Upload
others
View
4
Download
0
Embed Size (px)
Citation preview
MQP Griff Asphalt Planning Application Statement
June 2015
1
Planning Application Statement
Project: MQP Griff Asphalt Plant Proposal for the retention and continued use of the asphalt plant
and associated facilities at Griff Quarry, Gipsy Lane, Nuneaton,
Warwickshire.
Date June 2015
MQP Griff Asphalt Planning Application Statement
June 2015
i
Document Control
Project: Griff Coated – Planning Application for retention of asphalt
plant.
Client: MQP
Job Number: LD038/G/
File Origin: l:\landesign\projects\active\active\mqp\mqp - griff coated\final report\outputs\pa
final submission 20150610\griff retention of asphalt plan 2015061018v2 final.docx
Document Checking:
Change Management
Ref Status Purpose of Issue Originated Checked Date
pa 1st draft -
20150518\griff
retention of
asphalt plan
201500518v1 1st
draft.docx
Draft Draft Supporting statement IDB JEB 18/05/2015
griff retention of
asphalt plan
2015061018v2
final.docx
Final Supporting statement with client
amendments IDB JEB 10/06/2015
Issue Management
Version No Status Recipient Hard Copy /
Electronic Date sent
1 Draft MEP E (PDF) 18/05/2015
2 Final Warks CC E(PDF) +
Hard Copy
2 Final MEP E(PDF) +
Hard Copy
MQP Griff Asphalt Planning Application Statement
June 2015
iii
CONTENTS
1 Introduction ....................................................................................................... 9
2 Planning Application ...................................................................................... 10
3 The Site ............................................................................................................. 10
4 Landholding / Ownership............................................................................... 14
5 Planning History ............................................................................................... 14
6 Proposed Development ................................................................................. 17
7 Environmental Considerations ....................................................................... 24
8 Need for the development ............................................................................ 31
9 Planning Policy ................................................................................................ 32
10 Conclusion ................................................................................................... 39
11 Schedule of Structures and Buildings ........... Error! Bookmark not defined.
12 Potential Sensitive Receptors ........................ Error! Bookmark not defined.
13 Glossary........................................................... Error! Bookmark not defined.
14 Plans ................................................................ Error! Bookmark not defined.
PLANS
Plan Ref Title
LD038/G/003 Location plan
LD038/G/002 Planning Application and Landholding Plan
LD038/G/001 Buildings and Structures
MQP Griff Asphalt Planning Application Statement
June 2015
iv
FIGURES
Figure 3.1 – Existing Site Access .............................................................................................................. 13
Figure 3.2 Panoramic view of the Site entrance showing the mature vegetation along
Gypsy Lane. ............................................................................................................................. 13
Figure 6.1 General view of the asphalt plant. ..................................................................................... 18
Figure 6.3 Southern stock yard showing low level stock piles ........................................................... 22
Figure 6.4 Unusead asphalt collection area adjacent to plant. ..................................................... 22
Figure 7.1View from field near Abbotsbury way. ................................................................................ 29
Figure 7.2 View from Marston Lane Cemetery extension.................................................................. 29
Figure 11.1 View of the southern elevation of the asphalt plant ...... Error! Bookmark not defined.
Figure 11.2 Northern facade of asphalt plant ...................................... Error! Bookmark not defined.
Figure 11.3 Asphalt plant stack ................................................................ Error! Bookmark not defined.
Figure 11.4 Asphalt Bins ............................................................................. Error! Bookmark not defined.
Figure 11.5 Fuel oil and bitumen tanks with emergency shower ...... Error! Bookmark not defined.
Figure 11.7 Asphalt plant batch mixer building .................................... Error! Bookmark not defined.
Figure 11.8 Asphalt plant bag / filter house .......................................... Error! Bookmark not defined.
Figure 11.9 Asphalt plant hopper ............................................................ Error! Bookmark not defined.
Figure 11.10 Asphalt Plant Control Cabin and Substation 1- Western facadeError! Bookmark not defined.
Figure 11.11 Asphalt Plant Control Cabin and Substation 1- Southern facadeError! Bookmark not defined.
Figure 11.12 Aggregate storage bins – Western facade ................... Error! Bookmark not defined.
Figure 11.13 Aggregate storage bins – Eastern facade ..................... Error! Bookmark not defined.
Figure 11.14 Weighbridge Office - East facade ................................... Error! Bookmark not defined.
Figure 11.15 Weighbridge Office - North facade ............................... Error! Bookmark not defined.
Figure 11.16 Weighbridge Office - West facade ................................. Error! Bookmark not defined.
Figure 11.17 Weighbridge Office - South facade ................................ Error! Bookmark not defined.
