South Downs National Park - Soft Sand Study · 2015-03-05 · 1. Introduction & Terms of Reference...

Planning, Environment & Design

South Downs National Park - Soft Sand Study

August 2012

South Downs National Park - Soft Sand Study March 2013 i

Contents

1. Introduction & Terms of Reference ........................................................................................ 1 Background ............................................................................................................................................ 1 Study Aim & Objectives ......................................................................................................................... 1 The Scope of this Report ....................................................................................................................... 2

2. Mineral Definitions ................................................................................................................. 3 Introduction ............................................................................................................................................ 3 Soft Sand ............................................................................................................................................... 3 Sharp Sand ............................................................................................................................................ 3 Silica Sand ............................................................................................................................................. 3 Sand & Gravel ........................................................................................................................................ 3

3. Distribution & Availability of Soft Sand Resources ................................................................. 4 Soft Sand Distribution ............................................................................................................................ 4 Availability of Soft Sand ......................................................................................................................... 6

4. Minerals Planning Context ..................................................................................................... 7 Introduction ............................................................................................................................................ 7 The Managed Aggregates Supply System ............................................................................................ 7 Minerals Planning for the South East Region ........................................................................................ 7 Minerals Planning in the South Downs National Park ........................................................................... 8 Minerals Planning Policies of Surrounding MPAs ................................................................................. 9 Summary .............................................................................................................................................. 16

5. Trends in Demand & Permitted Reserves ............................................................................ 17 Regional Trends in Demand ................................................................................................................ 17 Local Trends in Demand ...................................................................................................................... 17 Regional Permitted Reserve Trends .................................................................................................... 18 Local Permitted Reserve Trends ......................................................................................................... 19

6. Permitted Soft Sand Sites, Markets & End Uses .................................................................. 20 Permitted Soft Sand Sites .................................................................................................................... 20 Current Markets and End Uses for Soft Sand ..................................................................................... 21 Discussion ............................................................................................................................................ 22

7. Provision of Soft Sand in the Current Plan Period ................................................................ 23 Hampshire Allocations ......................................................................................................................... 23 West Sussex „Long List‟ Sites .............................................................................................................. 25 East Sussex Site Allocations ............................................................................................................... 27 Summary .............................................................................................................................................. 27

8. Analysis of Reserves Information ......................................................................................... 28 Reserve Calculation Tables ................................................................................................................. 28 Sand & Gravel Reserves ..................................................................................................................... 30 Soft Sand Reserves ............................................................................................................................. 30 Potential Influence of National Park Status on Soft Sand Provision ................................................... 31 Discussion ............................................................................................................................................ 31

9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern .................. 33 Introduction .......................................................................................................................................... 33 Sustainability Issues ............................................................................................................................ 33 Potential Alternatives ........................................................................................................................... 34 Summary .............................................................................................................................................. 37

10. Conclusions ......................................................................................................................... 38 Introduction .......................................................................................................................................... 38 Soft Sand End Uses & Markets ........................................................................................................... 38 Provision of Soft Sand in the Study Area............................................................................................. 39 Alternatives to Future Extraction within the SDNP .............................................................................. 39 Apportionment in the SDNP ................................................................................................................. 40

Appendix A: Figures A.1 to A.3 (Resources and Constraints) ..................................................... 44 Appendix B: Figures B.1 to B.3 (Permitted and Potential Sites) .................................................. 45 Appendix C: Figures C.1 to C.4 (Soft Sand Resources) .............................................................. 46

1. Introduction & Terms of Reference


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1. Introduction & Terms of Reference Background

1.1 This report relates to the consultancy contract „Soft Sand Study‟ between the South Downs

National Park Authority and Capita Symonds Limited.

1.2 Mineral Planning Authorities (MPAs) are required to plan for provision of aggregate minerals

within their areas, including types of sand & gravel. Soft sand is a valuable mineral resource

that, for certain end uses, cannot be substituted by other materials and a significant proportion

of the resource in the South East is located within the National Park boundary and distributed

across the National Park, and adjoining parts of Hampshire, West Sussex, East Sussex, Surrey

and Kent.

1.3 The National Planning Policy Framework (NPPF) requires (paragraph 116) that applications for

major development within National Parks should be refused planning permission except in

exceptional circumstances, and where it can be demonstrated that they are in the public

interest. This broadly echoes the stance taken, specifically in relation to mineral development,

within the former Minerals Policy Statement 1 (MPS1: Planning and Minerals), Consideration of

such applications is required to include an assessment of the need for the development; the

cost of and scope for developing elsewhere, outside the designated area; and any detrimental

effects on the environment, the landscape and recreational opportunities.

1.4 The South Downs National Park Authority (SDNPA) assumed its full powers in April 2011,

including responsibilities as the Mineral Planning Authority (MPA) for the Park area. SDNPA has

commissioned this work in partnership the adjoining MPAs represented by Hampshire County

Council, West Sussex County Council and East Sussex County Council, in response to the

cross-boundary nature of this planning issue.

Study Aim & Objectives

1.5 The purpose of this study is to provide a better understanding of current soft sand reserves,

uses and demands within the SDNP boundary and in the context of the wider South-East

region.

1.6 Specifically, the study was required to provide information on:

unconstrained, workable and viable soft sand resources and reserves within the study

area that fall within the boundary of the SDNP (using GIS and building on existing

evidence gathered by the MPAs)

how much soft sand is/has historically been extracted within the study area

the extent and nature of the market for soft sand arising from the study area

current and likely future uses and demand within the SDNP, including any emerging

markets

assess the potential for alternative supplies of soft sand outside the SDNP and outside

the study area, and whether they could fulfil current and future demand.

The availability, feasibility and sustainability of sourcing soft sand from alternative

supplies outside the study area should also be assessed, including the social, economic

and environmental impacts which would arise.

1.7 The study should “assist the South Downs National Park Authority and partner MPAs by

providing a robust and sound evidence document which can be used by the Authority and

partner MPAs in formulating a policy approach to soft sand in the future” (ITT for Soft Sand

Study, SDNPA, December 2011).

1. Introduction & Terms of Reference


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The Scope of this Report

1.8 As required, the study primarily looks at land-won soft sand in the MPAs of the SDNP,

Hampshire, West Sussex and East Sussex („the study area‟), however, Surrey and Kent are

also included as the main source of soft sand in this area (the Folkestone Formation) is also

found within their boundaries.

1.9 This report contains information on:

the preparation of Minerals and Waste Plans within the SDNP, Hampshire, West Sussex

and East Sussex (including Brighton and Hove) MPAs

key planning points in relation to the provision of soft sand for each MPA and the extent

to which soft sand resources are safeguarded in those areas.

the distribution of soft sand resources in the SDNPA and neighbouring South East MPAs;

an overview of the availability of the soft sand given major environmental constraints;

regional and local (MPA-level) trends in permitted reserves of sand & gravel and soft

sand.

current permitted reserves in terms of active sites and the potential future reserves

represented by allocated or short listed soft sand extraction sites;

regional and local (MPA-level) trends in demand for soft sand, in terms of

sales/production;

the general markets that the active soft sand sites serve and the end use of their

products;

analysis of the potential shortfalls or surpluses over the current Plan period the study

area; and

the broad (rather than site-specific) options available for the release of further reserves,

where this may be needed to meet identified shortfalls

the location of potential alternative supply sources and provides a very broad analysis of

the sustainability issues that will need to be addressed.

1.10 Plan production, including collection of aggregates data, is ongoing across the four study area

MPAs. In order to assess the provision of soft sand, information (particularly the apportionment

and reserve figures) has been used which relates to the former three MPA areas.

1.11 This report presents the results of research carried out at a particular point in time, prior to the

publication of „Guidance on the Managed Aggregate Supply System‟ on 18 October 2012

(which supports the approach to planning for aggregate mineral extraction under the National

Planning Policy Framework) and the proposed changes to the Hampshire Minerals and Waste

Plan (October 2012) following the examination of the Submission Plan in June 2012.

1.12 For updates to the current planning situation for any of the MPAs in this report, please contact

the relevant Local Authority or see their individual websites.

2. Mineral Definitions


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2. Mineral Definitions Introduction

2.1 This study is specifically concerned with soft sand and the text below describes the difference

between this and other types of sand. While typical end uses have been identified below, those

sands used for high-end products may be used in lower-end applications.

Soft Sand

2.2 Soft sand is generally fine-grained sand in which the individual grains are well-rounded,

imparting a relatively soft texture and free-flowing nature to the sand. Such sands are commonly

deposited in marine environments, where constant movement by the sea results in the

rounding, polishing and sorting of the grains. They therefore occur within strata, such as the

Cretaceous Greensands, which originated in such environments. The characteristics of such

sands lend themselves especially to products which are required to „flow‟ or be easily „workable‟

by hand when they are being used - particularly mortars, but also plaster, in the case of very

fine grained sand. These are collectively known as „building sand‟. Soft sand may also be used

in asphalt products where it is used to stiffen the bitumen binder, and in concrete products -

although sharp sand (see below) is more commonly used for that purpose. Soft sands usually

comprise a high proportion of silica (quartz), but also impurities such as iron oxide, which impart

colour to the sand (mostly in shades of orange, brown and red). Similar sands but with fewer

impurities are classed as „silica sands‟. These are generally lighter in colour and are used for a

more specialist range of products (see below).

Sharp Sand

2.3 In contrast to soft sand, sharp sand tends to be relatively coarse and the component grains are

more angular. Such sands are typically deposited within river channels, rather than in oceans,

and are generally found, as part of a sequence of mixed sand & gravel, within river floodplains,

river terraces, and (in areas which have been glaciated) within other types of deposit. As the

name implies they have a sharper texture than soft sands and, although they can be used as

building sand, they are generally not preferred for that purpose because they produce less

„workable‟ mortars, unless special additives are included in the mix, adding to the cost. They are

better suited to use within concrete products, not least because they usually occur in

conjunction with gravels which provide the coarse aggregate component of the concrete mix.

Silica Sand

2.4 „Silica sand‟ is sand made up predominantly of silica grains and the content of other mineral

impurities and silt is very small. Silica sand is used for non-aggregate purposes in a range of

high value industrial applications such as glass manufacture, foundry sand, sands for brick

facings, water filtration and, for very fine-grained sands, in resins, tile and brick facings and

industrial filler applications. They are also used for specialist non-staining and neutral sports

sand (including golf courses), play sand and for horticultural and rootzone products.

Sand & Gravel

2.5 Where the term „sand & gravel‟ is used in this report it refers to aggregate that is not „crushed

rock‟, i.e. it includes: soft sand, sharp sand and sand and gravel aggregate. Figures quoted for

„sand & gravel‟ in this report may also include silica sand, although this is not normally classed

as aggregate. In some cases, soft sand figures cannot be separately identified, and more

generally the reporting herein of sand & gravel gives context to the situation as regards

provision of soft sand.

3. Distribution & Availability of Soft Sand Resources


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3.1 This section describes the distribution of soft sand in the SDNP MPA and the five nearby MPA

areas of Hampshire, West Sussex, East Sussex, Surrey and Kent. Some measure of the

practical „availability‟ of these resources is provided by way of constraints mapping that includes

urban/infrastructure features and major environmental designations are provided to demonstrate

the potential conflicts planning for extraction of these minerals may encounter. The way that

provision of these reserves is managed is provided in the following Section 4 „Minerals Planning

Context‟.

Soft Sand Distribution

3.2 The extent of the bedrock sand resources in the South East can be seen in Figure 3.1 below.

This image contains broad areas defined by the British Geological Survey (BGS) which “may be

of current or potential economic interest”.

3.3 In the South East of England the primary source of soft sand is the Folkestone Formation of the

Lower Greensand Group. The Folkestone Formation extends from north west of Lewes in East

Sussex, across West Sussex and into Hampshire to Petersfield, where it swings around to the

north east and then continues east across Surrey and Kent, meeting the coast at Folkestone.

3.4 Not all of the Folkestone Formation sands are suitable for use as building sand, as the

Formation varies in both colour and grain size across the South East. Some parts of the

resource are also sources of silica sand and/or sharp sand. Often, more than one type of sand

is sourced from a single quarry site.

3.5 The BGS have defined the whole of the Folkestone Formation (in brown on the figure) as an

area of potential bedrock sand and gravel mineral resource and have also identified specific

areas of silica sand resources (identified in yellow). In total, the mapped Folkestone Formation

resource covers an area of approximately 310 km2.

3.6 In the west of Hampshire, parts of the Bracklesham Group (including the Poole Formation,

Branksome Sand Formation and Selsey Sand Formation) are defined by the BGS as an area of

construction sand resource (these are shown in purple on Figure 3.1). These geological units

contain sand & gravel. To the west of this mapped area, but still within Hampshire, are areas of

Quaternary sands and gravels. In some locations, building sand is sourced from this material

(e.g. Bleak Hill Quarry).

3.7 To the west of the SDNP is an area of identified resource associated with the Whitecliff Sand

Member of the London Clay Formation. This is a „clean‟ fine to medium grained sand, worked

for example in the former Fair Oak Quarry in Hampshire.

3.8 Over to the east of Kent, parts of the Thanet Sand Formation are sources of building sand and

are identified as an area of mineral resource. There are also sand resources identified in the

Sand Rock Formation on the Isle of Wight.



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Figure 3.1 The Folkestone Formation and other soft sand resources in South East England.



August 2012 6

Availability of Soft Sand

3.9 Potential constraints to the extraction of soft sand resource naturally include the South Downs

National Park and Areas of Outstanding Natural Beauty (AONBs). They also include European

designations such as Special Protection Areas (SPAs), Special Areas of Conservation (SACs),

and nationally designated Sites of Special Scientific Interest (SSSIs) and Ancient Woodland.

Urban areas and major infrastructure may also be a constraint (although prior extraction during

redevelopment is a possibility).

3.10 The following sections describe the distribution of these particular constraints on the soft sand

resource within the SDNP and the MPAs that adjoin the SDNP boundary, and also in the nearby

MPA areas of Surrey and Kent. Figures A.1 to A.3 in Appendix A show the major environmental

constraints in relation to soft sand resources. Not mapped, but also present, are areas of Green

Belt, cultural constraints such as Scheduled Monuments; and locally designated sites such as

Sites of Importance for Nature Conservation (SINCs) and Local Nature Reserves. Likewise,

extraction may be precluded by hydrogeological, landscape character, highways, cumulative

impacts and other unmapped constraints.

3.11 The following descriptive text is not an appraisal of local constraints (as would occur during the

determination of applications for mineral extraction) but provides, at a high level appropriate for

the purposes of this study, an idea of the extent of national and international designations with

respect to the resource. Thus, where the terms „constrained‟ and „unconstrained‟ are used in the

text below, this is only in the context of those that are mapped. The scale of these maps is small

and so even small areas of unconstrained resource may still be economically viable.

