at the same time
effectively drives waste to the unlicensed sector often to the unscrupulous
who do not care for the environment.
And one of the main keys to all this is clay. The one word missing from the
Strategy’s own definition of C&D waste.
I am not remotely interested and nor is the industry in land-filling brick,
concrete, glass, and hardcore; all we really want is the soft, non recyclable
element which is predominantly clay, clayey materials and clay bound mixtures
which will contain the harder brick and concrete fraction but can not as yet
be separated economically. Such materials I would argue meet the Landfill
Directive definition of inert but possibly not our own proposed classification
as currently laid before parliament.
I see the waste stream quite simply as 2 main fractions, recyclable and nonrecyclable.
It is the non -recyclable fraction that not only could be landfilled
but should as it is essential for the restoration of mineral sites.
The recyclables have already been elevated by the minerals industry to the top
of the aggregate supply chain. The Quarry Products Association announced to a
fanfare of complete silence in 2001 that in future the first tranche of
aggregate supply should come from recycled and secondary aggregates and then
and only then should primary extraction follow. It was a profound
repositioning in thinking; so profound that all the green groups and even our
own Ministers have been slow to openly acknowledge it.
We need to wake up and think straighter. We should eliminate the unlicensed
tax busting loopholes to drive more waste back into the regulated sector. The
minerals and waste industry will split the waste stream so that the UK gets a
double sustainability dividend by the recycling of materials in concert with
the recycling of land.
I ask that in future the Waste Strategy openly acknowledges that rather than
taking a politically casual and inaccurate stance in relation to what is
called land-filling, inert land-filling which enables mineral sites to be
restored is re-branded recycling of land which has equal merit in terms of the
hierarchy of waste management as the recycling of materials and rather than
try and regulate it out of existence we should try and manage it so that it is
a recognised secure and valued opportunity.
I do not propose to hold my breath! particularly since the last election as we
now have to convince both the planners at the DTLR (now ODPM) as well as the
waste people at DEFRA .
Win or lose the strategic arguments, is the industry likely to be able to
continue to meet its existing planning and restoration obligations? I have a
bad feeling that it will not. Notwithstanding the securing of the inert
restoration exemption the running sore of the unlicensed sector is still
diverting valuable and much needed waste away from licensed sites.
To add insult to injury we have been battling with DEFRA to secure open
recognition that clay be defined as inert within the waste acceptance criteria
and having believed that this was finally acceptable we discovered only once
the Statutory Instrument was laid before parliament that clay had been
omitted.
We are now reliant upon the supporting guidance notes and their consistent and
reasonable interpretation and implementation by the Environment Agency across
the country. I am naturally sceptical as I believe that the Environment Agency
is overtly anti inert sites and in their new PPC world there will only be non
hazardous sites which effectively means that in the eyes of the public all
landfills will be the same!
Just how we are going to engender confidence in a suspicious public eye that
our non-hazardous site is an inert one and not a putrescible one at the
planning stage I do not know. This has serious implications for the release of
future sand and gravel sites as restoration to low level or to water is often
not an option in land use policy terms. The fear and uncertainty generated by
the term ‘non hazardous’ will unfairly prejudice the consideration of already
controversial mineral applications.
Of course it might prove academic because even if we overcome this hurdle the
Agency will probably object if the site lies in a river valley anyway by
virtue of their new landfill location policy which seems unilaterally
unreasonable given the lack of unpublished rigorous evidence that 2000 years
of relatively unregulated landfilling has materially damaged or impeded the
water environment.
All this assumes of course that we can operate at noise levels authorised in
the noise directive or a revised MPG 11, or at vibration levels implicit in
the vibration directive.
This endless conveyor belt of regulation where no single body stands back to
assess what the cumulative affects are upon essential industries or our
sustainability will eventually catch us out by which time it will be too late
to unravel the Gordian knot of legislation.
I can see the combination of the landfill directive and the Agency location
policy significantly reducing the industry’s ability to seek and secure
eminently workable sites for sand and gravel because of the difficulty of
obtaining waste for restoration, throwing the aggregate supply burden back
onto rock quarries which are not being replaced.