Figure 11.18 Canteen and Welfare Facility – Southern Elevation ..... Error! Bookmark not defined.
Figure 11.19 Canteen and Welfare Facility – Western Elevation ...... Error! Bookmark not defined.
MQP Griff Asphalt Planning Application Statement
June 2015
v
Figure 11.20 Laboratory and Store – Eastern and Northern elevationError! Bookmark not defined.
Figure 11.21 Laboratory and Store – Western elevation .................... Error! Bookmark not defined.
Figure 11.22 Workshop – Eastern elevation .......................................... Error! Bookmark not defined.
Figure 11.23 Workshop – Southern elevation ....................................... Error! Bookmark not defined.
Figure 11.24 Steel Container Store – Western facade ........................ Error! Bookmark not defined.
Figure 11.25 Steel Container Store – Southern facade ....................... Error! Bookmark not defined.
Figure 11.26 Compressor Shed – Southern / western facades .......... Error! Bookmark not defined.
Figure 11.27 Compressor Shed – Eastern facade ................................ Error! Bookmark not defined.
Figure 11.28 Wheel wash – eastern and northern facades ............... Error! Bookmark not defined.
Figure 11.29 Wheel wash – washing area.............................................. Error! Bookmark not defined.
Figure 11.30 Oil and Fuel Storage Area ................................................. Error! Bookmark not defined.
Figure 11.31 Substation 2 ........................................................................... Error! Bookmark not defined.
Figure 11.32 Container Store 2 ................................................................. Error! Bookmark not defined.
Figure 11.33 Sheeting Platform 1 ............................................................. Error! Bookmark not defined.
Figure 11.34 Sheeting Platform 2 ............................................................. Error! Bookmark not defined.
Figure 11.35 Substation 3 ........................................................................... Error! Bookmark not defined.
Figure 11.36 Septic Tank ............................................................................ Error! Bookmark not defined.
Figure 11.37 Temportary storage area for unused asphalt prior to removal from site.Error! Bookmark not defined.
Figure 11.38 – Southern stock yard.......................................................... Error! Bookmark not defined.
Figure 11.39 – Site Access ......................................................................... Error! Bookmark not defined.
Tables and Photographic Schedule
Table 11 .1 – Schedule of Structures and Buildings. ............................. Error! Bookmark not defined.
Photographic Schedule of structures and Buildings. .......................... Error! Bookmark not defined.
Potential Sensitive Receptors ................................................................... Error! Bookmark not defined.
Glossary Error! Bookmark not defined.l:\landesign\projects\active\active\mqp\mqp - griff
coated\final report\outputs\pa final submission 20150610\griff retention of asphalt plan
2015061018v2 final.docx
MQP Griff Asphalt Planning Application Statement
June 2015
vii
Planning Application Forms and Certificates
(NB These have been provided as a separate pdf file in the electronic
version)
MQP Griff Quarry Planning Application Statement
June 2015
9
1 Introduction
1.1 This submission is made by Landesign Planning and Landscape Ltd on behalf
of Midland Quarry Products (MQP) (the Applicant) at Griff No 4 Quarry (the
Quarry). The planning application seeks to allow the continued use of the
Griff asphalt plant and associated facilities, (the Site) beyond 31st October
2015.
1.2 The existing quarry planning permission requires mineral extraction operations
to cease by 31st October 2015 and supply of aggregates to the coating
(asphalt) operations to cease on the same date. However, the timeframe for
removal of the plant is linked to the final restoration of the site which is now
extended to 2032 by a more recent permission to reinstate the site using inert
materials.
1.3 MQP considered making an application under S73 of the Town and Country
Planning Act 1990 related to amending end dates in the existing quarry
permission however, following pre application consultation with Warwickshire
County Council it has become clear that this may not be the best long term
solution at the Quarry from the point of view of managing the planning
permissions for the activities on site.
1.4 MQP considers that it is unlikely to pursue further mineral extraction operations
at the Quarry but does wish to retain an asphalt operation to supply its
existing customers. It has therefore been decided that the best approach to
retain the asphalt operations beyond October 2015 is to seek a stand alone
planning permission for the asphalt operations such that a clear distinction
can be drawn between the WCL and restoration activities and the MQP
activities from a planning perspective.
1.5 This submission comprises:-
Planning Statement and associated plans;
Planning application form and certificates;
Planning application fee;
MQP Griff Quarry Planning Application Statement
June 2015
10
2 Planning Application
2.1 The proposed development seeks retention and continued operation of the
following existing facilities together with the right to import aggregate for use
in the manufacture of asphalt. These buildings structures and uses include;-
Asphalt plant and associated structures and stocking areas;
Offices;
Material stocking areas;
Weighbridge office and welfare facilities;
Car and lorry parking and use of the site access onto Gipsy Lane;
Other related existing ancillary buildings structures and roadways etc.