3.12 Parts of the Folkestone Formation in Hampshire County are within the SDNP MPA, with the

exception of an area to the north west of Haslemere. To the south of the SDNP, the Whitecliff

Sand Member is somewhat covered by constraints, particularly built development. However, in

the area west of Romsey there is an area of resource apparently free of mapped constraints1.

Much of the mapped resource in the area that relates to the Branksome and Selsey Sand

Formations falls within the New Forest National Park but in the area to the west of that, where

sand is currently extracted at Blashford Quarry there are fewer mapped constraints.

3.13 In East Sussex County, there is very little of the Folkestone Formation and all of the soft sand

resource is within the boundary of the SDNP MPA. The Formation continues as a low ridge in

West Sussex and the majority of it is with the boundary of the Park. Notably, there is an area

free of mapped constraints to the north of Upper Beeding and smaller areas around Storrington

/ Henfield, although local constraints may apply.

3.14 In the Surrey MPA, the Folkestone Formation also contains silica sands, and this is notable in

the unconstrained areas mapped either side of Reigate (although silica sand is found elsewhere

in the Formation). Areas without mapped constraints include those to east of Farnham, at

Runfold.

3.15 In the Kent MPA there are some areas to the east of Sevenoaks that are not constrained by the

AONB and resources areas picked out for silica sand are also largely unconstrained between

Sevenoaks and Maidstone. The Folkestone Formation resource is shown to extend from

Maidstone to Folkestone, running virtually parallel with the Kent Downs AONB. Within this

section of the Formation, the mapped international and national designations are relatively few.

1 Hampshire County Council has identified that other issues affect this area, including highway safety constraints

(comments on the draft version of this report, April 2012). Indeed these and other considerations (such as the

cumulative impact on local communities) may apply to all areas where there are no mapped constraints.

4. Minerals Planning Context


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4. Minerals Planning Context Introduction

4.1 This section outlines the national, regional and local minerals planning context for this study,

including the responsibilities of the Mineral Planning Authorities (MPAs) to meet their authority‟s

aggregate apportionments. It provides detail on what the situation is in each MPA in terms of

planning for the supply of sand & gravel and soft sand resources (as defined in Section 2). The

information given below reveals some important differences in Mineral Planning across the

study area.

The Managed Aggregates Supply System

4.2 The Managed Aggregate Supply System (MASS) is an informal name given to the „top-down‟

mechanism which has been used in England & Wales for many years to determine the levels of

aggregate provision required in each Mineral Planning Authority (MPA), in order to contribute

fairly to the overall expected level of demand. It is intended to help the planning system to

address the spatial inequalities between the distribution of supply sources and the distribution of

demand.

4.3 The system comprises:

National-level econometric forecasting of overall and regional demand for construction

aggregates, commissioned by the Department for Communities and Local Government

(CLG) and based largely on projected investment in construction activity;

Regional-level „apportionments‟ published by CLG at periodic intervals in the form of

National and Sub-National (formerly Regional) Guidelines for Aggregates Provision, each

one covering a rolling sixteen-year period (e.g. 2005 - 2020);

Further (sub-regional) apportionment of each sub-national guideline figure by the (former)

Regional Assemblies2 as supported by the Aggregates Working Parties, to give

apportionment figures for each component MPA. These are expressed in million tonnes

per year (mtpa) and in totals for the relevant 16-year period; and

Provision by each MPA for a „landbank‟ of sufficient permitted reserves to enable the

indicated level of production to be sustained throughout the relevant period, and to

maintain a landbank of at least seven years (for sand & gravel) throughout that period.

4.4 Under the recently published National Planning Policy Framework (NPPF, March 2012,

paragraph 145), the emphasis is on the preparation of annual Local Aggregate Assessments by

individual MPAs, or groups of MPAs. This theoretically allows greater scope for local minerals

planning, but there is still a requirement for MPAs to participate in the operation of an Aggregate

Working Party, and to take the advice of that Party into account when preparing their Local

Aggregate Assessment. Moreover, there is also still a requirement for MPAs to take account of

published National and Sub-National (previously regional) Guidelines as issued periodically by

CLG. The Managed Aggregate Supply System therefore still has a very important role to play in

determining the requirements for aggregates provision at the local scale.

Minerals Planning for the South East Region

4.5 Formerly, the sub-regional apportionment of aggregates was set out in Regional Spatial

Strategies (RSSs). In July 2010, a ministerial statement was published confirming the intention

to revoke the RSSs. The High Court subsequently overturned the revocation of the RSS in

2 The South East England Regional Assembly‟s (SEERA) functions have now been assumed by the South East

England Partnership Board (SEEPB)



August 2012 8

November 2010, however a High Court judgment in February 2011 confirmed that the intended

abolition of the RSS should be treated as a material consideration by decision makers.

4.6 Apportionments for the South East were issued under the regional system which prevailed at

that time. The South East Plan states that for the Plan period 2010 to 2026 the Region should

maintain a 7 year landbank that is sufficient to deliver 11.12 million tonnes per annum (mtpa). In

the adopted South East Plan of May, 2009 (Government Office of the South East, 2009), this

had been set at 13.25mtpa3. However the South East Regional Assembly challenged the

regional apportionment. An Examination in Public (EiP) of the South East Plan took place in

October 2009 and subsequently the Panel recommended the lower figure of 11.12mtpa. This

was never formerly adopted. Despite the subsequent intended revocation of the RSS (see

above), advice given to Chief Planning Officers (July 2010) was that MPAs in the South East

should work from the Secretary of State's Proposed Changes to the Review of Policy M3 of the

South East Plan (March 2010) unless there is local evidence which supports a different case.

4.7 Table 4.1 shows the breakdown of the required amount, per annum, by individual MPAs (or

groupings of MPAs) within the SE Region. This table shows the total S&G for the SE MPAs.

Where markets for sand & gravel aggregate are distinct enough, MPAs are encouraged by

National Policy to provide separate apportionments for the different mineral types. For this study

area, sand & gravel is variously divided for planning purposes according to the types described

in Chapter 2 and some MPAs have specific policies for silica sand. Where separate silica sand

apportionments exist in each MPA, they are mentioned briefly below. However the main focus of

the following paragraphs is soft sand and sand & gravel.

Mineral Planning Authority

Aggregate Apportionment in mtpa – Secretary of

State’s ‘Proposed Changes, March 2010

(previous apportionment in brackets)

Hampshire/Southampton/Portsmouth 2.05 (2.63)

West Sussex 1.03 (0.91)

East Sussex/Brighton& Hove 0.10 (0.01)

Surrey 1.27 (2.62)

Berkshire Unitaries 1.33 (1.57)

Buckinghamshire 1.05 (0.99)

Isle of Wight 0.10 (0.05)

Kent 1.63 (2.53, joint with Medway)

Medway 0.18 (see Kent)

Milton Keynes 0.28 (0.12)

Oxfordshire 2.10 (1.82)

Table 4.1 Sub-regional apportionments for the period 2010 to 2026.

4.8 It was recognised in the regional guidance that a significant part of the soft sand resources in

the region is within the South Downs National Park with a recommendation for Hampshire, West

Sussex and East Sussex MPAs to first consider the potential for meeting requirements from

outside the National Park and then from within.

Minerals Planning in the South Downs National Park

4.9 The South Downs National Park Authority Local Development Scheme (September 2011)

observes that until such time as Regional Spatial Strategies are finally revoked, and the SDNPA

adopts its own or further joint LDF documents, the „Development Plan‟ for the SDNPA includes:

The South East Plan (Proposed Changes)

3 On the basis of “the Government‟s National and Regional Guidelines for Aggregates Provision in England” (as

reported in Government Office of the South East, May 2009)



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Hampshire Minerals and Waste Core Strategy (2007) – for Hampshire part of the National

Park

East Sussex Minerals Local Plan (1999), East Sussex Waste Local Plan (2006) – for East

Sussex, and Brighton and Hove part of the National Park,

West Sussex Minerals Local Plan (2003) – for West Sussex part of the National Park.

4.10 Other plans which are noted to be material considerations are:

The emerging Joint Core Strategies for Waste and Minerals (with East Sussex and

Brighton and Hove), Waste (with West Sussex) and Minerals and Waste (with Hampshire,

New Forest NP, Southampton and Portsmouth), and

any emerging Development Plan Documents being prepared by the SDNPA

4.11 The SDNPA is working in partnership with Hampshire County Council (and Portsmouth City

Council, Southampton City Council, and New Forest National Park Authority), West Sussex

County Council and East Sussex County Council (and Brighton and Hove City Council) in the

production of minerals and waste local plans.

Minerals Planning Policies of Surrounding MPAs

Hampshire

Plan Development

4.12 The Hampshire Minerals and Waste Core Strategy was adopted in 2007 by the partnering plan

making authorities (Hampshire County Council, Portsmouth City Council, Southampton City

Council and the New Forest National Park). Some policies of the previous Hampshire Minerals

and Waste Local Plan (1998) were saved alongside the adoption of the Core Strategy. In line

with the new Development Scheme, the Draft Hampshire Minerals and Waste Plan was

submitted by the partners (now including the South Downs National Park Authority) for

consideration by the Planning Inspectorate in February 2012. The plan will replace the adopted

Core Strategy and the saved Local Plan policies. The Submission Plan was the relevant

document at the time research was carried out for this report and was based on a number of

evidence and assessment documents. Those reviewed for this study included:

Minerals in Hampshire: Background Study (Version 5) (the Hampshire Authorities, 2012);

Minerals Proposal Study (Version 5) (the Hampshire Authorities, 2012);

Safeguarding Study (Version 4) (the Hampshire Authorities, 2012);

Soft Sand Topic Paper (Version 4) (the Hampshire Authorities, 2012);

Provision of Soft Sand

4.13 The „proposed changes‟ apportionment for sand and gravel in Hampshire is 2.05 million tonnes

per year. However, the Hampshire Authorities consider that this apportionment figure does not

take into account local circumstances and supply. As such, in their Submission Plan (2012), a

figure of 1.56 mtpa of land-won sand and gravel is put forward for the period 2011 to 2030. This

is equivalent to 30mt over that period. Of this, 5.33 mt will be soft sand, equivalent to 0.28 mtpa4

(average sales of soft sand over the period 2001 to 2010). The authorities intend to meet this

soft sand requirement through:

existing reserves – 2.22 mt;

identified sites within the plan, including extensions and new sites – 4.03 mt.

4 Rounded figure



August 2012 10

4.14 Policy 20 of the Submission Plan (2012) identifies that the supply of soft sand will be provided

by maintaining a landbank of at least seven years from:

“a) the extraction of remaining reserves [at existing sites]5;

b) or extensions to [existing sites]6;

c) or new sand and gravel sites at ...:

Forest Lodge Farm, Hythe (soft sand / sharp sand and gravel) (Inset Map 10) – 0.57

million tonnes

Purple Haze, Ringwood Forest (soft sand / sharp sand and gravel) (Inset Map 12) –

4.0 million tonnes”7

4.15 Extensions and new sites must also “address the development considerations outlined in

Appendix A [of the Submission Plan]”.

4.16 Policy 208 also states that:

“Proposals outside the areas identified in the Plan could be supported where:

i. it can be demonstrated that the sites identified in the Plan are not deliverable;

ii. there is a demonstrated need for the development;

iii. the prior extraction of aggregate facilitates other development

4.17 Hampshire has identified a contingency sand and gravel reserve amount of 2.91mt in their plan

to come from un-allocated sites. This has been guided by evidence that 4.76mt of sand and

gravel has come from un-planned opportunities over the last 15 years. While Policy 20 applies

to all types of sand and gravel, no contingency figure is provided in respect of soft sand.

4.18 Hampshire does not currently propose a silica sand apportionment. In the recent Examination in

Public (EiP), discussion9 was had on whether the Tarmac site at Kingsley and the proposed

extension to the site (which is within the SDNP), should be considered as a silica sand site and

not as general construction sand. Hampshire produced a Silica Sand Topic Paper in May 2012.

This paper identified that, although the sands from Kingsley had specialist end uses as a “high

value non aggregate use namely for sports pitches”, they were not used for “„traditional‟ silica

sand uses in the glass, ceramics and foundry industries” and that other aggregates including

recycled aggregates could be used for the same end use as the Kingsley product. The

Hampshire Authorities concluded that they did not consider that the specialist end uses

constituted classification of the product as silica sand.

4.19 However, the Inspector agreed(8)

that the site should be considered as silica sand and has

asked for consideration of a modification to the Plan to this effect. The NPPF requires a silica

sand landbank of at least 10 years for individual silica sand sites. This has implications for this

study and these are discussed, where appropriate, in the remainder of this report.

Minerals Safeguarding

4.20 Mineral Safeguarding Areas (MSAs) are defined within the 2012 Submitted Plan on a Proposals

Map. The MSAs are based on the BGS resource mapping data and information “obtained from

„local knowledge‟ of mineral reserves” (Safeguarding Study, 2012) and therefore they include

5 for soft sand these are listed as: Blashford Quarry (soft and sharp sand), Frith End Sand Quarry and Kingsley

Quarry. 6 none are proposed that produce soft sand

7 Other sites are listed within this Policy 20 for sharp sand and gravel.

8 Since subject to modifications following the EiP.

9 Email from Peter Wilsdon, SDNPA, dated 13

th June 2012.



August 2012 11

most (but potentially not all) of the Folkestone Formation, Whitecliff Sand Member and the

mineral resources identified within the Bracklesham Group.

4.21 The Folkestone Formation soft sand resources near Whitehill and Bordon are specifically

identified for safeguarding as a prior extraction opportunity. Two potential sites identified at this

location were ruled out as potential allocations following earlier stages of site appraisal as the

deliverability of the sites is considered to be uncertain due to the development of the Whitehill-

Bordon Eco-town. This is in turn dependant on the vacation of the site by the Ministry of

Defence. This is documented in the Minerals Proposal Study. The Hampshire Minerals and

Waste Plan Soft Sand Topic Paper notes that, at February 2012, the MoD are likely to have

vacated the site by 2015 and that it is important that the soft sand reserves at Whitehill-Bordon

are safeguarded with a view to ensuring that the reserves are not unnecessarily lost through the

development of the proposed Eco-town. As such, these resources are afforded safeguarded

status under Policy 15 of the Submission Plan.

West Sussex

Plan Development

4.22 The Minerals Local Plan (MLP), adopted in May 2003 (and covering the period between 1999 to

2006) is being replaced by the West Sussex Minerals Local Plan (to cover the period to 2031).

4.23 The new Plan is being prepared jointly with the South Downs National Park Authority. It will

allocate „strategic sites‟ to meet the need for sand and gravel in West Sussex. The saved

policies of the earlier Plan will continue to form part of the statutory 'development plan' and

provide the local policy framework for development control decisions until they are replaced.