There is little long term comfort to be had believing that marine supplies or
imports can help us export our supply problems so of course it is assumed that
recycling and reuse will provide the answers.
I shall not dwell on the anticipated growth in the reuse of china clay, slate
or colliery spoil; suffice to say that it will make a growing contribution to
aggregate supply. Probably at about the same rate that quarry waste will
increase within quarries as its marketability reduces as a result of the
introduction of the aggregates tax.
I think it is becoming an increasingly mad world with one apparent solution
creating a problem somewhere else but in a fragmented regulatory environment
where it is difficult to know precisely what is happening.
With regard to recycling, the facts are rosier than the Government finds it
convenient to admit. The poor performance on the recycling of non inert waste
dominates waste policy thinking but unfairly tars our brush where quite
frankly the recycling debate is now old, albeit good, news.
The figures show that recycling levels were already at reasonable levels and
growing prior to the first economic driver, the landfill tax.
Since the tax was introduced the rate of growth has increased but I suspect
this has only accelerated a process that was already in hand. Nonetheless I
think that now that we have some quantitative data our performance is
surprisingly better than some previously critical pundits fully appreciated.
There is no room for complacency however and companies such as my own, which
is now operating 28 sites with planning approvals for a further 5 in hand, are
seeking permissions in areas where availability of the feedstock is sufficient
to support an economic operation.
Our own recycled outputs are in excess of 1.0Mtpa and rising but there is a
limit to how far we can go given that ideally we want permissions on inert
landfill sites to enable the recycling of material to take place in parallel
with the recycling of land in areas of plentiful feedstock.
We still struggle to get permissions on mineral and landfill sites
particularly in the Green Belt and it would undoubtedly assist the government
and the industry achieve maximum potential sooner if recycling was given the
same planning presumption in the Green Belt as minerals currently enjoys.
Although knowing our luck that will be the next cut into our marrow.
Benchmarking our primary and recycled aggregates consumption per capita
compared to our EU partners shows that we are only bettered by the Dutch on a
per capita basis although what is not often mentioned is that their total
aggregates consumption is only 47Mt and ours is 250Mt of which nearly 30Mt is
now recycled. Are we comparing cheddar with goudas?
If, however, we were to factor in the beneficial use we make of inert waste as
part of restoration and landfill engineering I believe we would conclude that
we are unrivalled in terms of sustainable behaviour in this country. This is
however in spite of the regulators and not because of them.
My aim has been to throw some alternative light upon a number of aspects of a
slightly neglected area of the waste management industry from an operator’s
point of view. One which I feel gets a relatively raw deal because of the lack
of distinction in the language we apply to things that appear similar
superficially but which are significantly different. A quote from the Agency’s
web-site: ‘landfill has been a favoured option for waste disposal but it is a
waste of resources’. I think we deserve better.
Until we are bold enough to consider giving equal weight to the recycling of
land as that given to the recycling of materials and recognise that we
actually have a good story to tell with regard to the recycling of C&D wastes,
we are doomed to undermine our achievements by confusion or by default.
As I said at the outset we have moved from the era of the operator to the era
of the regulator. I think it is time that we tried to strike a better balance,
where it is right to do so, or else we will miss even more opportunities than
perhaps we can fully realise by the micro policy approach we appear to have
vested future practice in.
I would also welcome an end to our self-denigration in relation to our
performance when compared to our EU partners. We are better than them on many
fronts and not always behind the game as is so often stated.
They may be the first to promote and sign up to any number of regulatory initiatives but my ground observations lead me to conclude that very often
their implementation leaves a great deal to be desired. We are the serious
implementers which is why we question the justifiability of each measure
because we will actually try to put it into practice.
How about a little credit where it is due? Let us put more effort however into
removing the anomaly of too much unjustified and damaging unlicensed activity
which I believe discredits our Strategy and mission of trying to behave more
sustainably to the point of farce.
Why would ‘I rather be a regulator than an operator’? Because it is easier to
preach than practice.