Importation of stone for coating at 50,000 tonnes per annum.
2.2 As a part of the application planning permission is sought to import up to
50,000 tonnes of stone for coating per annum to reflect likely increases in sales
volumes as the economy recovers. Permission currently exists for the
importation of 25,000 tonnes.
2.3 Imported materials are likely to be drawn mainly from MQP’s Leicestershire
quarries such as Cliffe Hill although some higher quality aggregate not
available from Leicestershire may be sourced from sites further afield.
3 The Site
General
3.1 The Site comprises land approximately 1.5 km north of Bedworth and 2.7m
south of Nuneaton, the asphalt plant being at OS Grid Ref SP36332 88966 and
a height of 101m AOD at the base of the plant.
3.2 The Site sits to the immediate south of Gipsy Lane which runs approximately
east – west along the southern limits of Nuneaton. Access into the Site is
directly from Gipsy Lane.
3.3 The area around the site is gently rolling countryside varying in height
between 90m and 100m AOD. The majority of Griff No 4 is a well-established
quarry excavated to a depth of 35m AOD in its south west corner. The
Application Area (the Site) sits in the north eastern corner of the Quarry.
3.4 Gipsy Lane is lined by mature hedges with open fields to the north leading to
Coventry Road (which is set in a cutting) such that there are no views into the
site from the north other than from immediately in front of the site access
point on Gipsy Lane.
3.5 To the east the land falls away from 97m AOD on the quarry edge, down to
90m on the Coventry canal towpath. The land further east beyond the canal
MQP Griff Quarry Planning Application Statement
June 2015
11
is open agricultural land leading to Perch Hill (also known as Griff No 5 Quarry
) for which planning permission has also been granted but no operations are
thought to have taken place in recent years.
3.6 To the south of the Quarry the land falls to approximately 90m AOD close to
the Coventry Canal at Marston Junction, before rising to 100m AOD at the
Marston Lane Cemetery.
3.7 To the west the Quarry is bounded by the Nuneaton to Bedworth railway line
and beyond that are a number of sporadically spaced properties along
Nuneaton Road. Further south west is the residential area of Collycroft on
Nuneaton Road.
3.8 To the north west of the Quarry is Bermuda Island (a large signal controlled
road island junction) being the point where the A444 / B4113 and Coventry
Roads meet. There is a Premier Travel Inn located on the western side of
Nuneaton Road immediately south of this junction. Gipsy Lane joins Coventry
Road 125m south of Bermuda Island.
3.9 The asphalt plant sits at the north eastern corner of the Site and is bounded to
the north and east by a large screening mound that hides all but the upper
most levels of the existing plant. All other elements of the operations are
hidden from view from other than from longer distance views from Marston
Lane to the south.
3.10 To the west and south of the plant lies operational land comprising stocking
areas, and administration and welfare facilities.
Application Area (the Site) Boundaries
The northern boundary of the site is formed by Gypsy Lane.
The eastern boundary of the Site is formed by the Coventry Canal.
The western boundary of the site is formed by an un marked internal
quarry land ownership boundary representing the point at which
occupation of land is maintained by the Arbury Estate / WCL.
The southern limit of the Site is formed by the limits of the asphalt stock
yard area.
Geological SSSI
3.11 A SSSI exists over the northern part of the Quarry including land north of Gipsy
Lane and includes the asphalt plant site. This is a geological SSSI arising from
the exposure of various stratigraphic horizons which can be seen to the west
of the Application Area. The SSSI will not be adversely affected by the
retained asphalt operations as there are no proposals to touch any of these
exposures as part of the asphalt plant use.
3.12 Mineral extraction at Griff No. 4 Quarry has exposed a series of rock
formations of nationally important geological interest. The northern part of the
MQP Griff Quarry Planning Application Statement
June 2015
12
Quarry is consequently designated a Site of Special Scientific Interest (SSSI).
The SSSI specifically relates to features at the northern end of the site that the
approved restoration for the Quarry will impact upon, inevitably resulting in
the loss from view (the features themselves will not be lost but some sections
will be covered by the restoration works) of some of these features. However
the approved restoration scheme will retain some of the key exposures that
make up the SSSI.
Overburden and Soils
3.13 There are no soils or overburden to be removed as part of the development
and the final restoration of the site is already defined as part of the wider
quarrying and infilling permissions.
Residential Receptors.
3.14 Residential receptors occur on the northern, western and southern sides of the
Quarry and are 400m from the asphalt plant Site.