4.24 Preparation of the West Sussex Minerals and Waste Core Strategy was suspended October

2010. In May 2011, the Council decided to build on the work previously carried out (during the

preparation of the Core Strategy) by commencing work on separate minerals and waste plans,

with the waste plan to be begun first. Work that was completed for the Core Strategy for

minerals is provided in a series of „living draft‟ background papers and these are to be used to

inform the separate Waste and Minerals Plans.


4.25 The saved policies of the Minerals Local Plan, 2003 that pertain to the provision of sand include:

“Policy 29: The Mineral Planning Authority will aim to grant planning permission for the

supply of sand and gravel so that when added to permitted reserves, a total of 1.4 million

tonnes per annum (812,000 tonnes of sand and 588,000 tonnes of gravel) can be provided

in the period from 1.1.1997 to 31.12.2006. Thereafter the Mineral Planning Authority will

aim to grant further permissions which when combined with reserves, will provide a

landbank for the period 2006 to 2013 at a rate of 880,000 tonnes per annum (510,400

tonnes of sand and 369,600 tonnes of gravel).”

4.26 Separate amounts of sharp sand and soft sand were not identified in the 2003 plan as their

occurrence within the same pits was identified to be irregular and unpredictable. However, the

later „living draft‟ Background Paper10

3: Minerals (version 2, 2009, referred to here as BP3)

provides options for a split in the apportionment of soft sand and sharp sand and gravel to guide

the allocation of sites. The options given in BP3 are: no split in the apportionment; a split of

70:30, or; a split of 80:20 (both sets of split figures are rounded). These splits were put forward

as options on the basis of comments raised by the minerals industry and the average split in

production over the previous 8 years.

10

Note that all background papers were produced by WSCC prior to SDNPA assuming full powers, thus they are

subject to review by SDNPA prior to their information acting being relied for future Minerals Planning.



August 2012 12

4.27 The paper identifies how much soft sand and sharp sand and gravel would be required to meet

apportionment until the end of the plan period for these different splits. Based on this, the MPA

has identified that there will be a total requirement for sand and gravel of between 9.35mt and

13.09mt, which equates to between 5.93mt and 10.47mt for soft sand. However, the total

requirement referred to in BP3 was for the period 2009-2026 whereas the new Minerals Local

Plan will cover the period to 2031. Therefore the requirement over the longer period is likely to

be greater.

4.28 BP3 also presents options for maintaining the seven year landbank that include identifying

separate landbanks for soft and sharp sand and gravel. These would be based on ratios

identified for guiding site allocations. The landbank would be used as a tool for indicating when

new permissions may be required and in this way the requirements for soft sand and sharp

sand and gravel will be different according to the permitted reserve of each mineral type.

4.29 Saved policies from the 2003 Plan pertaining to specific site allocations, preferred areas or

areas of search are:

“Policy 32: The new sites identified for sand extraction pursuant to Policy 29 are:

Dunford Rough (Site No. 20) (Inset Map G)

West Heath (Site No. 26) (Inset Map H)”

“Policy 33: Planning permission will only be granted for the extraction of sand and gravel

from sites other than sites provided for, or proposed, in the Plan if there is no longer a

seven year landbank available, or sterilisation of mineral resources would be avoided as a

result, subject to environmental and other material considerations.”

“Policy 34: Planning permission may be granted for minor extensions at existing workings

subject to environmental and other material considerations, where sterilisation of mineral

resources would be avoided as a result or where, on balance, and environmental benefit

would occur.”

4.30 The anticipated total supply of sand from the two proposal sites was 2,920,800 tonnes at

Dunford Rough and 352,300 tonnes at West Heath. With existing permitted reserves at the start

of 2002 estimated at 6,806,000 tonnes, an over-provision of 1,735,100 tonnes of sand was

anticipated.

4.31 In terms of emerging policy, BP3 gives details on the environmental, historical and ecological

constraints that effectively define a search area for suitable future sand sites. Sites were

brought forward from the Minerals Development Plan Document (DPD) (2005) and a call for

sites exercise was undertaken.

4.32 Background Paper 5: Strategic Mineral Sites (version 2, 2009, referred to here as BP5) provides

details on the assessment and selection process for deciding which specific minerals sites

should go forward for consideration. Sites not considered acceptable „in principle‟ were rejected

at this stage, those that were considered acceptable „in principle‟ are contained within a „long

list‟ of sites11

. The potential quantity of soft sand resources in the long list sites is 12.75 million

tonnes. One of the long list sites (the extension to West Heath Quarry), has now been permitted

giving a potential quantity of 12.35mt.


4.33 In terms of Mineral Safeguarding policy in West Sussex, the entire Folkestone Formation is

considered a sub-regionally important resource and is included in the MSA (BP3, 2009). In West

11

The long-list of sites is only an indication of the sites that may be acceptable (as subject to approval by SDNPA).

This is not a final shortlist as any shortlist would be linked to the number of sites required to meet the

apportionment.



August 2012 13

Sussex the MSA is identical to the Mineral Consultation Area (MCA) as no additional sites have

been identified outside of the MSA. It is the intention of WSCC that the MSA identified in a BGS

Study12

will be refined and will form the basis of a policy to safeguard mineral resources. Two

options are presented for safeguarding of soft sand and sharp sand and gravel: one of which

excludes only previously worked sites and one which excludes both worked sites and urban

areas.

East Sussex

Plan Development

4.34 East Sussex MPA jointly prepare minerals local policy with Brighton and Hove Council and the

SDNPA. The Waste and Minerals Plan for East Sussex, South Downs and Brighton & Hove has

been submitted in June 2012 and until the new plan is adopted, the policies from the East

Sussex, and Brighton and Hove Minerals Local Plan (1999) are saved. A Minerals Development

Plan Document which will have details of sites for minerals extraction and processing, a

Proposals Map showing area- and site-specific policies will be prepared following the adoption

of the submitted Plan.


4.35 In the 1999 Plan, the MPA adopted a notional production figure of 0.3mt per annum (for sand

and gravel) for the purposes of testing future allocations for land won aggregates and the plan

seeks to supplement scarce land won supplies by planning for appropriate levels of imports and

by encouraging greater use of secondary aggregates and recycled material.

4.36 Under the Submission Waste and Minerals Plan, the revised annual apportionment of 0.1mt

(from the Proposed Changes to the South East Plan) is to be met through existing planning

permissions. The annual allocation of 0.1mt of sand and gravel is to be met by the existing 7

year landbank of 0.8mt to 2017 or 1.7mt to 2026.

4.37 A separate soft sand apportionment is not proposed for the plan area as the soft sand resource

in East Sussex is particularly limited and production has been intermittent. In East Sussex, the

soft sand bed covers only 67 hectares of unsterilised mineral resource (outside the village of

Ditchling).

4.38 In reference to the recommendation by the Secretary of State to consider provision of resources

outside of the National Park first, the submission Plan (2012) outlines the approach of the

SDNPA to work with East Sussex, West Sussex and Hampshire County Councils, to find an

acceptable solution across the wider area. Parts b and c of Policy WMP 1 are relevant:

“Policy WMP 1. Minerals and waste development affecting the South Downs National

Park...

b) Major minerals and waste development in the South Downs National Park should not

take place except in exceptional circumstances, where it can be demonstrated to be in the

public interest. In this respect, consideration will be given to:

the need for the development, including in terms of any national considerations; and

the impact of permitting or refusing the development upon the local economy; and

the cost of and scope for developing outside the designated area or meeting the

need in another way; and

any detrimental effect on the environment, landscape and/or recreational

opportunities and the extent to which it could be satisfactorily mitigated.

12 British Geological Survey (2007). Mineral Safeguarding Areas and Mineral Consultation Areas for West Sussex.



August 2012 14

Development will only be in the public interest if the outcomes of i-iv above gives sufficient

reason/s to override the potential damage to the natural beauty, cultural heritage, wildlife or

quiet enjoyment of the National Park.

c) Extensions to existing soft sand quarries or new quarry proposals in the National Park

need to conform with (b) and additionally demonstrate that the need could not be

practically achieved by extraction in adjoining Counties...”

4.39 In the East Sussex Minerals Local Plan (1999) Policy 3 identifies only one soft sand site as a

preferred site – Stanton‟s Farm. The submission Plan (2012) identifies Stanton‟s Farm as the

permitted soft sand reserves that will aid maintaining the seven year landbank and contribute to

the combined sand and gravel apportionment for the Authority. This site has an annual

production of up to 30,000 tpa (as reported by the operator), with an approximate 120,000t of

remaining reserves). However, this site‟s permission is noted to expire in 2016 and therefore

soft sand is only provisioned for in the early part of the plan period (to 2017)13

. For the

remainder of the period the total apportionment is met by sharp sand and gravel.

4.40 Work on a site allocations document is intended to commence within 12 months of the adoption

of the Plan.


4.41 MCAs under the 1999 plan included all existing sites and the identified areas of search and

preferred sites. Minerals safeguarding under the proposed submission Plan (2012) is through

the application of MCAs around specific permitted sites. Thus, the MSA/MCA for soft sand is the

Stanton‟s Farm site. The Plan states that other non-strategic mineral resources that might need

protection will be identified through the Plan review process and in the Minerals Sites DPD.

Surrey

Plan Development

4.42 The Surrey Minerals Plan (SMP) was adopted in July 2011 and it plans for the period 2009 to

2026. The Minerals Core Strategy DPD and Primary Aggregates DPD were adopted in

November 2010 and January 2011, respectively. The DPDs within this replaced the saved

policies of the Surrey Minerals Local Plan, 1993.


4.43 Surrey supported the 2010 proposed changes to the apportionments which meant a reduction in

their apportionment from 2.62mtpa to 1.27mtpa. Because the plan spans the changes in

apportionment, the Primary Aggregates DPD (2011) assumes a requirement of 2.62mt for 2009.

Thus, the equivalent total amount required over period is 22.94mt. By applying a sales based

ratio between sand and gravel and soft sand, the proposed changes apportionment results in a

split apportionment of 15.57mt and 7.33mt, respectively. This is identified as a „low‟ estimated

resource requirement when compared to that which would result from use of the original

apportionment figure (identified as a „high‟ estimate in the DPD).

4.44 The DPD identifies proposals in preferred areas that will be available over the plan period, it

does not identify areas of search. The plan estimate is that these areas, plus the remaining

existing reserves, would be sufficient to deliver 23.96mt. On this basis, Policy MA1 of the DPD

states that provision will be made for 24mt of primary aggregate which comprises “15 million

tonnes of concreting aggregate and 9 million tonnes of soft sand between 2009 and 2026”.

13

This is a provisional stance as there is a lack of evidence and deliverability. In reality there could be supply post

2016 if planning permission is renewed.



August 2012 15

4.45 As for the apportionment estimates, the split between provision for concreting aggregate and

soft sand was based on average sales figures.. Using the „low‟ estimate of the soft sand

resources required, Surrey identify that 1.65mt needs to come from preferred areas and that this

could be met by reserves at Mercers Farm, Nutfield Marsh (2.70mt). .

4.46 Surrey‟s Core Strategy states that there is a presumption against major new workings of soft

sand within the Surrey Hills AONB as their requirement can (reportedly) be met from outside the

designated area. However, the Core Strategy DPD notes a recognised national scarcity of silica

sand “for which there is no suitable alternative”. There is, however, a silica sand preferred area

(and area of search) at Pendell Farm (which adjoins existing works at North Park Quarry,

Bletchingley) within the AONB and an application for silica sand extraction has since been

approved. An additional silica sand area of search is at Chilmead Farm., outside the AONB.

Consideration of Green Belt land also applies in this area.


4.47 Safeguarding of soft sand resources in Surrey is via Proposals Maps. There are six specific

areas within the Folkestone Formation in which soft sand MSAs have been mapped. All of these

areas fall within the Folkestone Formation resource.

Kent

Plan Development

4.48 Kent have begun development of their Minerals and Waste Core Strategy which will supported

by a Minerals Sites Development Plan Document. The development of the Core Strategy and

Minerals Sites DPD had reached options consultation stage at May 2011 and the 'Preferred

Options' consultation for mineral sites is currently „live‟ (28 May to 23 July 2012). The

publication and pre-submission consultation is scheduled for September 2013.


4.49 Kent‟s apportionment of land-won sand and gravel under the „proposed changes‟ is 1.63mtpa.

The NPPF now requires MPAs to prepare an annual Local Aggregate Assessment (LAA) based

on a rolling average of 10 years sales data and other relevant local information, assessing all

aggregate supply options. Kent‟s draft LAA shows that the apportionment for land-won sand

and gravel of 1.63mtpa closely reflects the average of the most recent ten years of available

sales data and Kent therefore identify that this figure is still valid.

4.50 The preferred option is not to split the land-won aggregate landbank on the basis that the ratio

of sharp sand and gravel to soft sand is thought likely to change over the plan period (“some of

the traditional areas of gravel working in the County are being exhausted or reducing outputs

considerably”, Core Strategy - Strategy and Policy Directions Consultation, 2011). The

Preferred Options document notes that “the majority of sites promoted to the County Council for

consideration were for soft sand leaving insufficient sharp sand & gravel sites to maintain a

separate landbank for these two types of mineral for the plan period”.

4.51 There are 25 preferred option sites for mineral development 7 of which are specifically soft sand

sites. Together, these soft sand sites represent a potential reserve amount of 17.06mt, and

23.53mt in total for sand & gravel.

4.52 One of the preferred option soft sand sites in Kent also has identified resources of silica sand (in

a ratio of roughly 2:1 silica:soft sand) which would “provide an estimated reserve landbank of 10

years according to the current rates of consumption”.



August 2012 16


4.53 The preferred option for mineral safeguarding is to apply this to scarce, high value minerals and

this reported to include the Folkestone Formation soft sand and silica sand. MSAs will be

included on a Core Strategy Key Proposals Map and in the Mineral Sites DPD.

4.54 Policy CSM4 in the Core Strategy states that safeguarding will be applied to areas of known soft

sand and that MCAs will be identified adjacent to Specific Sites.

4.55 Kent County Council published „Minerals Topic Report 4: Mineral Safeguarding‟ in May 2011

which uses the BGS map „Un-sterilised Soft Sand Resources in Kent and Medway‟ to form the

basis of their safeguarding policy. The map separates areas of resource on the basis of „no

environmental constraints‟, „one constraint‟ and „two or more constraints‟. Subject to refinement,

it is said that these areas will be safeguarded and likewise, areas of urban development will be

refined and removed.