07 - ‘Certain things need to be said’, Published in Mineral Planning, December 2001, based on paper given at the RTPI/QPA conference – ‘A fair deal for mineral’.
It is May 2005 and we are on the eve of an expected announcement by Prime
Minister Gordon Brown as to the date of the next election widely predicted to
be in June. Uncertainty surrounds the decision which has become entangled with
the progress of ‘Operation Backlash’, the shutdown of the building,civil
engineering and construction industries as a result of quarry operators
refusing to supply aggregates and other essential construction materials to
its customers. What was initially believed to be a minor irritation has
escalated into a national crisis as related sectors such as the haulage
industry join forces to blockade the ports to prevent attempts by the
Government to draw in imports from mainland Europe and Northern Ireland. The
closely related waste industry has also joined in the dispute as the majority
of landfill sites upon which it relies, which are controlled by the quarrying
industry, remain closed. The Leader of the opposition has likened the crisis
to the winter of discontent in the early seventies compounded by the fuel
blockades of 2000 and the foot and mouth outbreak of 2001. The materials
famine has had far reaching consequences throughout the economy and has
disrupted ordinary life in ways which most people could never have imagined
possible.
The dispute has its origins in the late 90’s when the landfill tax was
introduced by the then Conservative Government. Further ‘so called’
environmental taxes such as the aggregates tax, climate change levy and
increasing fuel levies soon followed under Labour. The catalyst for the
current materials embargo came in the November pre-budget statement when newly
appointed Chancellor Peter ‘I said I’d strike back’ Mandelson announced the
3rd consecutive annual increase in the aggregates tax from £3.60 to £4.60/t
representing an effective 50% increase in the cost of aggregate in addition to
the VAT already levied on sand and gravel and rock from quarries. As a result
supplies to the construction industry ceased from 1 April with the exception
of Northern Ireland which was exempted from the aggregates tax in 2002 on
implementation.
Prestigious national projects such as the much needed completion of the
Channel tunnel rail link, Crossrail, the 5th terminal at Heathrow and the new
national stadia at Wembley and Picketts Lock are now all in abeyance as the
Government contemplates bringing in the Army.
A senior industry spokesman is quoted as saying “In spite of the ever
increasing deluge of legislation and regulation from Brussels, Whitehall,
Edinburgh, Cardiff and the new regional assemblies the industry has worked
hard on a voluntary basis to improve both its environmental performance and
its public image as well as maximising recycling and the use of secondaries
and what is our reward? More regulation and more and ever increasing taxation.
We are now the only sector of the economy that pays 4 environmental taxes. We
appear to have been singled out by the Government as the main environmental
pariah in society. We think it is unfair and unjustified, we have had enough
and our aim is to provide a short sharp shock in order to educate both the
Government and the public at large to obtain ‘a fair deal for minerals"
So after only 48 days of a crisis that came from nowhere the hitherto docile
quarrying industry has hit back and hit back hard at a difficult time for
Gordon Brown whose reputation as a prudent and tough Premier is under
challenge as public frustration and unrest grows and voters start to consider
their options for the forthcoming election.
And now entertainment. There is joy mingled with outrage as Victoria Beckham
announces her retirement from the world of pop to concentrate on her embryonic
career as a writer after the surprise success of her contribution to ‘thought
for the day’ when she quipped that undeserved wealth and no talent had not
stopped her from being happy and successful and she couldn’t understand why
more people didn’t try it.
It’s OK I have woken up now!
When I accepted Chris Offord’s invitation to address the RTPI/QPA minerals
seminar, other than immediately regretting it, I must admit that I was not
particularly inspired by the contents of the Rural White Paper which although
very necessary and well intentioned is unlikely likely to be measurablyprofound for rural communities for quite some time.
I was, however, ever so slightly more motivated by the proposition ‘A fair
deal for minerals’.
My title ‘Certain things need to be said’ was not only a desperate and mildly
threatening fudge to buy time to think of something useful to say, but also a
challenge to myself to try and articulate those every day thoughts many in our
industry might want to express rather than the more considered statements our
formal deliberations often give rise to.