3.15 The properties nearest to the development are set out in Section 13 below.
3.16 Properties 2, 3, 4, 6, 7 and 9 comprises a collection of residential properties
that sit at a similar height to the original ground level at the development site.
As a result, existing screening and intervening vegetation mean that the
Quarry is largely unseen from them. However the existing asphalt plant site
and Site access are visible from Marston Lane (Bedworth) over the Quarry’s
southern screening bund from a distance of approximately 1km.
3.17 Noise and dust are already well controlled under the existing quarrying
permissions and Part B permitting controls. MQP proposes that the levels
already set, shall be maintained as part of the proposed development as
they represent modern effective limits and controls.
Sensitive Receptors
3.18 A table of ‘Potential Sensitive Receptors’ is set out at Section 13 of this
submission.
Vegetation
3.19 The screening bunds around the Quarry are already well vegetated with
mature trees, short grasses predominating with sporadic emergent scrub
species.
3.20 The eastern bund provides significant screening and combines with dense
mature woodland species between the Site and the canal. The northern
boundary similarly has a well vegetated screening mound running the length
of Gipsy Lane.
MQP Griff Quarry Planning Application Statement
June 2015
13
Transport routes and public rights of way
3.21 The proposals will continue to adhere to the existing S106 agreement (8th
June 2005) traffic routing commitment to use Gipsy Lane west of the Site
entrance. This will apply for both imported and exported materials.
3.22 It is understood that WCL has committed under a separate S106 to erect
traffic signals at the junction of Gypsy Lane and Coventry Road. These lights
have yet to be installed as far as MQP is aware.
3.23 Onward distribution of materials will be via Gipsy Lane west to access the
A444 for distribution via the main motorway and trunk road networks.
Importation of stone for coating is similarly undertaken using the same routes.
3.24 It should be noted that permission for importing 25,000 tonne of stone for
coating already exists and permission is now sought to regularise the increase
in volumes that is expected.
3.25 Importantly, the volumes of traffic to be generated by this proposal will be
significantly below those generated by MQP / Hanson’s previous quarry
operations. Furthermore, as the asphalt plant is already in operation the level
of traffic generated should not alter from that which already exists and was
deemed acceptable under the permission to infill the Griff No 4 quarry.
Figure 3.1 – Existing Site Access
Figure 3.2 Panoramic view from opposite the Site entrance showing the mature vegetation along Gypsy Lane.
MQP Griff Quarry Planning Application Statement
June 2015
14
3.26 The nearest public footpath follows the tow path of the adjacent Coventry
Canal (on the eastern bank). This path is set down well below the level of the
Site such that views of the Site are not possible from it.
3.27 The nearest water course to the Site is the Coventry Canal to the east. This
includes the discharge point for quarry water.
Landscape designations
3.28 There are no formal landscape designations at the Site although the area is
part of the West Midland Green Belt.
Cultural Heritage
3.29 There are no scheduled monuments or listed buildings on site, with the nearest
ones being Griff House Hotel and Griff Cottage approximately 500m to the
west of the Site. Neither they nor their setting are directly affected by the
proposals.
4 Landholding / Ownership
4.1 MQP currently has a long term lease for the Site but has decided that it no
longer wishes to pursue mineral extraction at the Quarry. Notwithstanding that
decision, Hanson still holds freehold ownership of various mineral interests at
the Quarry. The recent introduction of the WCL operations to the Quarry has
complicated the planning controls as there are now two operators operating
under the same permissions. Furthermore the Quarry is likely to be active for
several decades to come as a waste and recycling centre producing
recycled aggregate, in addition to the other permitted activities such as
asphalt production.
5 Planning History
5.1 Mineral extraction commenced at Griff No.4 Quarry sometime prior to 1925.
Mineral reserves at Griff No. 4 Quarry are nearly exhausted, although some
permitted mineral remains to be worked and further un-consented reserves
are known to exist in the western faces that are now considered by MQP to
be commercially unviable. The roadstone coating (asphalt) plant is already a
well-established feature of the Site and remains in operation utilising a range
of stocked reserves from the Site and imported stone for which a separate
planning permission was issued. In recent years the plant has operated using
primarily imported stone.
5.2 In 2000 the site was the subject of an Environment Act Review (ref
N100/99CM010 dated 14th January 2000) (the ROMP). This reviewed the
extant planning permissions and approved a single modern set of working
conditions covering both Griff No. 4 and No. 5 quarries.
MQP Griff Quarry Planning Application Statement
June 2015
15
5.3 Since the ROMP there have been further changes to the planning permission
as follows:-
5.4 N100/01CM009 dated 13th July 2001 varied condition 34 the ROMP extending
the implementation date for Griff no.5 to 8th July 2007.