Summary

4.56 There are some important differences between the approaches to Minerals Planning for the

study area‟s MPAs and for those with nearby soft sand resources (Kent and Surrey). These are:

the stage at which minerals planning has reached in each MPA (therefore for some MPAs

there is more certainty for the next plan period and/or an advanced evidence base);

how the plans define where future resources will come from (i.e. using areas of search,

preferred areas and/or allocated sites);

how the MSAs have been developed (i.e. whole outcrop approach, selective approach

based on constraints and/or named areas);

the proposed apportionment figure (in some cases this is close to the „proposed changes‟

figure, in some it is not);

the identification of apportionments for specific mineral types (no split or a soft sand/sand

and gravel split), and;

the need to plan for minerals extraction within the SDNP (and other landscape

designations) in order to meet apportionments e.g. West Sussex has identified

„acceptable in principal‟ sites within the SDNP, while Hampshire plan for sand resources

outside of the SDNP (current consideration of the Kingsley extension site

notwithstanding).

4.57 As a result of the recent Hampshire EiP, all or some of the reserves remaining at the Kingsley

site do not now form part of the permitted soft sand landbank for Hampshire. Kingsley has been

agreed as a silica sand site by the Inspector and as such Hampshire are drafting a plan

modification to reflect this.

5. Trends in Demand & Permitted Reserves


August 2012 17

5. Trends in Demand & Permitted Reserves 5.1 This section looks at the regional and local trends in sales for sand and gravel and the portion of

that which is soft sand. This section also deals with provides an overview of the past and current

permitted reserves both regionally and for the study area.

Regional Trends in Demand

5.2 Sales information is shown below in Table 5.1.Overall, sales of land-won sand and gravel over

the period 2002 to 2009 inclusive have decreased. However, despite showing year on year

changes, the soft sand sales do not show a comparable downward trend.

5.3 Published information regarding anticipated future trends in demand have not been identified,

however, the Mineral Products Association has been able to provide more recent figures for the

sales trends (reproduced in Table 5.2 below which includes both land-won and marine dredged

sand and gravel: separate figures are not available). These figures (which are based on a

reportedly large sample of the market) show that after 2009 sales have recovered, with a more

marked recovery in the South East when compared to Great Britain as a whole. In terms of

emerging or expected trends in demand, this correlates with reporting by one mineral industry

representative of increased demand for sand and gravel in 2011, and the prediction by another

representative that demand is expected to be greater in at least the next 2 to 3 years.

Year Sales (million tonnes)

S&G Soft Sand

2000 12.63 0.32

2001 12.44 0.31

2002 11.48 3.06

2003 10.64 2.66

2004 10.41 2.62

2005 9.71 1.75

2006 8.80 1.78

2007 8.50 1.91

2008 7.30 2.27

2009 6.10 1.39

Table 5.1 Sales for the South East Region (source: collated from the South East Aggregates Monitoring Reports for 2000 to 2009).

Year S&G

1 Sales (% change on previous year)

Great Britain South East of England

2009 -23% -18%

2010 No change +3%

2011 +5% +10%

Table 5.2 Change in sand and gravel sales volumes for Great Britain and the South East Region (source: Mineral Products Association, 2012).1. includes both landed and primary sand and gravel, for which the relative proportions are expected to be broadly similar over the period.

Local Trends in Demand

5.4 Table 5.3 below provides approximate sales figures for the MPAs over the period 2000 to 2010.

The data within this table should be treated with caution as they are likely to be best estimates

made by those who collated the original sources.

5.5 In West Sussex, overall sand and gravel sales were greater at the start of the period between

2000 and 2004, with a decline in sales observed thereafter to 2009. Soft sand sales (whilst the

figures are not consistently available) were also greater at the start of the period (between 2000

0

2

4

6

8

10

12

14

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

To

nn

es (M

illio

ns

)

Sales - S&G Sales - Soft Sand



August 2012 18

and 2004) and show a sharp decrease between 2004 and 2005. A slight decrease in sales is

shown thereafter to 2009.

5.6 For Hampshire overall sand and gravel sales decreased between 2000 and 2010 (with the

exception of 2007) and each year remain the highest sales of the three MPA areas. Sales of

soft sand also decreased between 2000 and 2009 (with the exception of 2008), 2010 shows a

slight increase in sales. As such, the 10-year average of soft sand sales in Hampshire is 0.28

million tonnes per year (Soft Sand Topic Paper, 2012).

5.7 Figures for East Sussex cannot be obtained due to confidentiality reasons; annual figures would

reflect individual sites.

Year Hampshire West Sussex East Sussex

Total S&G Soft Sand Total S&G1 Soft Sand

1 Total S&G Soft Sand

2000 2.41 0.71 0.8 0.6 C C

2001 2.29 0.50 1.0 0.7 C C

2002 2.19 0.38 0.9 0.7 C C

2003 1.81 0.31 0.9 0.7 C C

2004 1.67 0.36 0.8 0.6 C C

2005 1.58 0.31 0.6 0.5 C C

2006 1.24 0.19 0.5 0.5 C C

2007 1.49 0.18 0.5 0.5 C C

2008 1.27 0.29 0.4 0.4 C C

2009 1.05 0.11 0.3 0.3 C C

2010 0.98 0.14 0.3 0.3 C C

Table 5.3 Sales in million tonnes (approximately end of year) by MPA. ?: figure not identified. C: confidential figure. (sources: where possible, the MPAs have verified or supplied the figures. In the case of West Sussex, these are estimates only. A portion of the sand and gravel reserves in East Sussex is confidential and so figures provided do not include this data. AMRs, SEERAWP reports and MWDF documents have also been used).

Regional Permitted Reserve Trends

5.8 Between 2000 and 2009, the permitted reserves of sand and gravel within the whole of the

South East fell from ~140mt to ~80mt. However, since the regional apportionment also

decreased during this period, the declining reserves have been sufficient to reduce to, and then

maintain, an approximate landbank of just under 7 years in the latter part of the period.

Permitted soft sand reserves have also fallen, in a similar pattern to the overall totals for sand

and gravel. In the absence of a separate apportionment figure for soft sand, this cannot be

assessed in terms of a regional landbank.

Year Permitted Reserves (million tonnes)

S&G Soft Sand

2000 139.56 60.09

2001 129.67 54.43

2002 121.36 46.74

2003 97.09 28.41

2004 80.81 26.95

2005 87.29 19.98

2006 76.43 18.82

2007 78.13 24.30

2008 84.69 30.66

2009 79.05 21.30

Table 5.4 End of year permitted reserves for the South East Region (source: collated from the South East Aggregates Monitoring Reports for 2000 to 2009).

0

1

2

3

4

5

6

7

8

9

10

11

12

13

14

0

10

20

30

40

50

60

70

80

90

100

110

120

130

140

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

To

nn

es (M

illio

ns

)

S&G Soft Sand S&G Landbank

Eq

uiv

ale

nt S

&G

La

nd

ba

nk

(Ye

ars

)



August 2012 19

Local Permitted Reserve Trends

5.9 The permitted reserves for West Sussex, East Sussex and Hampshire are shown in Table 5.5.

The data within this table should be treated with caution as they are likely to be best estimates

made by those who collated the original sources and because the reserves are subject to

frequent reassessment by the mineral operators.

5.10 For Hampshire, there has been a general downward trend in permitted sand and gravel

reserves until 2008 though reserves are estimated to have increased to 16.44mt by 2011.

5.11 In West Sussex, there has been a downward trend similar to that of Hampshire, and likewise the

permitted reserves of soft sand have increased since 2007.

5.12 In East Sussex, the sand and gravel landbank has been consistently high at around 38 years, a

result of large existing planning permissions. Most of the available resources are located close

to the Kent border. Reserves of soft sand in the western part of the county are limited to a single

small site (Stanton‟s Farm), which currently has a permission expiry date of 2016).

Year Hampshire West Sussex East Sussex

S&G Soft Sand S&G Soft Sand S&G Soft Sand

2000 17.04 4.88 8.22 7.06 C C

2001 14.00 4.14 7.72 6.81 C C

2002 13.73 2.38 6.55 5.85 C C

2003 12.12 2.03 5.96 5.04 C C

2004 10.54 2.29 5.08 4.35 C C

2005 10.89 0.55 4.75 4.57 4.55 0.38

2006 9.80 1.87 4.21 4.11 4.55 0.38

2007 9.22 3.19 3.74 3.66 4.55 0.38

2008 7.63 2.94 4.84 4.79 4.55 0.38

2009 14.30 2.17 5.49 4.56 4.55 0.38

2010 14.00 2.22 5.37 4.44 4.10 0.12

2011 16.44 2.22 ? ? 4.10 0.12

Table 5.5 Permitted reserves in million tonnes by MPA (approximately end of year, rounded figures). ?: figure not identified. C: confidential figure. (sources: where possible, the MPAs have verified or supplied the figures. In the case of West Sussex, these are estimates only. A portion of the sand and gravel reserves in East Sussex is confidential and so figures provided do not include this data. AMRs, SEERAWP reports and MWDF documents have also been used,)

6. Permitted Soft Sand Sites, Markets & End Uses


August 2012 20

6. Permitted Soft Sand Sites, Markets & End Uses 6.1 This section provides information on existing soft sand quarry sites and the potential future

sites, where they have been allocated in mineral plans. It also looks at the end uses of soft sand

from particular quarries. In order to obtain this information, minerals industry representatives

were contacted, along with reference to plan documents and directories. All sites identified in

this section and in Section 7 are shown on the Figures B.1 to B.3 in Appendix B.

Permitted Soft Sand Sites

6.2 Existing sites in the three MPAs that are adjacent to the SDNP (as identified for 2011) are

shown in Table 6.1 below. All sites are marked on Figures B.1 to B.3, in Appendix B, in green.

County Site Status Within the SDNPA?

Hampshire

Kingsley Quarry (Rookery Farm) Active No, but adjacent

Frith End Sand Quarry Active No, but adjacent

Blashford Quarry (Plumley Wood / Nea Farm) Active No, ~40km away

West Sussex

West Heath Quarry and extension1 Active Yes

Minsted Sandpit Active Yes

Sandgate Park Quarry Active No, but adjacent

Rock Common Sandpit Active No, but adjacent

Heath End Quarry Inactive Yes

Hampers Lane Sandpit Inactive No, but adjacent

East Sussex Stanton’s Farm (Novington Sandpit) Active Yes

Table 6.1 Existing quarry sites in the study area with permitted reserves of soft sand. 1. the extension was a long list site in 2009 (see Section 7) and was granted planning permission in 2010.

MPA Site Status

Surrey

Runfold South Quarry Area C Active

Homefield Sandpit Active

Reigate Road Quarry Active

North Park Quarry (Sand and Silica Sand) Active

Moorhouse Sandpits Active

Farnham Quarry (Wrecclesham) Inactive

Woodhill Sandpit Dormant

Kent

Addington Sand Pit (Wrotham Quarry) Active

Aylesford Quarry (Sand and Silica Sand) Active

Borough Green Sandpits (Sand and Silica Sand) Active

Charing Quarry (Swan Lane) Active

Chilston Quarry Lenham Inactive

Ham Hill Sandpit Inactive

Ightham Sandpit Active

Joyce Green Quarry (also produces sand and gravel) Inactive

Nepicar Sand Pit Active

Ospringe Brickworks Inactive

Sevenoaks Quarry Active

Shepherd's Farm Quarry, Lenham Inactive

Squerryes Court Quarry Inactive

Winterbourne Quarry Active

Table 6.2 Existing quarry sites in Surrey and Kent with permitted soft sand reserves. Sites as identified in Minerals and Waste Planning in Surrey - Annual Monitoring Report 2010-11 (Surrey County Council) and TRM1: Draft Local Aggregate Assessment (May 2012) (Kent County Council).

6.3 For the sites situated within the SDNP (as given in Table 6.1), there is an estimated total

remaining permitted reserve of around 1.8mt of soft sand. This estimate is based on remaining



August 2012 21

reserves reported in conversations with the mineral operators of the individual sites and on

historical planning permission information; it includes some reserves that may be subject to

obtaining time extensions for extraction and, as such, this figure should be treated with caution.

6.4 Sand quarries in Kent and Surrey, include those in Table 6.2 above (and these are marked on

Figures B.2 and B.3 in green). The active/inactive status has been based on discussions, where

these have been held, with mineral operators or identified within the most recent planning

documentation available.

Current Markets and End Uses for Soft Sand

6.5 For existing sites within the study area, Table 6.3 (below) provides detail on the end uses of soft

sand and the demand in terms of main markets. Similar information is given for Kent and Surrey

in Table 6.4. The location of these sites is shown in Figures B.1 to B.3.

County Site Uses & Markets

Hampshire

Kingsley Quarry (Rookery Farm)

Currently 75% of sand sales are for specialist end uses as the extracted sand is high in silica and matches the horticultural sand curve well. The sand is blended with imported soil and this „Kingsley Mix‟ is used within playing pitches, especially football pitches and golf courses, travelling as far as Birmingham, Bristol and Wales (up to around 200 miles). Another specialist sand end use is for filtration. The remaining 25% of sand sales is primarily for use as a building sand with a smaller proportion used in concrete.

Frith End Sand Quarry

There are two main end uses of the sand: the majority is used as a mortar sand and the remainder is mixed with marine aggregates, replacing the fines washed away by dredging so that the end mix can be used in concrete. The sand travels to wharves at Portsmouth and Southampton and is then used within these local areas. Approx. 1/3 of the sand has specialist end use, and the operator considers the sand extracted to be similar to that at Kingsley.

Blashford Quarry (Plumley Wood / Nea Farm)

Both sites have sand and gravel (sharp sand) overlying soft sand. The soft sand is from the Poole Formation containing more silt than the soft sand making up the Folkestone Beds and does not meet specialist sand grading curves. (The sand is used mainly as a building sand, primarily for mortar and serves the local market (not travelling more than 30 miles).

West Sussex

West Heath Quarry and extension (West Hampshire)

The sand is primarily used as building sand and much is transported to the operator‟s Kingsmead processing site, near Heathrow, where it is mixed with other quarry products to serve the west London market. Sand also travels to nearby Petersfield and to builders merchants on south coast. Finer material is transported to wharves in Portsmouth and is mixed with marine aggregate to assist in lowering the chloride content for concrete end uses. A specialist sand end use includes bedding for cattle as micro-organisms grow very slowly within the clean sand.

Minsted Sandpit

About 95% of the sand has a concrete products end use, predominantly roof tiles and serves a wider market of up to 45 miles. The remaining 5% of the sand is use in specialist applications such as for polo pitches and golf bunkers.

Sandgate Park Quarry About 75% of the sand is transported to the operators ready-mix plant near Crawley, 40 miles away for use as a building sand. The remaining 25% is used within the onsite concrete plant.

Rock Common Sandpit About 80% of the sand is used as a building sand, with the remaining 20% of the sand having a specialist s end use within golf bunkers and for equestrian applications.

Heath End Quarry The new operator has not yet commenced operations but anticipates a 50% building sand end use and a, 50% concrete products end use.

Hampers Lane Sandpit Building sand / concreting sand

East Sussex

Stanton‟s Farm (Novington Sandpit)

The sand is used entirely as a building sand, mainly within mortar.

Table 6.3 Summary of reported end uses and markets for permitted soft sand sites in the study area.



