The new NPPF sees mineral planning as optional rather than essential – this must change.
The draft revised NPPF’s approach to minerals planning could have serious ramifications for the government’s ability to meet its built environment commitments, says Chris Heffernan.
Everything that the new NPPF hopes to achieve is underpinned by a steady and adequate provision of building materials. However, the changes proposed erode the already tentative stability of supply. Put simply, it appears to the minerals sector that the NPPF (through December’s consultation draft) is either beginning to consciously distance itself from minerals as a whole, or is (potentially, catastrophically) becoming indifferent to them.
Firstly, the reference to minerals being “essential” has been removed from the revised framework. Since there hasn’t been a change to the way in which we build things since the last iteration of the NPPF, the industry is at a loss as to why the raw ingredients of development are no longer recognised as being absolutely necessary.
The significance of this amendment shouldn’t be underestimated and the industry is, rightly, worried that this hints at an overarching distancing by mainstream planning from having to recognise the special characteristics of mineral planning generally.
“This hints at an overarching distancing by mainstream planning from having to recognise the special characteristics of mineral planning generally.”
While there remains, quite rightly, a healthy dose of art in mainstream planning, minerals will always carry a fundamental technical foundation. Much of this flows from the irrefutable fact that without minerals everything stops and that, at the end of the day, minerals can only be worked where they are found.
Secondly, and perhaps most shockingly, at a strategic level – principally in the approach to spatial planning – there is a direction to only have regard to the suitable provision of minerals (i.e., resources / building materials) “where appropriate”.
While waste infrastructure and transport, for example, are recognised as being part and parcel of strategic development goals, the draft NPPF provides an opportunity for decision makers to uncouple minerals from the equation. This compounds an emerging issue of major development not sourcing its building materials sustainably or, moreover, checking they exist indigenously in the first place.
Third, the draft NPPF removes a long-standing recognition that the supply of minerals should be both “steady” and “adequate”. This terminology was deliberate in that it required mineral planning authorities to not just have enough mineral ‘in theory’, but that they must be able to demonstrate that they could supply it consistently and at the pace required by the building sector/s.
The draft wording creates a position where dynamic new sites will not have the benefit of policy support simply because a mineral planning authority can point to ‘sufficient’ (i.e., adequate) supply of minerals, potentially tied up in one or two sites with very little output (steadiness).
Why this matters for the delivery of infrastructure and some 1.5 million new homes is that when you specify 1,000,000 bricks for your next scheme, they may not exist.
There is much more to say, but these three issues appear somewhat existential to mineral planning. The UK has, perhaps, the most sustainable approach to mineral planning in the world and has some of the best and brightest talent working on schemes, but there is a clear and growing risk that minerals are seen as optional rather than ‘essential’.