5.5 N100/04CM039 dated 20th December 2004 varied (under S73) condition 2 of
the ROMP to reconfigure the quarry faces as per working plan is G76fcg/30b.
5.6 N100/01CM026 dated 8th June 2005 varied condition 3 of the revised ROMP
(N100/01CM009) to enable 24 hour operation of the asphalt plant. The
permission is subject to a Section 106 which covered inter alia lorry routing.
5.7 N100/05CM011 dated 12th July 2005 provided a further variation of
N100/01CM009 which extended the implementation date for Griff no.5 to 8th
July 2012.
5.8 Although N100/05CM011 contains 84 planning conditions, many of the
conditions relate to Griff No.5 quarry. Only conditions 1 to 34 are directly
relevant to Griff No.4. Of particular note is condition 1 which states that the
‘winning and working of minerals shall cease on or before the 31st October
2015.’ Conditions 29 – 32 concentrate on the ‘Coating Plant’ but contain no
specific end date for asphalt / coating operations. It is noted however that
condition 29 provides that only stone produced at Griff Quarries shall be
coated at the plant. This condition, by default, would deprive the asphalt
plant of stone once mineral working had ceased on site on 31 October 2015.
Permission to Import Aggregate
5.9 During the later 2000s mineral extraction at Griff No 4 slowed due to the
quality of aggregate available from the Site. As a result, the need arose to
import higher quality stone to the Site in order to maintain product quality
from the asphalt plant.
5.10 Planning permission N100/07CM038 dated 20th December 2007 varied
condition 29 of N100/05CM011 to permit importation of up to 25,000 tonnes
p.a. of high quality stone for use in the asphalt plant.
5.11 N100/07CM038 provides 5 conditions that replace the original condition 29 of
N100/05CM011, but the permission reiterates all other conditions by cross
reference to N100/05CM011 so far as they are still subsisting and capable of
taking effect. Condition 5 of N100/07CM038 allows inter alia the coating plant
operation and importation of stone until the cessation of mineral extraction at
Griff Quarries. Use of the plural ‘Quarries’ in this instance is understood to be
linked to the Griff No 4 and Griff No 5 sites collectively as both are shown in
the committee report that relates to this permission.
Retention and Removal of Asphalt (Coating) Plant
MQP Griff Quarry Planning Application Statement
June 2015
16
5.12 It is our understanding that the plural reference to ‘Quarries’ in N100/05CM011
implies that the asphalt plant was intended to remain in operation as a facility
for both Griff No 4 and then Griff No 5 quarries. i.e. the intention being that
the asphalt plant may continue in operation beyond the life of mineral
extraction at Griff No 4 quarry in order that coated stone could still be
produced using Griff No 5 mineral. This implies an acceptance that the
asphalt plant would continue in use beyond 31 October 2015 i.e. the date
when winning and working of mineral from Griff No 4 is to cease.
5.13 However, as Griff No 5 now appears unlikely to be worked, the proposal now
brought forward is for the asphalt plant to continue in operation for a period
whilst the restoration of Griff No 4 is completed. This will require the asphalt
plant to be fed using imported stone of all qualities i.e. not just that with a PSV
of 63+ as required by condition 2 of N100/07CM038.
5.14 Only condition 33 of the planning permission N100/05CM011 specifies a date
for the removal of the structure of the asphalt plant and that date has now
been extended to 2032 to match the infilling operations. Permission
N100/07CM038 condition 5 allows the importation of stone until the date by
which the winning and working of minerals from Griff No 4 quarry must cease
under condition 1 set out in permission N100/05CM011 i.e. 31 October 2015.
The retention of the plant until 2032 is therefore not contrary to any planning
condition, but importation of stone to the asphalt plant beyond 31 October
2015 does appear to be prevented. This creates a position whereby the plant
structure can remain insitu and operational to 2032 but the feed source of
aggregate to the plant will be stopped.
WCL Permission Griff No 4 Quarry (NBB/12CM002) (the WCL Permission)
5.15 Aside from the mineral / asphalt (coating) plant permissions, a further major
permission has been granted at Griff No 4 Quarry to restore the Site using
imported materials as well as allowing aggregate recycling activities.
5.16 NBB/12CM002 dated 31st January 2013 (the WCL Permission) was made by
WCL for inert landfill and recycling and includes a restoration scheme to
satisfy condition 33 of the N100/01CM009 (the ROMP consent). Permission
NBB/12CM002 runs until 31st December 2032. The approved restoration
plan(s) for the site are KL147.001 (restoration plan) and KL147.002 (restoration
sections) are reliant on the activities approved under NBB/12CM002 and
therefore by definition, this permission and the condition 33 restoration
scheme must logically mean that restoration of the mineral permission area
has shifted to 2032.