I should point out that the views that I express are mine and in the event of
legal proceedings my solicitors are conveniently located close to the
Chechnyen border.
Let me make my own position plain from the outset.
I am proud to be a participant in the quarrying industry. I am very proud of
most of the work we do whilst feeling disappointed when we do get it wrong,
and of course we do, particularly when it is avoidable.
Getting it right is not always easy, however, and too often people overlook
the practical problems and realities of men and women working long hours, come
rain or shine, in the outdoors with machines which require skilled and
dedicated users, who are in short supply in our call-centre economy.
I think we have a good story to tell. But either we don’t tell it well or
nobody is really that interested. I do not think the general public sees us as
a major issue other then when it hits them locally and then they underestimate
how much genuine interest and commitment exists within most quarrying
companies and how much effort goes into trying to do the right thing.
Environmental concern is not the exclusive preserve of the regulators or the
activists.
Shareholder pressures whether private or public are also real and are growing.
No one wants a dirty, irresponsible and unsafe dividend.
Unlike many of the organisations with a claim on our industry and who profess
to be experts on the environment and appear to want to dominate policy
thinking and formulation, we are the practitioners who work full time in and
with the environment and who actually deliver environmental mitigation and
improvement with the aim of at least maintaining and ideally increasing
biodiversity.
However, in spite of our many environmental and other achievements and our
significant contribution to the economy we appear, in common with other
primary producers such as the fisherman, the farmers and the miners, to be
unwelcome and under attack.
As an industry we of course remain committed to the orderly democratic process
but it is difficult not to feel crushed by the sheer size and weight of it and
the slow speed at which it operates in relation to our interests most of the
time.
It is the cumulative impact of the entire raft of regulatory measures and
constraints that have emerged over the last 10 years or so, which we find so
overwhelming and frustrating.
In summary, therefore, I feel challenged by the situation the industry now
finds itself in. Not so long ago we were accused of being dinosaurs. We were
told that we needed to change and engage with the new politics, the so-called‘language of now’. Confrontation was out, inclusiveness and dialogue was in.
So we gave it a whirl and as we fought against the aggregates tax we were
offered the opportunity to make an alternative deal to the Government, a
better deal for the environment; New Deal, yes, we even used their own
language to try and sell it to them.
We failed, or did they fail us? Will time show that they also failed the
environment as is the case with the landfill tax which has driven tens of
millions of tonnes of inert waste as well as significant quantities of
contaminated waste out of the regulated and licensed waste management system
to unlicensed sites?
It doesn’t really matter now. I am not going to advocate or revisit New Deal,
but I ask one central question on behalf of my colleagues in the industry in
the search for ‘a fair deal for minerals’. And it is this.
If being a dinosaur does not work, and being responsive to Government does not
work, what does in this apparently New political landscape?
What political posture are we to take now? Do we lie down and meekly accept
poor and misguided regulation after healthy dialogue, ciabbata and kiwi fruit
at the DTLR or do we revert to the politics of the jungle?
What is the right way to engage with Government when we have lost so many
arguments already and the threats and constraints upon our industry continue
to grow and proliferate both from the UK and Europe?
Why is it that one emotive press release from CPRE which predicts the demise
of yet another County or an area the size of a city seems to rattle through
Elland House with devastating effect and yet a properly researched piece of
analysis from the industry is warmly welcomed without so much as a flutter. I
don’t know, and until I do I will continue to believe that not only do we need‘a fair deal for minerals’ but we deserve one.
The big environmental issues for the planet as a whole for the foreseeable
future remain population growth driving demand for more energy, food, water
and raw materials, including mineral resources, and the consequences this has
for the generation of waste products, and their knock on impact upon land,
air, water and bio-diversity. Clearly the biggest issue of all, whatever the
primal cause, is that of climate change.
For our industry the question is what do we contribute to these global
environmental problems and what is our impact locally? In terms of lasting net
negative global impact the emissions from our production and distribution are
real and need rigorous management but in truth no more or less than anyone
else in the supply chain.
