Assessing the environmental impact of regional and sub-regional supply options

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Executive Summary

Introduction

1. The regional and sub-regional apportionment of aggregate provision is a long established component of mineral planning in England. Driven by a need to ensure a steady and adequate supply of raw materials to the construction industry, it has been a priority of Government to maintain a planning system that ensures sufficient land comes forward for extraction in locations in reasonable proximity to the principal markets.


2. The regional apportionment process is driven partly by the available distribution of resources but is also strongly influenced by the maintenance of productive capacity in traditional supply areas, reflecting the investment in extraction and transportation infrastructure, and established planning policy to protect areas of acknowledged environmental value. This has led to questions about the extent to which attention has been paid to the environment in the 'current approach' to apportionment of the National Guidelines to the Regions in England.


3. By contrast, at the sub-regional apportionment level, many of the former planning Regions have sought to implement methodologies for the apportionment of aggregate provision between Minerals Planning Authorities which take account of environmental considerations in a transparent way. However, such work has been varied in process and outcome.

 

Project Aim

4. The original project brief described the overall aim of the project as the development of: "a methodology to assess the environmental implications of aggregates apportionments". At the outset of the work, the exact meaning of this aim was clarified with the project steering group, such that the project should consider how environmental considerations can be taken into account during the apportionment process. Assessment of environmental implications is in fact already addressed through the legal requirements of Strategic Environmental Assessment and Habitats Regulations Assessment.


5. The following work has been undertaken:
   
   
   1. An evaluation of current approaches to regional and sub-regional aggregates apportionment. This centred on a review of the various approaches that have been tried against a set of agreed criteria to identify good practice and, where appropriate, shortcomings in the methodologies used.
   
   
   2. Drawing on the findings of the evaluation, reviewing the extent to which improvements are needed in the aggregate apportionment process and steps that can be taken to achieve a consistent mechanism for developing apportionment options.
   
   
   3. The formulation of a toolkit for developing apportionment options that ensures environmental considerations are taken into account during, and therefore informing, the apportionment process, and that Land Use Consultants 2 Proposed Toolkit for Developing Aggregate March 2011 Apportionment Options: Final Report the process is founded on a robust evidence base, engages relevant stakeholders and is well documented and transparent.

Overview of Current Apportionment Methodologies

6. A summary of the regional apportionment process in England and the subregional processes followed in the nine English regions is provided. The approaches in Wales and Scotland have also been considered. It is evident
   that practice varies across the regions, and some Regional Aggregates Working Parties (RAWPs) and Regional Assemblies have experimented with new methodologies which seek to pay more attention to environmental considerations compared to what is characterised as a 'past sales' approach (i.e. based on data relating to past patterns of aggregate supply). In making this observation, it is important to acknowledge that past patterns of supply
   in part reflect planning and environmental constraints applied at lower tiers of the planning system (i.e. through development plans and the development management process) and thus already have an 'in-built' environmental policy component.

 

Evaluation of Sub-regional Apportionment Methodologies

7. The methodologies for aggregates apportionment attempted in each of the nine English regions and the two Welsh regions were evaluated using a framework based on qualitative descriptions of the potential strengths and weaknesses. Each apportionment method was evaluated against six criteria:
   
   
   1. Range of environmental issues incorporated (e.g. components of environmental capacity, SEA Directive topics)
   
   
   2. Degree to which reasonable alternative spatial options are considered
   
   
   3. Transparency of approach
   
   
   4. Data and technical requirements (including level of definition of geological data required)
   
   
   5. Level of spatial definition of outputs
   
   
   6. Extent of stakeholder engagement
8. Environmental issues were most comprehensively incorporated into apportionment methodologies attempted in South East, West Midlands and North/South Wales, with only partial consideration in the East of England, North East and North West Regions. However, it is recognised that environmental issues may have been more fully considered in these regions through RAWP meetings etc, but documentation of the process is not readily available.


9. A similar picture exists in relation to the consideration of different spatial options, with those regions above that incorporated environmental issues more comprehensively as well as Yorkshire and Humber Region, also considering a full set of reasonable alternatives.


10. Eight of the ten regions were explicit about judgements made within the methodologies attempted, and drew on the best available evidence. Methodologies used for London and the North East Region are less transparent. Again, it is acknowledged that appropriate documentation of the process may not have been obtained, as it may only be available within minutes of meetings etc.


11. None of the methodologies is considered to be technically complex, but most require some technical expertise and have some data limitations. These tend to be those regions that have incorporated a full range of environmental considerations and alternative options.


12. The level of spatial definition of outputs is based on MPA boundaries for the majority of regions, but based on geological 'resource blocks' for the South West and North/South Wales.


13. Key stakeholders have been involved in the apportionment process for most regions, with a full range of interests involved in the South East, South West, West Midlands and Yorkshire and Humber Regions. Some stakeholders were involved in the creation of the North/South Wales environmental capacity tool, but there was very limited engagement in the application of the tool.

 

Recommendations

14. It is evident from the various approaches attempted to apportion aggregates in different parts of the country that they reflect particular local circumstances – geology, past patterns of supply, the composition of aggregate working parties, etc. Thus rather than formulating a prescribed one size fits all methodology, a toolkit for developing apportionment options between constituent MPAs or other spatial planning unit is recommended.
    This comprises three key components: local demand, local supply and environmental issues.
15. It is recommended that:

• An accurate assessment of local demand for aggregates within the aggregate working party area is required, as understanding future demand helps establish how much primary aggregate will be needed to supply the construction industry and where building materials are likely to be required in large quantities. This can be used to influence the distance over which aggregates may be transported from areas of supply, thereby helping to reduce emissions from transport.


• An accurate assessment of the quality and spatial extent of primary aggregates available for extraction is required to ensure any apportionment options are realistic. This is likely to require the BGS Mineral Resource Data to be supplemented with local knowledge, drawn from pooling information available from MPAs and industry on the extent, quality and workability of aggregate resources.


• The consideration of environmental issues should be a central part of an apportionment methodology, and the resulting apportionment options. The range of environmental considerations that could be included is wide, and it will be for aggregate working parties to determine which ones are most relevant to their particular local circumstances. In doing so, it will be important to draw a distinction between those which lend themselves to a strategic-level apportionment (e.g. the presence of nationally designated landscapes), and those which are better dealt with at the minerals development framework level by individual MPAs (e.g. impacts on local
  environmental designations).

16. Any methodology should also display five essential characteristics:

• Transparency of approach (i.e. it should be possible for all stakeholders to see and understand the data inputs, assumptions made and outputs).


• Data and technical inputs to be as robust as possible without requiring excessive cost of new data provision.


• Level of spatial definition (i.e. it should be possible for all stakeholders to identify the planning unit to which a local apportionment applies).


• Extent of stakeholder involvement (i.e. there should be adequate stakeholder input to the apportionment process).


• Consideration of alternatives (i.e. realistic and achievable alternatives at each stage of the apportionment methodology should be considered).

17. The output from the apportionment methodology should be a set of apportionment options divided between the relevant planning unit(s), which can form the basis of public consultation, leading to the choice of a preferred strategy for inclusion in the relevant development plan(s).


18. Lastly, the report provides some comments on the process used for determining the national and regional aggregates guidelines and highlights aspects which may be considered for improvement, based on the evaluation
    of existing approaches. Suggestions for improvement include greater transparency in the approach taken in establishing the guidelines, particularly with regard to access to the source data; consideration of alternatives; spatial definition of outputs (e.g. geological resource blocks rather than administrative areas); and enhanced stakeholder input.