Planning Permission Summary
5.17 Therefore, in summary, MQP is operating the Site to permission N100/07CM038
which allows, inter alia, the operation of the quarry, coating (asphalt) plant;
MQP Griff Quarry Planning Application Statement
June 2015
17
and the importation of stone until the cessation of mineral extraction at Griff 4
and 5 Quarries.
5.18 Condition 1 of N100/05CM011 requires all mineral winning and working at Griff
No 4 Quarry to cease by 31st October 2015.
5.19 Mineral remains to be worked at both Griff No 4 and Griff 5 but the latter looks
unlikely to be exploited.
5.20 Therefore it appears that from 31 October 2015, the importation of stone and
operation of the asphalt plant should cease unless a further permission is
granted for continued importation of stone beyond 2015 (or indeed if mineral
extraction is allowed to continue beyond October 2015). However, the plant
its self does not appear to be under any requirement to be removed until Griff
No 4 quarry is finally restored.
5.21 The WCL application provides the restoration scheme for the whole Quarry
(including the asphalt plant site) as required by condition 33 of
N100/01CM009 and indicates a final restoration date of 2032 for that scheme
to be implemented. This therefore suggests that the asphalt plant permission
remains extant to circa 2032 even if the current conditions preclude a feed of
stone to the plant after October 2015.
5.22 Therefore permission is required to allow the asphalt plant to operate at Griff 4
beyond 31 October 2015.
5.23 As the above text shows, the planning controls at the site are becoming very
complex when applied to the different activities and operators in the site. For
this reason a new standalone planning permission for the retention of the
asphalt plant and associated facilities so as to separate the asphalt plant
from the WCL operations is considered the clearest way forward.
6 Proposed Development
The Proposed Development
6.1 The proposed development seeks retention and continued operation of the
following existing facilities together with the right to import aggregate for use
in the manufacture of asphalt.
Asphalt Plant and associated structures and stocking areas;
Offices;
Material stocking areas;
Weighbridge office and welfare facilities;
Car and lorry parking and use of the site access onto Gipsy Lane;
Other related existing ancillary buildings structures and roadways etc.
Importation of stone for coating at 50,000 tonnes per annum.
MQP Griff Quarry Planning Application Statement
June 2015
18
Figure 6.1 General view of the asphalt plant.
Buildings and Structures
6.2 The proposed development seeks permission to retain and use a number of
existing buildings and structures to 2032. Many of these have been erected
altered and improved over several decades as part of the quarry operations.
6.3 Detailed drawings and records of each structure are therefore of limited
value as they do not reflect the current form of the structures on site. As a
result of discussions with Warwickshire County Council it has been agreed that
the best approach is to provide a photographic schedule of the buildings
and structures linked to an up to date topographic survey of the site.
6.4 Section 11 of this submission therefore comprises a detailed photographic
schedule of the structures and buildings for which planning permission is now
sought.
Proposed Uses
6.5 The proposed uses will be restricted to the production of asphalt for road
surfacing. This will however require the importation of materials for coating (as
currently permitted by N100/07CM038.) This is because Griff No 4 quarry is no
longer producing primary aggregate although some unworked minerals do
remain and further reserves are known to existing in the quarry’s western face.
6.6 Importation of aggregate to the site further established by the WCL
permission which allows the importation and processing of materials to
produce aggregate products. However, MQP would like a clear right to
import stone for the purposes of asphalt production to clarify the planning
position at the Site.
MQP Griff Quarry Planning Application Statement
June 2015
19
Material Importation.
6.7 Imported materials are likely to be drawn from MQP’s Leicestershire quarries
such as Cliffe Hill although some higher quality aggregate not available from
Leicestershire may be sourced from other sites. Such materials are already
being imported to the Site and the combination of the lack of suitable
material being produced at Griff No 4 Quarry for asphalt production linked to
the upturn in the economy mean that an increase in imported stone is
required. MQP considers that 50,000 tonnes per annum is sufficient. This is well
below the levels of output previously undertaken from the quarry which
understood to have regularly exceeded 200,000 tonnes per annum, on top of
the asphalt produced at the Site.
Productive Capacity and Output
6.8 The proposed plant is expected to operate at a realistic capacity of 50,000
tonnes per annum. This output comprises its normal day to day business but
also allows for periods when MQP’s busier plants such as Cliffe Hill, are
subjected to break downs and asphalt has to be sourced from back up
facilities nearby. Griff provides that flexibility to act as a back-up plant.
