It’s Critical that you read this

Mineral planners in the UK have been advocating for a levelling of the playing field when it comes to attitudes and policies towards different types of minerals, it seems as though New Zealand (NZ) has beaten us to it…

The NZ Critical minerals list opens with a straight talking, easy to read position statement on the importance of minerals generally:

“Minerals are essential to modern economies; their use in key industries and products supports economic growth and stability, national security, and technological advancement…”

“Developing a list of critical minerals is an important first step to ensure a secure supply of the minerals we need for our economic growth and resilience. The list developed identifies the minerals that are economically important and are vulnerable to supply risk or essential to unlocking other critical minerals. 

The list provides a basis for strategic actions to support secure mineral supply chains…”

In the UK, USA, Canada and EU discussions about Critical Minerals wouldn’t have most people thinking of crushed rock and sand. However, while not scoring highly on scarcity and rarity tests, NZ resolved (without hesitation) to include aggregates and sand in their list because:

“[they] were recommended for inclusion in the Critical Minerals List due to their high level of economic importance to New Zealand…”

The UK planning system also has a knack of not setting out (or agreeing upon) what level of weight different adjectives have when trying to establish whether a scheme, such as a new quarry, is acceptable or not. An example is the NPPF where “Great”, “Significant”, “Substantial” and “Strong” (amongst others) are used when directing decision makers as to the level of beneficial weight that should be applied towards a proposal. This must ring alarm bells when sticking the word ‘critical’ before any type of mineral without having a policy basis for the weight that should subsequently be applied to it during the decision making and development plan process. 

Furthermore, any ‘binary’ (i.e. critical mineral good, normal mineral less good) test that is introduced through legislation and subsequently policy / guidance, is going to, quite quickly, create havoc when the bar for ‘non-critical’ mineral extraction inevitably and inadvertently gets raised from high to stratospheric. 

It seems as though NZ has taken a step back from a purely academic exercise and sought to establish what is actually going to be required for its economy to prosper and its built development needs be met. Giving the UK, USA and EU the benefit of the doubt…perhaps they were simply the Guinea Pigs in the grand scheme of Critical Mineral planning.

At the core of this tension are the inherent difficulties that come with the choice of the word ‘critical’, I appreciate that you need decision makers and politicians on side and the word is ideal for that, but this has got High Court Challenge written all over it. 

Anyone for a unilateral agreement on mineral adjectives??? UAMA is quite catchy…

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