August 2012 22

MPA Site Uses & Markets

Surrey

Runfold South Quarry Area C

Building and construction

Homefield Sandpit Building sand, as dug aggregate and construction sand

1

Construction sand3

Reigate Road Quarry Graded sand & gravel, construction sand and building sand

1

Glass sand, dried sand, foundry sand, equestrian sand, leisure sand, industrial sand, bagged sand, sports sand.

2

North Park Quarry Glass sands, coloured glass sands, sodium silicate sands, foundry sands, asphalt and mortar sands, rootzones, urban tree soil, mineral filler sands

2. Sand for equestrian use

3.

Moorhouse Sandpits Building sand and plasters

1

Construction sand, industrial, non construction3

Kent

Sevenoaks

Soft sand sales from here travel to the south coast for mixing with marine dredged sand and are primarily used in concrete rather than as a building sand and have been used in high-profile projects including “the Gherkin, the Chelsea and Arsenal football stadiums, Wimbledon Centre Court and the Globe Theatre”

4

Borough Green Sandpits

Building sand* Construction aggregate (non construction aggregate)

3

Charing Sandpit (Swan Lane)

Building sand* Building and asphalt3

Lenham Quarry Concreting sand, building sand1

Snodland (Ham Hill Sandpit)

Building sand, construction sand1

Squerryes Court Quarry

Sand for brick or tile manufacture1

Winterbourne Quarry West

Building sand5

Ightham Sandpit Building sand5

Table 6.4 Summary of reported end uses and markets for soft sand in permitted sites in Kent and Surrey 1.Uses description from the Directory of Mines and Quarries, 2010, BGS. 2. http://www.samsa.org.uk/who_locations01.htm 3. GWP report, 2010 4. Minerals Planning Magazine, 01 June 2010 „Aggregates - Sevenoaks quarry wins consent for extension‟ 5. Kent Core Strategy consultations document

Discussion

6.6 The radius of economic transportation of sand and gravel is often quoted as being generally

less than 30 miles. However, it is clear from Table 6.4 that soft sand in the South East does in

many instances travel over greater distances. There would appear to be a number of reasons:

For national operators, such as CEMEX, the product is transported to the nearest ready-

mix plant, such as that based at Kingsmead near Heathrow. This means the product

travels up to 45 miles for processing with onward travel to more distant places, such as to

the West London market.

One end use of the soft sand is to mix with marine aggregates to replace the finer

material washed away by dredging and to assist in meeting the chloride content required

for concreting purposes. In these instances, the product travels to the nearest wharves

which again may be up to 45 miles distant.

For the smaller operators, the sand is often used more locally but manufactured products

(such as roof tiles) will again travel up to 45 miles for longer term, larger demand

contracts.

Finally, where the soft sand is being used for a specialist silica sand end use, such as in

sports pitches, then distances travelled may be up to 200 miles.

http://www.samsa.org.uk/who_locations01.htm

7. Provision of Soft Sand in the Current Plan Period


August 2012 23


7.1 The Plans for East Sussex, West Sussex and Hampshire, which are all being prepared jointly

with the SDNPA, are in various stages of development (see Section 4). Potential sites or areas

for future working, and their success (or lack thereof) at Plan selection stages are provided in

Tables 7.1 to 7.4 below. All sites identified in this section are shown on the Figures B.1 to B.3 in

Appendix B (potential sites are identified by orange markers and rejected sites are marked in

red).

Hampshire Allocations

7.2 Information on the Hampshire sites that are potential future allocations comes from their work in

preliminary assessment (documented in the Minerals Proposal Study) and for those sites put

through the subsequent interim and draft Integrated Sustainability Appraisal (ISA). As Table 7.1

shows, only Forest Lodge Farm and Purple Haze were recommended for inclusion in the draft

Plan following completion of the appraisal work. Two potential areas at Whitehill - Bordon were

recommended for specific safeguarding, as a potential opportunity for prior extraction, due to

the known development pressures in this location (the development of the Whitehill-Bordon

Eco-town). The site identified within the Plan at Bleak Hill is allocated for sharp sand and gravel

(0.5mt), but a small soft sand reserve is also likely to be found in this location.

7.3 Purple Haze may potentially be allocated as the best option for continuing a local supply for

west Hampshire and, similarly, Forest Lodge Farm is considered the best option for continuing

local supply in south Hampshire.

7.4 The potential site allocations in Hampshire for the period up to 2030 total 11.57mt for sand &

gravel and the portion of that which is soft sand equates to 4.03mt. None of the potential

reserves are within the area now covered by the SDNPA. However, the safeguarded sites at

Whitehill-Bordon are approximately 500m from the SDNP boundary.

7.5 Note that Table 7.2 below includes the Kingsley site, as this was considered and rejected during

the allocations process as it was considered that other soft sand sites would have less

sustainability impacts. This site and the potential implications of its promotion as a silica sand

site are discussed at the end of this section.

Site Within the SDNPA?

Status (most recently reported) Estimated Reserve

Forest Lodge Farm

No, ~20km away

PROPOSED ALLOCATION: This site was considered at ISA to be appropriate for inclusion within the Minerals and Waste Plan. The proposal would feed the South Hampshire market area. The proposal is considered to be the most sustainable option for this type of extraction within this area.

400,000

Purple Haze No, ~40km

away

PROPOSED ALLOCATION: Recommended in 2011 for inclusion in the plan. The proposal would feed the west Hampshire and surrounding market areas. The proposal is considered to be the most sustainable option for this type of extraction within this area.

7,250,000 (3,625,000)*

Whitehill Bordon A

No, <500m

away

PROPOSED SAFEGUARDED AREA: Recommended for safeguarding at ISA. The site is not considered to be suitable for allocation within the Minerals and Waste Plan, however, the soft sand reserves should be specifically safeguarded through policies on the protection of mineral resources from sterilisation. Area is only suitable for specific safeguarding. Deliverability of the Eco-town is uncertain. Reserves only provide an opportunity for prior extraction

Not known

Whitehill Bordon B

No, <500m

away

PROPOSED SAFEGUARDED AREA: Recommended for safeguarding at ISA. The site is not considered to be suitable for allocation within the Minerals and Waste Plan, however, the soft sand reserves should be specifically safeguarded through policies on the protection of mineral resources from sterilisation. Area is only suitable for specific safeguarding. Deliverability of the Eco-town is uncertain. Reserves only provide an opportunity for prior extraction

Not known

Table 7.1 Site options proposed as potential allocations in Hampshire

*A maximum of 4mt of sand and gravel will be available within the plan period, which includes up to 3.625mt of soft sand (Hampshire Minerals and Waste Plan (Submission).



August 2012 24


Status (most recently reported) Estimated Reserve

Dunwood Nurseries

No, ~20km away

At Integrated Sustainability Appraisal (ISA) the site was not considered to be suitable for allocation within the Minerals and Waste Plan. This is based on potential impacts on communities, amenity, health and quality of life. The cumulative impacts of this proposal working alongside other nearby minerals and waste developments is also considered to be potentially significant. There are other proposals considered to have less sustainability impacts.

600,000

Frith End Sand Quarry Extension C

No, <1km

away

This potential extension was identified in the draft Hampshire Minerals Plan as Area 4. It lies 0.6 miles south of the South Downs National Park Boundary. However, in July 2010 the potential mineral operator indicated that that the new landowners no longer wanted to promote the site for mineral extraction. The site is considered to be undeliverable at this stage.

400,000

Frith End Sand Quarry Extension D

No, <1km

away

Previously considered up to Regulation 26 for the draft Hampshire Minerals Consultation Plan, now considered to be undeliverable. In 2011, confirmation was received that the landowners of the site do not now support its nomination for mineral extraction. This site is therefore now considered undeliverable at this stage.

1,000,000

Frith End Sand Quarry Extension E

No, <1km

away

Not considered to be suitable for allocation at ISA, based on potential impacts on landscape and townscape, transportation, communities and amenity and health and quality of life. Other proposals are considered to have less sustainability impacts.

1,800,000

Frith End Sand Quarry Extension F

No, <1km

away

Considered unsuitable and ruled out at ISA stage. Extension of existing site 250,000 tonnes The site has not previously been considered 750 metres south of the South Downs National Park boundary The proposal is for an extension to Frith End Quarry an existing, permitted and active mineral extraction site with a demonstrated operating performance. There is not enough information to fully appraise this site at this stage. It is therefore not considered to be suitable for further appraisal at this stage.

250,000

Glebe Farm No, ~20km

away

This possible new site is not considered to be suitable for allocation within the Minerals and Waste Plan, based on landscape and townscape, communities, amenity, health and quality of life. The cumulative impacts of this proposal working alongside other nearby minerals and waste developments is considered to be potentially significant. Other proposals are considered to have less sustainability impacts.

700,000

Kingsley Quarry Extension

Yes

This possible extension site was rejected at ISA stage. The site is located within the South Downs National Park. Other opportunities for the extraction of soft sand which lie outside of designated areas. There may be impacts on prudent use of resources, communities and amenity and health and quality of life. Other proposals are considered to have less sustainability impacts.

2,000,000

Malthouse and Osbourne

No, ~700m away

Rejected at ISA stage. This is based on potential impacts on landscape and townscape, communities and amenity and health and quality of life. There are other proposals which are considered to have less sustainability impacts.

1,800,000

Post Hill Farm No, ~20km

away

Rejected at ISA stage. This is based on potential impacts on landscape and townscape, communities, amenity, health and quality of life. The cumulative impacts of this proposal working alongside other nearby minerals and waste developments is considered to be potentially significant. Other proposals are considered to have less sustainability impacts.

965,000

Table 7.2 Site options rejected as potential allocations in Hampshire

7.6 The potential implications of classifying Kingsley Quarry as a silica sand site (in the recent

Hampshire Minerals and Waste Plan EiP) and the subsequent requirement for Hampshire to

plan for silica sand relate to: the defining and meeting of apportionments for soft sand/sand &

gravel, and; the environmental criteria against which site allocations and planning applications

are judged. The following discussion draws upon information from Sections 4 and 6.

7.7 If Kingsley is reclassified then the implications for aggregate apportionments, in particular soft

sand apportionments, is not clear14

. It may be assumed that part or all of the „soft sand reserves‟

at Kingsley that contribute to the current Hampshire landbank will be deducted and that there

may a reduction in the soft sand apportionment. If there is no reduction in apportionment, there

may need to be an increase in other allocations to cover this „deficit‟ unless the remaining

reserves at Kingsley are very limited, and then the potential allocations at other sites may be

sufficient for the coming plan period (an analysis of the soft sand provision situation across the

study area is given in Section 8).

7.8 In terms of weighing up the environmental factors against the need for minerals extraction, the

classification of the Kingsley site as silica sand may set an important precedent. For example

14

Legal opinions are awaited (Lisa Kirby, Hampshire County Council, pers. comm. July 2012).



August 2012 25

there are reportedly other sites that may have similar specialist end uses for a portion of their

product. Broadly speaking, these could be seen to include:

Rock Common (a rejected site in West Sussex, adjacent to the SDNP: an existing site in

this area has 20% specialist end use)

Minsted West (a long list site in West Sussex, inside the SDNP: an existing site in this

area has 5% specialist end use)

Heath End (a currently inactive site in West Sussex, inside the SDNP: 50% specialist end

use)

7.9 However, the implications of the successful argument by Tarmac may be that sites that would

otherwise be put forward as soft sand sites could, in the future, be put forward for whole or

partial classification as silica sand sites regardless of whether the end use of the material is

„industrial‟ (as defined in the Technical Guidance to the NPPF) or „specialist‟. This clearly has

implications for a site‟s strategic importance in the judgement between national need and

national landscape protection.

7.10 A legal opinion is being sought on the issues raised by this classification of the Kingsley

extension and Hampshire County Council are considering how they will respond.

West Sussex ‘Long List’ Sites

7.11 For West Sussex, the sites in Tables 7.3 and 7.4 below are those identified through the long-list

process, as documented in the „living draft‟ Background Paper 5: Strategic Mineral Sites

(December 2009). Of the 20 sites, 8 were identified as „acceptable in principle‟ (Table 7.3) and 7

of these were within the SDNPA boundary.

7.12 The 0.565mt extension to West Heath Quarry was permitted in 2010 (included in active sites

table above and in Table 7.3 below). Horncroft Quarry/ Coates Quarry was applied for but then

withdrawn (at this time the SDNPA had raised an objection due to lack of exceptional

circumstances and ambiguity over future level of supply from within the Park).

7.13 One previously allocated site (Dunford Rough, within the area now covered by the SDNPA) was

rejected at the long list stage as a result of restrictive covenants and access difficulties.

These long list sites may or may not be taken forward to allocation, depending on the next

stages of West Sussex‟s Plan development, but those sites that fall within the SDNPA boundary

have an identified potential soft sand reserve of 12.065mt (including West Heath Extension and

Horncroft).



August 2012 26


Status Estimated Reserve

Chantry Lane Extension

Yes

Long list site, 2009: Acceptable in principle subject to: assessment of impact on landscape character; buffers to waterbodies; retention of hedgerows; protected species assessment; mitigation of impacts on archaeological remains; flood risk assessment; new access from the A283.

350,000

Duncton Common Yes

Long list site, 2009: Acceptable subject to: assessment of impact on landscape character; ecological assessment; buffers to SNCI, SSSI and ancient woodland; archaeological assessment; flood risk assessment; assessment of impact on nature conservation; diversion of PRoW.

1,800,000

East of West Heath Common

Yes Long list site, 2009: Acceptable in principle subject to: protection/mitigation of PRoW; screening to protect views into the site; archaeological and geoarchaeological assessment; flood risk assessment.

2,850,000

Ham Farm No, but adjacent

Long list site, 2009: Acceptable in principle subject to: buffers to hedgerows and woodland; planting to screen and retain landscape character; mitigation of visual impact upon listed building and buried archaeological remains; retention/protection of PRoW and mitigation of any impact on public amenity.

850,000

Hawkhurst Farm Yes

Long list site, 2009: Acceptable in principle subject to the site being allocated as an extension to the existing Pendean sandpit utilising the same access and further information about site deliverability; further assessment of the site boundary; retention of Dunford Hollow and hedgerows; flood risk assessment, protection/mitigation for listed obelisk and archaeology.

3,000,000

Minsted West Yes

Long list site, 2009: Acceptable in principle subject to: mitigation of woodland features and hedgerows; reduction of site to south-west edge; mitigation of impacts on buried archaeology; flood risk and hydrogeological assessment; assessment of impact on nature conservation; retention/mitigation/diversion of PRoW.

2,000,000

West Heath Quarry Extension

1

Yes Long list site, 2009. Acceptable in principle subject to: assessment of landscape impact; ecological assessment; archaeological assessment; flood risk assessment.