6.9 In summary MQP anticipates that the output from the asphalt plant is unlikely
exceed 50,000 tonnes per annum.
Vehicle Movements
6.10 Vehicle movements will not alter from those previously undertaken; indeed
MQP’s share of the site traffic is likely to be significantly lower than the
tonnages that have been previously experienced from the quarry operations.
6.11 Based on a capacity of 50,000 tonnes per annum, and assuming no back
hauling occurs at all (which is unlikely) the worst case suggests that circa 22
loads per day will be generated.1 – i.e. up to an average of 44 movement per
day. The asphalt plant as it stands can already operate at 40 movements per
day this is discussed further in Section 7.21-7.27 below. The change proposed
as a result of importation is therefore not significantly different from what is
already permitted.
6.12 However, it should be noted that in reality the plant may well operate below
capacity for much of the day and delivery vehicles may be larger than those
used to assess the worst case traffic movements. Furthermore it is likely that
where practical most hauliers will take return loads thereby substantially
reducing the amount of traffic.
1 The worst case calculation assumes imports of 50,000 tonnes and sales of 50,000 tonnes – i.e.
a total of 100,000 tonnes per annum; an average lorry load of 17 tonnes; and a 270 day
working year.
MQP Griff Quarry Planning Application Statement
June 2015
20
6.13 It is therefore likely that the level of traffic generated will be substantially
below the worst case level for much of the time.
6.14 As the worst case scenario appears to be acceptable, in practice no traffic
problems are therefore anticipated.
Access
6.15 The proposed development will continue to use the existing site access. All
internal roads to and from the asphalt plant are hard surfaced.
Figure 6.2 general view of site access from the Site yard.
Operation of the Asphalt Plant
6.16 Aggregate is transported to the Site by road lorry, entering from Gypsy Lane
where it immediately separates from the WCL traffic. Vehicles then follow the
MQP internal one way system before off loading aggregate in the
appropriate stock piles to the south and east of the plant.
6.17 Loose aggregate is then fed from these stock piles into the aggregate bins
using a front end loading shovel. From the aggregate bins, material then
feeds by conveyor into the plant where it is heated, dried and mixed with
bitumen, sand and other additives before being transferred into the asphalt
bins.
6.18 Asphalt is then discharged from the asphalt bins, directly into the lorry bodies.
The lorries then progress to the weighbridge, before being sheeted prior to
leaving the Site to the customer.
6.19 The asphalt plant is operated from an elevated cabin attached to the side of
the mixer building.
6.20 The hard surface around the batching plant will ensure that vehicle
cleanliness is maintained by MQP vehicles, as exists already.
MQP Griff Quarry Planning Application Statement
June 2015
22
Substations 1 -3.
6.21 There are three separate sub stations at the site and date back to a point in
time when the quarry was fully operational and there were more plant items
at the Site than exist now. These are all in varying degrees of use but none
can be removed at this point without undertaking major changes to the
electrical systems on site.
Open Stocking Area
6.22 Aside from the main plant there is a large stocking area on the Eastern side of
the Site where aggregate is loose tipped into piles. This is important as it is
essential that the plant does not run out of key materials and the plant
aggregate bins only have a limited capacity.
6.23 However, the stocking area is well hidden from outside views. Whilst longer
distance views from the south are possible, the separation distance means
that the effect of such views is minimal.
Figure 6.3 Southern stock yard showing low level stock piles
Figure 6.4 Unused asphalt collection area adjacent to plant.
MQP Griff Quarry Planning Application Statement
June 2015
23
Unused Asphalt Collection Area.
6.24 Adjacent to the plant there is a small area where returning loads and
laboratory samples of asphalt can be offloaded for temporary storage prior
to removal to another facility for reuse / recycling. See Figure 6.4.
6.25 This approach ensures that waste generation water use is minimised at the
Site.
Office Accommodation and Staff Welfare
6.26 Staff facilities on site will be maintained. These comprise a central canteen
area as well as smaller facilities within some of the other offices and
workshops.
6.27 The main site office is adjacent to the site weighbridge, with the plant control
cabin attached to the asphalt plant its self.
Car Parking
6.28 Car parking spaces are accommodated in the existing site car parks
adjacent to the main offices and the main entrance. This accommodates
cars and light vans. All parking is reverse only for safety purposes.
6.29 The parking area allows pedestrian routes around the Site to be restricted, so
Site traffic and pedestrians can be separated as much as possible.
Lorry Parking
6.30 The Site currently employs two resident HGV’s but may wish to base a further 2
there in due course to support the import and sales of asphalt. All lorry parking
is undertaken adjacent to the plant site.