We acknowledge that we can have other impacts upon the local environment,
which are evaluated as part of the environmental assessment process, but these
are largely temporary in nature and some of which are arguably more of an
amenity dis-benefit as opposed to permanent and net damaging environmental
impact.
This is not to dismiss them as clearly quality of life issues are a key
element of sustainable development. We appreciate that a 10 year site no
matter how temporary it is in our eyes has the air of permanence to those most
affected.
Like many other industries our impact upon the landscape can be a serious
issue but not necessarily always a negative one, witness the 100 SSSI’s the
industry has created over the years as well as the 160 in its stewardship and
the countless other sites of environmental, recreational and agricultural
significance that are the direct result of quarrying. And remember our
occupation of the surface area of the island for quarrying purposes is less
than 0.35%.
Are we so much worse than the more permanent Agricultural, Chemical, and
Energy industries, whether non renewable or even renewable, that we deserve to
be in the front of the queue for so much ill conceived regulation and
spuriously justified environmental taxation?
Surely if we are really going to be serious about the environment in this
country a national audit of the environmental impact of all industrial and
other major activity is required to provide a sense of balance and perspective
before we shoot off down any particular fiscal or regulatory avenue?
We appear to be approaching the issue on a very parochial and piecemeal basis
governed more by who is perceived to be the easy target rather than in
relation to their actual or relative environmental impact.
We need to remember that our industry exists to serve customers so that we can
make a profit and in turn pay a clean, safe and responsible dividend to our
shareholders. En route we happen to employ and pay 40,000 people all over the
country in a huge range of disciplines, pay a massive rate bill and contribute
a huge amount of money to the Government in taxes.
We also make a significant contribution to rural life and the rural economy
which is of ever increasing value given the tragic situation farming has found
itself in over recent years.
As we always say, we respond to demand for our primary products, we do not
create it. And since the recession of 1992 whether by design or default we
have dramatically reduced our output partly because of lower demand, certainly
because we are recycling more and significantly because of the consolidation
that is taking place in the industry.
Let me remind you as to the trends in Great Britain’s GDP and construction
output since 1989, the peak of the last boom. GDP peaks in 89/90, reduces and
then increases steadily until 2000. Construction output reduces and then rises
back to 1989 levels and shows some signs of a looser relationship with GDP as
the mix in the economy shifts away from manufacturing to the service sector.
Turning now to primary aggregates and recycled aggregates consumption we
see a similar peaking in primary aggregates consumption in 1989 which positively
plummets until 1993 from where it increases briefly until it falls dramatically again
and again until it reaches the lowest level for nearly 20 years, last year.
The recycling figures are interesting in two ways. Firstly they show that
recycling was already at a high level in 1989, contrary to popular belief, and
whilst the advent of the landfill tax has possibly increased the rate of
growth per annum it is not significant overall. If we now look at primary
aggregates consumption per £1000 of construction this too shows a healthy
trend in sustainability terms with consumption dropping very dramatically by
33% from 5.2t per £1000 of construction to 3.5t in 11 years. If we relate
consumption of primary aggregates to GDP we see an even bigger fall of 46%
over the period and finally if we look at primary aggregates consumption per
capita, we see a similar drop of 35% over the period. What other industry can
match all this?
But what about those pesky European mainlanders I here you cry, they are so
much better at these sorts of things than us. If we look at total primary and
recycled consumption per capita what we see is that Great Britain is better
than everyone other than the Dutch, who we are only just behind.
Consequently as an industry we are already achieving one of the most
significant and fast emerging aims of Government policy which is the evolution
of a more sustainable economy where we use less resource to produce more and
in so doing improve our ‘Resource efficiency’.
Not only do we not recognise this achievement ourselves but while we are still
improving our performance other sectors of the economy are still debating the
issue. I think our record may prove to be exemplary, once it becomes properly
recognised.
We are also well ahead of most if not all of Europe with regard to the
recycling and reuse of inert waste particularly if we take into account the
beneficial use of inert waste materials to enable the restoration of mineral
workings.