565,000

Horncroft Quarry/ Coates Quarry

2

Yes

Long list site, 2009, Acceptable in principle subject to: assessment of impact on landscape character; retention of boundary hedgerows and stream valley with associated oaks; ecological assessment; archaeological investigation; flood risk assessment; protection of PRoW.

1,500,000

Table 7.3 Site options that were successful during the long list process in West Sussex

1. permitted in July 2010. 2. subsequently applied for but then withdrawn, during Nov 2010.


Status Estimated Reserve

Buncton Crossways

Yes Not considered for allocation unacceptable landscape character impact and uncertain deliverability.

1,000,000

Burton East Yes Not considered for allocation unacceptable landscape character impact and

uncertain deliverability. 2,000,000

Burton West Yes Not considered for allocation unacceptable landscape character impact and

uncertain deliverability. 3,000,000

Coopers Moor Yes Not considered for allocation due to uncertain deliverability. 500,000

Dunford Rough Yes Allocated in 2003, but not considered for allocation in recent plan due to

restrictive covenants and access difficulties. 3,400,000

Lower Chancton Farm

Yes Rejected in 2009 due to improvements to the A283 are needed before access can be achieved uncertain deliverability.

7,500,000

Minsted East Yes Rejected in 2009 due to Unacceptable impact on landscape character. The site

would have a detrimental visual impact along the extent of the valley floor. There is also uncertainty about deliverability of the site.

2,500,000

Ridlington Farm Yes Rejected in 2009 due to unacceptable impact on landscape character, visibility

issues in National Park and wider foothills. Covenants on the land have also restricted deliverability.

5,700,000

Rock Common South

No, but adjacent

Rejected in 2009 due to unacceptable impact on landscape character in context of the South Downs National Park. Adverse impact on public amenity as a result of cumulative impact. There is also uncertainty about deliverability. Improvements to the A283 are needed before access can be achieved.

700,000

Rock Common West

No, but adjacent

Rejected in 2009 due to unacceptable impact on landscape character. Removal of this section of land will open up views into existing extraction site. The proposal would have an adverse impact on public amenity as a result of cumulative impact. There is uncertainty about deliverability of the site.

Not known

Severals East Yes Rejected in 2009 due to deliverability issues. The landowner has indicated that they

will not be bringing the site forward. Not known

Severals West Yes Rejected in 2009 due to deliverability issues. The landowner has indicated that they

will not be bringing the site forward. Not known

Wiggonholt Yes Rejected in 2009 due to unacceptable impact on landscape character. The

proposal would have an adverse affect on landscape character and loss of landscape features. There is also uncertainty about deliverability of the site.

2,000,000

Table 7.4 Site options that were not successful during the long list process in West Sussex



August 2012 27

East Sussex Site Allocations

7.14 East Sussex intend to begin a site document within 12 months of the adoption of their Plan but

there has been a lack of potential soft sand sites identified previously.

Summary

7.15 At present, Hampshire has no potential sites now covered by the SDNPA, while the majority of

reserves intended to meet West Sussex‟s apportionment are within or adjacent to the Park‟s

boundary. In total, some 11.56mt was considered by WSCC, prior to the designation of the

SDNP as potential allocations within the SDNP.

8. Analysis of Reserves Information


August 2012 28

8. Analysis of Reserves Information 8.1 This section brings together information relating to available permitted reserves, apportionments

and estimated reserves within allocated/long-list sites, to provide an analysis of the potential

shortfall or surplus over the current Plan period for each MPA in the study area, with

consideration of reserves in Kent and Surrey. Note that, although this sections uses some very

precise figures, the results of the calculations applied to them should be viewed as providing a

general picture of soft sand provision (particularly given the differing stages achieved in

planning for minerals across the MPAs and the availability of data to support the analysis).

Reserve Calculation Tables

8.2 Tables 8.1 and 8.2 below, summarise the overall position with regard to sand & gravel and soft

sand provision, respectively, within each MPA. The tables set out information relevant to the

current Plan period (the one for which minerals and waste local plans are currently being

developed), and refer to the whole of the MPAs concerned. The sand & gravel figures in Table

8.1 provide a starting point and context for the analysis of soft sand provision in Table 8.2,

which accounts for only a portion of the total sand & gravel values.

8.3 Column A in each table describes each MPA‟s approach to adoption of an apportionment figure.

In some cases the MPAs have worked towards meeting the apportionment as set out in the

„Proposed changes‟ to the South East Plan. In other MPAs, an alternative figure has been

proposed based on assessment of local issues. In the case of soft sand, not all MPAs have or

propose to identify a separate apportionment. Where a separate apportionment is proposed, the

method for identifying the amount of soft sand the MPA will plan for is noted.

8.4 Column B identifies the number of years covered within the calculations. The start date for the

period of years is that defined in Adopted, Submission or Proposed Submission plans and

likewise, the end date is based on the end of each MPA‟s Plan Period (defined within the

relevant submitted Plan or other supporting, but earlier stage, planning documents). For West

Sussex, minerals planning has not yet reached the stage of having prepared a proposed

submission plan and therefore the start date is based on a point in time for which „current‟

permitted reserves (Column E) could be identified and could be separated from „potential future

reserves‟ (Column G, those being planned for). The end date for West Sussex calculations is

203115

.

8.5 Column C gives the annual apportionment that each MPA is working towards meeting16

, with

additional rows provided where this differs from the „proposed changes‟ apportionment. Column

D identifies the total apportionment for the number of years used identified as roughly

equivalent to „plan period‟.

8.6 In Column E, the permitted reserves figures are those given for the start of the plan period in the

planning documents. For West Sussex and Kent, these figures have been obtained for the

relevant point in time from the Annual Monitoring Reports for those MPAs. Both Table 8.1 and

8.2 include the Kingsley site within the permitted reserves figure.

8.7 Column F shows the result of subtracting the apportionment for each MPA from the permitted

reserves and, in effect, identifies the amount of mineral that would need to be identified in order

to meet the apportionment.

15

As identified in the West Sussex Minerals and Waste Development Scheme 2011-2015. 16

West Sussex do not yet have a defined apportionment but it may be based on the figure identified - Table 8.1,

footnote 6.



August 2012 29

S&G A B C D E F G H

MPA Apportionment

type used in calculations

Years Annual

Apportion-ment (mtpa)

Total Apportion-ment (mt)

Permitted Reserves at Start of Plan Period (mt)

Shortfall or Surplus over Plan Period

(mt)

Allocated or Potentially Allocated

Reserves (mt)

Residual Shortfall

or Surplus

Hampshire Locally derived 19.25

1 1.56

2 30.00 16.44

3 -13.56 11.57

4 -1.99

'Proposed Changes' 19.25 1

2.05

39.46 16.44 3

-23.02 11.57 4

-11.45

West Sussex Locally derived 22

5 0.64

6 14.12 5.34

7 -8.78 25.03

8 16.25

'Proposed Changes' 22 5

1.03

22.66 5.34 7

-17.32 25.03 8

7.71

East Sussex 'Proposed Changes' 17 9

0.10 10

1.70 4.10 11

2.40 0.00 12

2.40

Total residual S&G shortfall or surplus against locally proposed apportionments 16.66

Total residual S&G shortfall or surplus against proposed changes apportionments -1.33

Surrey 'Proposed Changes' 18 13

1.27 14

22.94 8.00 15

-14.94 16.00 16

1.06

Kent & Medway 'Proposed Changes' 19 17

1.63

30.97 20.62 18

-10.35 23.53 19

13.18

Total residual S&G shortfall or surplus against locally proposed apportionments 30.90

Total Residual S&G Shortfall or Surplus against Proposed Changes apportionments 12.90

Table 8.1 Sand & gravel provision in the study area NB: figures are rounded. Source notes: 1. 2011-2030 (based on Submission Plan, 2012). 2. Submission Plan, 2012 3. Submission Plan, 2012 . 4. Allocated sites. 5. 2009-2031 - CSL defined based on contemporary figures available for potential allocations and existing reserves for 2009. 6. Locally derived figure is based on 10 year average production figures as reported in the AMR and suggested by the MPA as likely to inform their apportionment figure. 7. West Sussex

AMR, Dec 2011. Table 3: Sand and Gravel Landbank - 2005/06 to 2010/11. 8. Acceptable 'in principle sites' in long list 2009, incl. West Heath, permitted July 2010 (165,000t more than anticipated) and Horncroft (later applied for then withdrawn). Only the minimum number of sites to meet the apportionment would be allocated in the final plan. 9. 2012-2026 (Submission Plan 2012). 10. the 'Proposed Changes' apportionment has been locally adopted. 11. Table 11, (Plan, 2012). Excl. confidential reserves. 12. Plan, 2012. 13. 2009-2026 (Adopted Core Strategy, 2011). 14. 'Proposed Changes' apportionment used for 2010 onwards, previous apportionment applies to 2009, para 6.2 in Primary Aggregates DPD, 2011. 15. Primary Aggregates DPD, 2011. Total permitted is 10.28mt but only 8mt will be available in plan period. 16. Tables 3&4 in Primary Aggregates DPD, 2011, plus a modest adjustment to the production at Preferred Area E of +0.53mt. 17. 2012-2030 (Core Strategy - Strategy & Policy Directions Consultation, May 2011), however permitted reserves figure is for year beginning 2011. 18. Kent AMR 2010/11, Dec 2011. 19. Preferred Options Allocations total.

Soft Sand A B C D E F G H

MPA Apportionment

type used in calculations

Years Annual

Apportion-ment (mtpa)

Total Apportion-ment (mt)

Permitted Reserves at Start of Plan Period (mt)

Shortfall or Surplus over Plan Period

(mt)

Allocated/ Potentially Allocated

Reserves (mt)

Residual Shortfall

or Surplus

Hampshire Sales based apportionment

19.25 1

0.28 2

5.33 2.22 3

-3.11 4.03 4

0.92

West Sussex

Sales based ratio on locally derived

22 5

0.51 6

11.30 5.13 7

-6.17 12.92 8

6.75

Sales based ratio 'Proposed Changes'

22 5

0.82 6

18.13 5.13 7

-13.00 12.92 8

-0.08

East Sussex No separate apportionment

17 9

0.00 10

0.00 0.12 11

0.00 0.00 12

0.00

Total residual soft sand shortfall or surplus against locally proposed apportionments 7.67

Total residual soft sand shortfall or surplus against proposed changes apportionment 0.84

Surrey Sales based apportionment

18 13

0.41 14

7.33 5.68 15

-1.65 2.70 16

1.05

Kent & Medway No separate apportionment

19 17

0.00 18

0.00 9.85 19

0.00 17.06 20

0.00

Total residual soft sand shortfall or surplus against locally proposed apportionments 8.72

Total residual soft sand shortfall or surplus against proposed changes apportionment 1.89

Table 8.2 Soft sand provision in the study area. NB: figures are rounded. Source notes: 1. 2011-2030 Hampshire Submission Plan, 2012. 2. Hampshire Submission Plan, 2012. Table 5.3. Based on average sales, however 0.28 x 19.25 years is 5.39mt, while 5.33mt is given in Plan. 3. Hampshire Submission Plan, 2012. Table 5.3. 4. More reserves are available for

allocation at Purple Haze, only that which is to be available in this plan period is included (3.625mt of soft sand)). 5. 2009-2031 CSL defined, based on contemporary figures available for potential allocations and existing reserves for 2009 and revised end of Plan period by WSCC. 6. Both apportionments are based on a 80:20 split applied (soft:S&G). Options presented in Background Paper 3: Minerals, Version 2, December 2009. 7. RAWP Report 2009: figure for end of year 2008.Table 6. 8. Acceptable 'in principle sites' in long list 2009, incl. West Heath, permitted July 2010 (at 65,000t more than anticipated). Only the minimum number of sites to meet the apportionment would be allocated. 9. 2012-2026 East Sussex Submission Plan 2012. Operator has suggested a higher figure (400,000) but that is approximately the same as the total for this site when first permitted in 2003 (380,000) and does not seem plausible. 10. No apportionment figure is provided however the approximate current level of production, as advised by operator is 25,000 to 30,000 tpa. 11. Table 11, (East Sussex Plan, 2012). 12. East Sussex Plan, 2012 states that no separate soft sand landbank will be used. 13. 2009-2026 Adopted Core Strategy, 2011. 14. Calculated: Surrey's low estimate requirement gives a total apportionment for the period of 7.33mt. 15. Primary Aggregates DPD, 2011. Total permitted is 7.96mt but only 5.68mt will be available in plan period. 16. Tables 3&4 in PA DPD, 2011. NB. although the result is a shortfall in reserves likely to 'come online' in the plan period, the current permitted reserve is actually greater. 17. 2012-2030 Core Strategy - Strategy & Policy Directions Consultation, May 2011. No separate soft sand apportionment is proposed. 19. Kent AMR 2009. 20. Approximate total of soft sand sites in Preferred Options Allocations.



August 2012 30

8.9 The values in Column G represent the amount of reserves specifically identified at sites or areas

within the submission plans or, in the case of West Sussex and Kent those identified at the most

recent planning stage („long list‟ sites and Preferred Options Allocations, respectively) and

contain therefore greater amounts than are likely to be put forward in submission documents.

8.10 Finally, Column H shows the resulting surplus or shortfall of sand & gravel or soft sand that

each plan (or early stage of plan) represents. A total is given across the study area MPAs, and

for the study area plus Surrey and Kent.

8.11 The figures in Tables 8.1 and 8.2 incorporate a number of important points / assumptions for

which there are notes given beneath the tables and in the following text.

Sand & Gravel Reserves

8.12 Table 8.1 shows that for sand and gravel provision it is likely that, despite showing slight

shortfall17

, Hampshire will have sufficient resources available for their plan period (however, the

existing reserves at Kingsley are included in the calculation). The surplus figure for West

Sussex is large as it contains the reserve amount for all long-list sites. In reality this figure will

be reduced during subsequent stages of the minerals plan development process. However, the

outlook is positive given that so much reserve has been put forward and found to be „acceptable

in principle‟. In East Sussex the current permitted reserves are deemed to be sufficient for the

coming plan period and a surplus is also forecast, although it has been noted18

that the market

for approximately half of the output of soft sand in East Sussex is in Kent.

8.13 Also shown in Table 8.1 are similar data for Kent and Surrey. Both MPAs have a surplus: for

Surrey, this is because the MPA is planning for slightly more mineral than apportioned (24mt

against 22.94mt „proposed changes‟ requirement) and; for Kent, this surplus figure could be

slightly less due „current‟ permitted reserves only being found for the beginning of 2011 (i.e. the

existing reserves and planned reserves may need to viewed over 20 years, not 19).

Soft Sand Reserves

8.14 Hampshire have developed a sales based apportionment based on the 10 year average of

0.28mt. Table 8.2 shows that there is a 0.92mt surplus of soft sand over the required

apportionment plan period which may or may not help cover any reduction in soft sand

reserves, as a result of silica sand issue at Kingsley. The amounts required from unallocated

opportunities, as detailed in Table 8.1, relate only to sharp sand and gravel, not soft sand..

8.15 The apportionment figure for soft sand in West Sussex is based on 80% of the total sand &

gravel reserves in the County, this being the highest of three sales-based ratio options

considered in BP3. The table shows that, if they are all allocated, the „acceptable in principle‟

long list sites would represent a surplus of around 6.75mt, however, in practice, only enough

soft sand to meet the apportionment will be allocated. If the „proposed changes‟ to the SE Plan

apportionment were to be adopted in West Sussex, rather than the „Locally Derived‟

apportionment there would be a shortfall.

8.16 There is no apportionment for soft sand proposed in East Sussex but the permitted reserves

have been included for completeness. These reserves relate to a single site and are taken from

the 2012 Plan. This amounts to just 3% of the total sand & gravel reserves in the County, 19

. If

this percent is applied to the potential surplus, soft sand represents around 0.072mt of the

surplus.

17

Based on the historical contribution from non-allocated opportunities. 18

Pers. comm. East Sussex County Council, August 2012 19

although a higher (confidential) figure has been reported to this study‟s authors by the operator. Pers. comm. S.

Dudman, March 2012



August 2012 31

8.17 Outside of the study area, Surrey has a projected surplus for soft sand and this is because the

MPA plan to enable production of 9mt20

(Policy MA1) against the „proposed changes‟

requirement of 7.33mt. Given that only 8.38mt is identified in their Plan (5.68mt in permitted

reserves and 2.7mt in the single soft sand Preferred Area) it could be considered that Surrey

have a small shortfall against Plan. However, only 5.68mt of a total permitted 7.96mt is used to

meet the apportionment within this plan period and it may be that any shortfall could be

remedied by upping the production at sites with reserves permitted beyond end of the plan

period.

8.18 In Kent, there are permitted and potential soft sand reserves of 26.9mt but no separate

apportionment is proposed. The soft sand figures represent 48% of the permitted reserve and

73% of the Preferred Options Allocations. Together, they represent 61% of the reserves

potentially available in the next plan period and theoretically therefore also represents 61% of

the potential surplus – some 8mt.

Potential Influence of National Park Status on Soft Sand Provision

8.19 Only the West Sussex County area has the potential for allocated sites within the National Park

(excluding the Kingsley Quarry extension site in Hampshire). Table 8.3 below shows the

potential effect on sand & gravel and soft sand provision if these sites are excluded from the

calculations. The table indicates that there would not be a shortfall in all sand & gravel,

however, this would depend entirely on almost all of the long list sites outside the SDNP being

included in the submission plan (and subsequent approval/adoption of this Plan).

8.20 However, the effect of removing the estimated 12.065mt of soft sand in sites within the SDNP is

a shortfall of 4.4mt. In the longer term (beyond the current Plan period), as existing permitted

reserves within the National Park become exhausted, the shortfall would increase significantly.

County Area Shortfall / surplus

1

(mt, see tables 8.1 & 8.2) Potential allocations inside

the Park (mt) Remaining shortfall

/ surplus (mt)

Hampshire 0.920 0 0.920

West Sussex 16.249 14.9652

1.284

East Sussex 2.400 0

2.400

Total S&G 4.604

Hampshire 0.920 0 0.920

West Sussex 6.750 12.065 -5.315

East Sussex 0 0 0

Total Soft Sand -4.395

Table 8.3 Shortfall or surplus result for Sand & Gravel and Soft Sand if potential future reserves in the SDNPA are excluded from the calculations. 1. Against locally derived apportionments. 2. All long list sites except Ham Farm plus the two sand & gravel sites in the long list (2009) that sit within the SDNP: „Land adjacent to Valdoe Quarry‟ and „Land at Redvins‟.

Discussion

8.21 The foregoing analysis has demonstrated that the existing / emerging Plans for East and West

Sussex county areas, and for the MPA of Hampshire are likely to be able to make sufficient

provision for soft sand for most of the relevant Plan periods (assuming that the potential sites

identified are brought through to the adopted plans).

8.22 The majority of the existing sites and potential allocated or safeguarded future sites for the

working of soft sand within West and East Sussex Counties are located within or immediately

20



August 2012 32

adjacent to the National Park. This is largely a reflection of the distribution of soft sand

resources (as described in Section 3).

8.23 It follows that, as joint local mineral plans are developed with the South Downs National Park,

these will either need to reflect the importance of traditional supply areas and sites within the

Park in maintaining the necessary supplies of soft sand for use in adjoining areas, or there will

have to be a change in future supply patterns, with a requirement for output from additional sites

outside of the SDNP in West Sussex MPA and Hampshire MPA, and perhaps from further

afield.

8.24 Whilst mineral extraction is not altogether precluded from National Parks, any new applications

are required by the NPPF to be, as far as is practical from outside National Park other than in

exceptional circumstances, and where it can be demonstrated that they are in the public

interest. Consideration of such applications is required to include an assessment of the need for

the development; the cost of and scope for developing elsewhere, outside the designated area;

and any detrimental effects on the environment, the landscape and recreational opportunities.

Whilst similar restrictions applied to the former South Downs AONB21

, the existing permissions

for mineral extraction were nevertheless granted. This contrasts with the neighbouring Surrey

Hills AONB, where future soft sand sites will be resisted22

,23

. This may or may not set a

precedent for continued mineral extraction within the SDNP, depending on the extent to which

the differences in approach resulted from clear differences in demand, public interest and

environmental impacts.

8.25 Thus, although the need for soft sand can be demonstrated by reference to existing demand, as

discussed briefly in Section 6, and although the acceptability or otherwise of potential

allocations has begun to be tested through the local plan process, consideration must also be

given to the options available for meeting this demand from other sources outside the National

Park. This is discussed in the next Section.

21

As with the current NPPF, previous National Policy for minerals, as set out in Minerals Policy Statement 1 (2006) and before that

in Minerals Planning Guidance Note 6 (1994) has always been the same for both National Parks and AONBs, in each case

requiring that major developments should not take place other than in exceptional circumstances, and that they should be subject

to the most rigorous examination, and demonstrated to be in the public interest. 22

There are no allocations for soft sand in the Surrey Hills AONB, but there is however an allocation for silica sand. 23

Policy MC2, Surrey Core Strategy DPD, 2011 and para 3.7 “There is a presumption against major new workings of

soft sand within the Surrey Hills Area of Outstanding Natural Beauty, because it is not so scarce as to justify

sufficient need”

9. Planning & Sustainability Implications of Altering the Traditional Supply Pattern


August 2012 33


Introduction

9.1 In recognition of National Policy regarding future planning applications for mineral extraction

within National Parks, there is a need to consider potential alternative resources of soft sand

which may need to be called upon to maintain future supplies, and to consider the broad

sustainability implications of placing increased reliance on such sources in the years ahead.

Although the potential need for such supplies has been shown to be limited during the Plan

periods covered by existing and emerging Local Plans, this will increase significantly in the

longer term as existing permitted reserves within the SDNP are exhausted. Consideration of

alternatives does not imply that they will necessarily be required, but it is a step towards

reaching a balanced and informed decision regarding future supply patterns.

9.2 Therefore, the potential policy responses of the SDNPA to extraction of soft sand within the

Park will depend on the sustainability implications of changing patterns of supply and may be an

all or nothing approach, or somewhere in-between. Options include:

a) Continue the current style of extraction by allowing future supplies of soft sand from

sources within the SDNP;

b) Restrict the amount of extraction within the SDNP to a level lower than the current one;

c) Do not allow any future supplies of soft sand to come from the within the SDNP, once

current permissions have run their course.

9.3 In options b) and c) alternative terrestrial sources of soft sand will need to be found outside the

SDNP. Generally, and insofar as the availability of unconstrained resources will allow,

alternative sources most likely to be proposed in future will be those located close to existing

sites, since these will generally be best placed to provide comparable materials and to serve the

same market areas.

9.4 In the sub-sections below, the type of potential sustainability implications arising from alternative

sources of land-won soft sand are briefly described, subsequent text discusses the practicality

and sustainability aspects of the potential alternatives for provision of soft sand outside of the

SDNP.

Sustainability Issues

9.5 Sustainability issues which would need to be considered in relation to any of these potential

alternative supply sources will comprise a mixture of local environmental and employment

issues, and wider transport-related or product-related issues. None of these can be addressed

in detail without being able to construct specific scenarios for comparison, since they will all be

influenced by site-specific details regarding environmental constraints, mitigation options,

employment factors, transport distances and routes, and product types. Some indications can,

however, be given, regarding the nature of the issues which would need to be considered in any

future detailed analysis. The broad groups of sustainability implications considered in this

Section are:

1. Local environmental and economic impacts

2. Transport-related impacts; and

3. Product-related impacts

9.6 Local sustainability issues relate primarily to the wide range of factors that are normally

considered within a site-specific Environmental Impact Assessment. Although the constraint



August 2012 34

maps presented in Appendix A provide some indication of the likely sensitivity of the various

potential source areas, they deal only with a limited number of major constraints and do not

provide any information regarding local priorities. Additional issues to be considered include the

site-specific impacts relating to all ecosystem services, including the scope for mitigation and

enhancement. This goes far beyond any impression that could be gained from an analysis of

mapped environmental constraints.

9.7 Transport issues are primarily relevant where existing sites within the SDNP are to be

substituted by other sites located in very different resource areas (e.g. West Hampshire, Surrey

or Kent). More generally, potential substitute resources that are located reasonably close to

existing sites would probably have limited relative sustainability implications in terms of

transportation. This would also probably apply in terms of employment.

9.8 Whilst these issues cannot be assessed in any detail without more precise knowledge of

locations and specific substitutions, the more general observation can be made that, with

increasing distance there are increased fuel and associated carbon emissions. Depending on

the routing of the vehicles there might also be increased traffic impacts associated with heavy

lorries on minor roads. Equally, however, those impacts might actually be reduced by virtue of

travelling along major highways (or by other means e.g. rail or water) to the market destinations

(e.g. along the south coast) rather than along country roads through the SDNP. This highlights

the importance of needing to compare specific alternative scenarios.

9.9 One further aspect of sustainability to be taken into account is that relating to the suitability or

otherwise of the alternative materials for the intended end uses involved. Soft sand can

sometimes be replaced with sharp sand in mortar, but this will generally require increased

quantities of water and cement to achieve a comparable degree of workability and performance,

and might also give rise to the need for artificial additives such as plasticisers. These again

have cost implications and may also give rise to increased levels of embodied CO2 within the

construction materials.

Potential Alternatives

9.10 The following alternatives for supply of soft sand are grouped under headings that relate to the

meeting or amending current apportionment. „Current‟ means those apportionments so far

defined in planning policy.

Marine Sources

9.11 Although it is not part of the scope of this work to look at marine-based alternatives for the

supply of soft sand, they are mentioned briefly here for completeness.

9.12 Marine sands are often formed by the same processes that have created terrestrial sand

deposits and therefore, comparable sands could be anticipated in an offshore situation. Marine

sands are used in the production of mortar24

and the Crown Estate25

indicate that there are

areas of the sea bed in the south east that could provide suitable raw materials.

9.13 Although they identify some issues that would need to be resolved, the Crown Estate “believe

there is potential for marine sources to provide a viable “soft” sand as an alternative to land

based quarrying”. They have identified the following issues as relevant: being able to meet

colour and grading expectations26

; the logistics of onshore handling and/or processing; retention

of the bottom end of the sand grading as material is dredged (particularly to meet building sand

grading specification) and customer product acceptance. Options put forward for providing the

24

Indeed British Marine Aggregate Producers Association (2002) 25

Dr I Selby, pers. comm., August 2012. 26

potentially, there may be appropriate resource areas already within some consented licences on the south coast.



August 2012 35

desired products are: targeting particular sandbanks for the appropriate grades; screening for

the appropriate grade at sea; or, screening on land.

9.14 Brief research27

indicates that, in order for marine sands to offer a suitable alternative to the

current land-won pattern of soft sand supply, wharf and fleet capacity could be key. Phased

long-term investment to enable permanent working above the current capacity might be

required, or the marine materials that might otherwise be exported could be sold into the south

east. Either way, a reliable UK market could be needed as justification.

Land-won sources: Meeting Current Apportionments

9.15 A) Do not have a separate soft sand apportionment in West Sussex: The total sand & gravel

requirement may well be met from sites outside the SDNP (subject to refinement of the „long list‟

of sites) and if no soft sand apportionment is identified for West Sussex, then the issue of

extraction within the Park may be „solved‟ in this way. However, the duty of MPAs to provision

for those minerals which have distinct markets (as required by the NPPF) may not then be seen

to be fulfilled.

9.16 B) Look for sources outside of the SDNP but within West Sussex for allocations: In West

Sussex, the only resources outside the SDNP are those located close to the Park boundary,

between Storrington, Henfield and Keymer. Currently active pits and those which are being

considered as site allocations in these areas are all located in the western part of this outcrop,

close to Storrington (see Figure C.1 in Appendix C). The remainder of the outcrop, further east,

is narrower, implying a reduced thickness of mineral, though it may be feasible to develop small-

scale sandpits within these areas, subject to more detailed geological investigations and, of

course, to acceptability in planning and environmental terms. No soft sand sites have been

worked in the eastern outcrop in at least the last four decades.

9.17 As shown on Figure C.1, the resource is generally free from mapped major environmental

constraints however, the River Adur cuts through this low lying area and it may be that the

reserves underlie floodplain in this location. In addition, part of the outcrop is sterilised by the

town of Henfield and various major roads. It is considered unlikely that any sites within that area

would be able to accommodate much, if any of the soft sand component of sand & gravel

apportionment currently ascribed to West Sussex. In practice, any future development of the

resources within this area might be able to substitute for West Sussex sites within the eastern

part of the National Park, but for those further west, substitution would be more likely to involve

the resources around Bordon or north east of Southampton and Fareham, in neighbouring

Hampshire (see below).

Land-won sources: Reducing the Soft Sand Requirement in West Sussex

9.18 The following four alternatives involve a reduction in the apportionment of soft sand for West

Sussex.

9.19 C) Within the study area, recognise the reserves in East Sussex as an „apportionment‟ thereby

offsetting some of the cross-boundary shortfall: This „apportionment‟ could reflect the remaining

life of the permitted soft sand reserves in East Sussex because, if no extraction is to take place

within the SDNP in the future, this “apportionment” could not continue beyond the existing

permitted reserves. There would be no sustainability issues with this alternative to the current

planning situation. However, due to the very small amount of „surplus‟ permitted reserve

(0.072mt), it is not a full substitution solution.

9.20 D) Within the study area, reduce the apportionment in West Sussex and plan for greater soft

sand reserves above the current Hampshire apportionment: The safeguarded resource at

27

including Mankelow (2008) and Highley (2007) (see references section).