I conclude that we are neither a global threat nor a significant local threat
to key environmental interests provided we do things properly. We are also a
lot more sustainable than we are given credit for. But there is no room for
complacency and it is right that we continue to quantify our impacts and find
better ways to minimise them.
Let me remind you all about how simple it is to operate in this country as a
quarry operator in 2001.
We are only governed by some:
• 30 Acts of Parliament
• 30 sets of Regulations
• 24 PPGs
• 13 RPGs
• 15 MPGs, and
• countless other policies from other agencies
In the last 16 months we have only had to consider 38 consultation documents
of various sorts, 134 development plans and 48 ‘leap’s whilst monitoring
progress in 35 counties and 260 districts not to mention whatever may be
happening in Wales, Scotland and Brussels.
I could go on but I won’t. In summary far too much.
And yet if I compare the quarrying process for sand and gravel now to that 100
years ago not much will have changed: we strip soil, we dig mineral, we wash
it and screen it, we stockpile it, we sell it and deliver it, and we restore.
The workings of old have not materially damaged the island we occupy nor has
the 5 billion tonnes we have supplied to customers in the last 20 years, a
large percentage of which has been supplied to the Government alone.
However, we do it far better today, we are quieter, we are better screened, we
borrow a smaller working area and our restoration is more purposeful and more
sustainable. So why do we get such a bad press?
Are we just victims of a more informed internet linked and agitated populous
who resist all change because that is how we have become, untrusting and
suspicious.
Is most environmental objection really amenity objection wrapped up in a green
cover or is it the old chestnut of fear that the value of ones property might
reduce because of the threat of a quarry? Where does amenity objection end and
environmental objection begin?
Whatever, I say it is time for the industry to set out what it wants rather
than forever responding to everybody else.
So here is my contribution to developing ‘a fair deal for minerals’ which I
hope will evolve into a robust, reasoned and rational agenda for the industry
with the intention of getting us on the front foot for a change and off the
back foot which we seem to have been on for so long.
What industry needs from now on is more certainty to be able to plan its
contribution to the development of minerals in this country not more
constraint leading to more uncertainty.
So here I go!
The ‘fair deal’ agenda
From Government:
• A national environmental audit of the environmental costs of all industries
and major processes to provide a consistent and robust foundation for a
sensible examination of the environmental externalities of any process.
• Ideally, albeit highly unlikely, we should defer the introduction of the
aggregates tax until this work is undertaken. It is vital, however, that the
tax is introduced sensibly to avoid an explosion of tax busting non quarry
mineral sites.
• The creation of a high level dialogue between industry and the Government,
possibly involving a review of Verney, to identify what the role of the
quarrying industry is believed to be now and where does the Government see the
industry being in 10 and 20 years time.
• Fund local authorities so that they are able to resource their mineral
planning function properly and to give them a better chance to discharge the
plan led system quicker.
From the DTLR:
• A lot more sponsorship and a lot less regulation or if this is too difficult
a balance to strike, a clean separation of the existing dual role, with DTLR
regulating and DTI sponsoring. I don’t mind which, but whatever happens we
need to feel that someone in Government in future is prepared to be genuinely
and openly supportive of us.
• Admit that the plan led system unnecessarily slows and inhibits mineral
development by taking too long and by being too complicated. It needs to be
quicker, smarter, and simpler.
• Commission an audit of planning committee process around the country to try
and establish more consistent and objective procedures or a meaningful code of
practice for the consideration of mineral planning issues to kill off some of
the antics we have to put up with in some of the committee chambers around the
country.
• Recognise that the industry has significantly progressed and largely
achieved the aim of maximising the recycling of inert waste and that future
growth is now in the Governments own hands. Firstly, enable recycling to take
place on quarries and landfills in the green belt provided high environmental
standards are maintained. Secondly repeal or significantly modify Paragraphs 9 & 19 of the WML Regulations to choke off the bogus landscaping and
landraising, golf course and other creative tax busting projects which are
still diverting essential inert waste away from restoration and recycling.
• Recognise that whilst secondary aggregates have some potential to make a
contribution to future supply that they are also limited by environmental
constraints and primary aggregates will continue to be the main source of
supply for the foreseeable future.
• Recognise that landfilling mineral workings with inert waste enables the
recycling of land and this should justify moving it up the waste hierarchy so
that it has the same status as the recycling of materials.
• Resist the possible threat to the landfilling of inert material below the
water table as this will jeopardise the restoration potential of many key
sites in river valleys and could constrain the release of future mineral
resources.
• Ensure that the Landfill Directive is implemented sensibly and reasonably so
that it does not jeopardise the landfilling of mineral workings with inert
waste and in turn our restoration objectives.
• Listen carefully to industry’s arguments on MPG6. We need a practical and
quantitative MPG which does not fudge key issues but sets out clear guidance
unambiguously and which is as barrister proof as possible. We need some key
elements of the existing guidance to be retained particularly those relating
to ‘real’ landbanks which should not be reduced any further.
• Listen carefully to industry’s comments on noise in the proposed revision of
MPG11. We are not against improvement provided it delivers perceptible benefit
and is achievable.
• We are also most concerned at the potential impact the proposed Water Bill
could have if the removal of our existing exemption to enable dewatering is
not replaced with a reasonable alternative.
• Commission research on the relationship between property prices and the
minerals industry to try and attract some objectivity into the debate.
Of MPAs:
• Industry would endorse you receiving more financial support to enable you to
resource and equip your mineral planning teams better to enable the existing
system to function quicker and more efficiently.
• All new planning committee members should go on a minimum one day minerals
planning training course which could be organised between the industry and the
MPAs so that they get some balanced training as to the subject matter they are
deliberating.
• Planning committees must make decisions which support their local plans
whenever possible as they are supposed to be the cornerstone of the system.
• I think that mineral planners could also afford to exercise more confidence
in their own judgement particularly where consultees can be seen to take
unjustifiably stubborn positions which can not be backed up with good evidence
or good argument.
And finally the industry:
• Above all we need to develop our own vision for the future of the industry,
if we don’t we are lost.
• I think that we place too much emphasis upon formal management systems at
the expense of simple practical measures on the ground. There are still too
many untidy site entrances, poorly maintained hedges and perimeters, poor
signage, mud or dust on the roads.
• We must remember that it is what the public sees, hears, smells and feels
that matters. You don’t need an ISO 14001 audit to spot the unacceptable
sites. If the loos and mess room are clean it is likely to be a well managed
site.
• I believe it is time to shift the emphasis of our achievement away from our
best sites to our worst. We need to be brutally honest and accept that it is
our worst sites that we are judged by and not the best. This is not to deny
our best but to admit to our worst. I would suggest that we try and lance this
problem with a ‘Worst First’ campaign. Let us try and raise the minimum
standard on all of our operations and aim to eliminate the worst by the end of
say 2003 and then we could justify arguing that if our externalities are
diminishing the aggregates tax should go down and not up!
• I admitted earlier that I am challenged by the political posture we need to
adopt to ensure that we are not just heard by Government but listened to. I do
not believe in direct action, tempting as my opening fantasy was.
• I do believe in robust and vigorous argument and I think we need to be
better in this regard if we are to stand any chance of making progress towards
achieving our aims in this superficial world of spin and celebrity.
• Perhaps we should create a Minerals Industry Economic and Environmental
forum which elevates our role and achievements above the trade association
level, which is inclusive in terms of its membership and whose sole purpose is
to deliver the truth about the value of our industry both economically and
environmentally to the key decision makers and opinion formers in this
country.
• I don’t claim to have the answer but I do know we have a major problem and
unless we commit more of our time, resources and passion to finding a better
way we will continue ‘in our terms’ to suffer.
• And if we are sincere in trying to increase the confidence the public has in
our industry we must always ensure that when we say what we do, we then do
what we say.
One way or another I think members of the industry whether big or small,
public or private, gravel or rock, deserve ‘a fair deal for minerals’ and if
not, at least ‘a fairer deal’.
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