August 2012 36

Whitehill-Bordon offers potential for utilisation within the Plan period and perhaps beyond but

being able to make use of these minerals prior to development is vital. This is potentially a key

alternative to quarrying in the SDNP, depending on the quality, quantity and workability of the

reserves as prior extraction is generally a sustainable practice. This area is also close to current

sites of production.

9.21 If the resources at Whitehill-Bordon cannot be utilised, finding alternatives could entail re-

assessing the rejected Hampshire sites in light of the increased requirement for soft sand (for

example in the areas already permitted around Kingsley and Frith End, see Figure C.2). Major

potential constraints within the area around Frith End (their coverage shown on Figure C.2),

include proximity to the SDNPA and Surrey Hills AONB, a SSSI and proximity to a SPA. Other

factors reported as part of the draft sustainability appraisal on submitted sites in this area

(Interim Report on Sites, dated February 2011) include potential negative impacts on

communities and amenity, health and quality of life and the potential for cumulative impacts.

9.22 Alternatively there may need to be a call for additional sites to come forward for assessment

and in terms of finding new sites the Whitecliff Sand Member (see Figure C.3) may be suitable

but this would depend on the availability of that land for extraction. This is an area not currently

exploited for soft sand (although historically there have been sand sites within the formation)

and so there may be sustainability issues surrounding the setting up of new sites. This area is

however, in close proximity of the M27 and rail lines and depots at Eastleigh, Botley and

Fareham (which have been used for imported crushed rock supplies28

). These depots have

been proposed as safeguarded under the 2012 Submission Plan and if of sufficient quality, it

would be prudent to investigate the practicality and cost of distributing soft sand from here to

West Sussex markets.

9.23 In Hampshire there is also the option of utilising soft sand resources in the west of the County,

within the Bracklesham Group, near to the safeguarded site at Purple Haze. All of these lie

outside the SDNPA, although parts of the Bracklesham Group extend into the New Forest

National Park. Other potential constraints include the River Avon SAC and Avon Valley

SAC/Ramsar/SSSI and the distance from markets currently served by West Sussex and East

Sussex quarries.

9.24 E) Outside the study area, reduce the apportionment in West Sussex and plan for greater soft

sand reserves above the amount currently provisioned for in Surrey: There are potentially areas

of soft sand resource within Surrey, along the northern outcrop of the Folkestone Formation.

Most of those resources fall within AONB designations, however, and are thus subject to the

same level of protection as those within the National Park. Of those which are not, the outcrop

around Farnham would seem to offer similar potential to that around Bordon in Hampshire (see

above and Figure C.2), and the area around Reigate, though more distant from the West

Sussex sites, offers specific potential for the future extraction of silica sand. However, one or

two potential sites in this area have been assessed as part of the development of Surrey‟s

Plan29

and have been found to have their own sustainability implications30

. Even if these sites

(or other, as yet unidentified sites in this area), were found to be appropriate locations for

extraction in the future, this alternative relies on the ability and willingness of Surrey MPA to co-

operate. It appears that there may not be sufficient surplus of soft sand in Surrey in the short

term and increasingly so in the long term.

28

Aggregate Mineral Resources Map South East England and London Region, BGS, 2008, & Need Assessment for

Wharves and Rail Depots, Land & Mineral Management Ltd (February 2011) 29

Draft Appendix Four to the Environmental & Sustainability Report for the Surrey Minerals Development Framework

2004 to 2016 – February 2006 30

For example, being situated within principal aquifer, risk of cumulative impacts, local level Area of Great Landscape

Value designations and proximity to residences



August 2012 37

9.25 F) Outside the Study Area, Reduce the apportionment in West Sussex and plan for greater soft

sand reserves above the current Kent apportionment: There are potentially areas of soft sand

resource within Kent that may not yet have been subject to assessment for inclusion in a

minerals plan and it is possible that some of these could be identified as appropriate for mineral

extraction (determining of individual applications pending). However, although much of these

resources lie outside (but close to) AONB designations, they are more distant from the relevant

markets. In practice this might restrict the extent to which resources in Kent would be likely to

substitute for those in West Sussex or Hampshire, though in detail this would depend on

individual market relationships between suppliers and consumers, and cannot be ruled out as a

possibility, especially in the long term.

9.26 Notably, much of the soft sand resource in Kent is located adjacent to the M20 between

Maidstone and Ashford (see Figure C.4). Generally, sites situated in this location that were not

successful at sustainability appraisal had few potential adverse impacts on the environment

despite being located near to the Kent Downs AONB. Rather, the potential adverse impacts

related to residential amenity and communities (due to use of local roads) and unsuitable

access via (or impacts along) local roads. Further to the south east, between Ashford and

Folkestone there are additional mapped areas of unconstrained resource for which no sites

have been put forward during production of the Kent Minerals Plan. Thus, it does appear that

there may be largely unconstrained soft sand resource in this area of Kent, close to major

transport routes, providing that sites could be identified for which local transport impacts are

less.

9.27 As with Surrey, this potential alternative relies on the ability and willingness of Kent MPA to co-

operate in planning for additional soft sand reserves but it may be that this is a long term

alternative to extraction within the South Downs National Park becoming comparatively more

sustainable despite the impacts of transport over longer distances.

Summary

9.28 A combination of the alternatives outlined above may be appropriate in the long term. In the

short term it appears that there may be some un-investigated reserves in West Sussex but

investigation would be required as to the potential for that area to support extraction, particularly

in relation hydrological and hydrogeological constraints associated with proximity to the River

Adur. To a greater extent, there are apparent un-investigated reserves within the Whitecliff Sand

Member in Hampshire. By exploring these two alternatives initially, it may be possible to

alleviate some of the requirement for reserves to come from within the Park and without the

need to seek cooperation of MPAs outside of the study area.

10. Conclusions


August 2012 38

10. Conclusions

Introduction

10.1 This report has considered the current and planned situation regarding soft sand provision in

the study area. Land-won soft sand is specifically considered, although silica sand has been

included to a limited extent and where it has particular implications for the planning of soft sand

supply. The majority of the existing reserves and potential allocated or safeguarded sites for the

future working of soft sand, especially within West Sussex, are located within the Cretaceous

Folkestone Sand Formation, which, in the study area, is found within or immediately adjacent to

the SDNP. Additional resources are found in the MPAs surrounding the SDNP in other

geological formations however, soft sand extraction has historically been (and is currently)

focussed within the Folkestone Formation.

10.2 Key conclusions of this study are given below and these concern the end use and markets for

soft sand, the ability of the study area to provision for soft sand supply and the potential

alternatives and suitability implications of reducing or curtailing future permissions for extraction

within the SDNPA. Some discussion is also given to the potential for setting an apportionment

for soft sand for the SDNP.

Soft Sand End Uses & Markets

10.3 In most cases, the majority of output from existing soft sand quarries is used as building sand,

taking advantage of its natural ability to produce „workable‟ mortar, based on grain size and

shape characteristics. Alternative sources of sand which did not have the same physical

characteristics (e.g. the „sharp‟ sands derived from Quaternary river deposits) would provide a

relatively poor substitute, requiring additional quantities of water, cement and chemical additives

in order to achieve similar workability and quality, which in turn would have both cost and

sustainability implications (see below). The radius of transportation for building sand is generally

within around 30 miles to distribution depots and other areas of demand along the south coast,

and in parts of south west London. Greater distances (up to 45 miles) may be involved,

particularly where the mineral operator is part of a vertically-integrated supply chain and thus

has long term steady demand for its products from specific distribution depots in urban areas.

Distance travelled also increases as minerals become more scarce locally.

10.4 As demonstrated in Section 6, above, soft sand resources are also utilised in places for

concreting aggregate and elsewhere for more specialist sand products. In the case of

concreting aggregate, soft sand is often blended with imports of marine-dredged sand. This is

because it complements the „gap-graded‟ particle size distribution of the marine sand, and also

helps to reduce the overall chloride content, resulting in a better overall product. In such cases,

any replacement of the soft sand from a given location would need to come from other similar

sources, and not from different types of material such as „sharp‟ river sands or additional

dredged sand.

10.5 In the case of specialist „silica‟ sand, the specification requirements (though generally rather

vague) are more exacting in terms of limiting the opportunities for substitution. The primary use

of these specialist sands is for horticultural and sports (particularly equestrian) applications,

where the primary qualities are the high silica content, rounded grains and pale colour. It is

therefore unlikely that the existing source of silica sand within the study area (at and around

Kingsley in Hampshire) could be substituted by sands from elsewhere in the study area,

although more detailed analysis of soft sands from other sources would be needed to confirm

this. It is also the case that specialist sands command higher prices and thus tend to travel

greater distances to areas of demand. For this reason, and notwithstanding the relative scarcity

10. Conclusions


August 2012 39

of these materials, alternative supply sources further afield may well be able to substitute for

those produced within the study area.

Provision of Soft Sand in the Study Area

10.6 In terms of the emerging mineral plans for the neighbouring MPAs of National Park, the study

has found that there are sufficient permitted and allocated or potentially allocated reserves to

make adequate provision for soft sand for most of the relevant Plan periods (based on the use

of MPA‟s locally-derived rather than sub-national apportionments and on the assumption that

the allocations identified in local mineral plans are all granted planning permission in due

course). However, should the pattern of supply from the SDNP be reduced or curtailed in future

planning there is the potential for the apportionment formerly relating to the area defined by the

county of West Sussex to be short by approximately 5.315mt. This is an equivalent potential

shortfall of 4.4mt across the study area (and possibly could be larger, as the figure assumes

that all sites outside of the SDNP are allocated).

Alternatives to Future Extraction within the SDNP

10.7 In identifying alternative sources of supply, consideration must be given to the end uses for

which the sand has traditionally been used; the suitability or otherwise of the alternative sources

for meeting those specification requirements; and the locations of the markets that are being

served. Soft sand can be replaced with sharp sand in mortar, but this will generally require

increased quantities of water and cement to achieve a comparable degree of workability and

performance, and might also give rise to the need for artificial additives such as plasticisers.

These again have cost implications and may also give rise to increased levels of embodied CO2

within the construction materials.

10.8 In terms of locating the alternative supplies, consideration will first need to be given to the

immediately adjoining MPAs of East and West Sussex and Hampshire. In the case of East

Sussex, there are no resources of soft sand outside the National Park. In West Sussex, the only

resources outside the National Park are located very close to the Park boundary, between

Storrington, Henfield and Keymer and could be subject to environmental constraints outside of

those mapped (potentially, the reserves sit within the floodplain of the River Adur). In

Hampshire, the safeguarded resource at Whitehill-Bordon offers potential for utilisation within

the Plan period and perhaps beyond. There may also be possibilities of finding further reserves

in the areas already permitted around Kingsley and Frith End (in areas outside the Park).

Significant parts of the resource outcrop within these areas lies outside the National Park

boundary and there may thus be scope for this area substituting for existing sources in both this

part of Hampshire and neighbouring parts of West Sussex. Subject to more detailed analysis,

some of these areas might be suitable for providing specialist silica sand as well as more

general building sand. The Whitecliff Sand Member to the north east of Southampton and

Fareham may offer the best alternative to resources within the National Park in the more

immediate future, particularly given the proximity to the rail network which might be looked at for

its potential to supply the resources from here to parts of West Sussex.

10.9 There are further soft sand resources in Surrey, though most of these fall within AONB

designations and are thus subject to the same level of protection as those within the National

Park. Therefore, Surrey itself may have increasing difficulty in meeting apportionments beyond

the current plan period. There are also alternative resources of soft sand within Kent. These

generally lie outside (but close to) AONB designations, but are more distant from the relevant

markets. In practice this might restrict the extent to which resources in Kent would be able to

substitute for those in West Sussex or Hampshire, though in detail this would depend on

individual market relationships between suppliers and consumers, and cannot be ruled out as a

possibility.

10. Conclusions


August 2012 40

10.10 With regard to transport-related issues, these cannot be assessed in detail without precise

knowledge of locations and specific substitutions and further work on this would be needed.

However, the more general observation can be made that, with increasing distance (for

example, the resources in Kent) there are inevitably increased fuel and associated carbon

emissions, and increased costs. Depending on the routing of the vehicles there might also be

increased traffic impacts associated with heavy lorries on minor roads. However, those

particular traffic impacts may actually be reduced by virtue of travelling along major highways to

the market destinations (e.g. along the south coast) rather than along country roads through the

SDNP.

10.11 While alternatives have been provided, these cannot be addressed adequately without being

able to construct specific scenarios for comparison, since they will all be influenced by site-

specific details regarding environmental constraints, mitigation options, employment factors,

transport distances and routes, and product types. Local environmental issues include the site-

specific impacts relating to all ecosystem services, including the extent of national and local

designations relating to environmental protection but also the local scope for mitigation and

enhancement.

Apportionment in the SDNP

10.12 In the absence of a formal apportionment figure for the SDNP in the South East Plan, and in

view of the fact that the neighbouring MPAs are basing their requirements on Local Aggregate

Assessments, rather than reflecting any kind of „top-down‟ approach, it will be for the SDNPA to

decide how it wishes to make provision for future aggregate production, including soft sand.

Taking account of the observations outlined above, regarding alternatives and sustainability

factors, and of the considerable difficulties in unravelling the complexities of market demand for

soft sand in different areas, it would be very difficult to arrive at a sensible, justified

apportionment figure for future soft sand production within the area. An apportionment could be

based on past sales figures for sites within the national park but this would not take account of

the need for Nationals Park MPAs to give consideration to alternatives outside of the Park31

.

Equally, however, it is clear that well defined alternatives are limited and that continued

production of soft sand from within the National Park would help to avoid the adverse effects of

longer-distance transportation from alternative sites and those associated with the use of less

suitable alternative materials. More detailed surveys would be useful to establish the quality of

the potential alternatives outside of the Park, including a better understanding of the potential

for marine sands to substitute for land-won resources.

10.13 It would therefore seem prudent for the SDNPA to develop policies which allow for the

continued production of soft sand from resources within the National Park, whilst also continuing

to co-operate with its neighbouring MPAs to encourage the production of material from

unconstrained resources in those areas. Subject to there being adequate site-specific controls

on environmental impacts, this would encourage the continued operation of a free market in

which material is delivered efficiently to the markets according to actual demand. This would

reflect the general ethos of „Plan, Monitor and Manage‟, rather than perpetuating the outdated

concept of „predict and provide‟.

31

Note: this report was written prior to the publication of the new MASS guidance which should be consulted in any

further consideration of these issues.


August 2012 41

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http://www.bmapa.org/documents/marine_building.pdf%20accessed%20August%202012

South Downs National Park - Soft Sand Study August 2012

Appendix A: Figures A.1 to A.3 (Resources and Constraints)


Appendix B: Figures B.1 to B.3 (Permitted and Potential Sites)


Appendix C: Figures C.1 to C.4 (Soft Sand Resources)

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