Hours of Operation.
6.31 Asphalt hours of operation are currently unrestricted. This is because many
road contracts typically require deliveries of asphalt when the major roads
are least busy. This is often over night and at weekends.
6.32 The application seeks to maintain this provision (which is incorporated into the
existing permissions at the site – under condition 4 of N100/05CM011).
Operations outside the usual daylight hours are not frequent but do occur
and are often necessary to avoid other inconveniences to the general public.
This is particularly so when supplying public transport and highway works. The
Site therefore needs to be able to supply materials at unusual times on ad
hoc occasions.
6.33 The Applicant does ensure that when operating outside normal hours of
business that extra care is taken in minimising noise generation by, for
example, ensuring aggregate bins and silos are fully loaded up in the normal
MQP Griff Quarry Planning Application Statement
June 2015
24
working day such that out of hours activities are kept to essential activities
only.
Employees
6.34 The Site employs 5 people on site these comprise Site management staff and
two drivers. In addition there are further related supporting roles not based at
the Site but which provide management and administrative support to the
operation.
6.35 MQP may in time wish to base a further two vehicles at the Site to assists with
the importation of materials for coating however that is not expected to
occur immediately.
Development Proposal Summary
6.36 The proposal is to retain the existing asphalt plant and associated buildings
and structures. In addition permission is sought to import up to 50,000 tonnes
per annum of aggregate for asphalt production. No new buildings or
structures are proposed.
6.37 At a practical level a new permission should not result in any noticeable
change in and around the site as the asphalt operations are so well
established.
6.38 In conclusion the development is confined to an existing operational site, is
well screened and will remain active until the site closes at the end of 2032
when the whole site is due to be restored and all plant and structures will be
removed.
7 Environmental Considerations
Air Quality
7.1 The manufacture of asphalt is a process that is required to be permitted
under Part B of the Environmental Permitting (England and Wales) Regulations
2010 ('the Regulations'). This requires certain industrial installations to obtain an
environmental permit before they are allowed to operate. As such the
existing operation, and by implication the process for which permission is now
sought, is already subject to an environmental permit (Ref B7(08) –issued by
Nuneaton and Bedworth District Council on 9/1/2011) that places tight
pollution prevention controls on the emissions to air from the asphalt
operation.
7.2 Should planning permission be granted for the proposed development the
existing Part B controls will be maintained. As is recognised in NPPF paragraph
122, it is not necessary for the planning system to revisit issues matters
MQP Griff Quarry Planning Application Statement
June 2015
25
controlled through the permitting regimes operated by the pollution control
authorities. 2
Noise Control Measures
7.3 Planning condition 14 in permission N100/05CM011 provides a blanket noise
limit during daytime operations (as set out in condition 3) of 55db LAeq (1hr)
free field value at the nearest noise sensitive property.
7.4 Planning condition 4 as set out in permission N100/05CM011 refers specifically
to asphalt operations that occur outside the normal hours of operation and
requires that noise generated by the asphalt plant should not exceed 40dB
LAeq(1hr) free field value at the nearest adjacent dwelling (external) ‘outside
the time permitted by condition 1’ (of the same permission). The assessment
methodology to be used should accord with BS4142:1990.
7.5 Condition 1 does not actually refer to time limits and it is presumed that the
cross reference to condition 1 is a mistake and that the cross referenced
condition should refer to condition 3.
7.6 Condition 3 provides time limits for mineral operations of:-
0600 – 1800 (mon – fri) and
0600 – 1200 (sat) for mineral operations
No mineral operations to be carried out on Sundays and Bank
Holidays.
7.7 For the purposes of this planning application it is intended that the asphalt
operations will continue to adhere to these two noise conditions.
Traffic and Transport Statement
7.8 The retention of the asphalt plant is not thought to have any significant
transport effects as the operation and associated infrastructure are already
well established features that have run for many years without obvious signs of
any transport issues. Indeed when operating as part of the quarry, the outputs
were significantly higher than what is currently proposed.
7.9 It is noted that the proposal to increase the importation of stone for coating /
asphalt will result in an increase in stone imports to the Site, but this will be a
fraction of the vehicle movements that the quarry has generated previously
and so the proposal sits well within the established vehicle movements linked
to the established and historic Griff 4 Quarry operations.
7.10 Whilst the presence of the WCL operations interacts with the traffic
movements generated by at the wider site, it is understood that the WCL
Permission takes into account the operation of the quarry and asphalt plant
2 NPPF paragraph 122.
MQP Griff Quarry Planning Application Statement
June 2015
26
and on this basis it appears that the likely traffic levels that this proposal will
incur, will not result in an overall increase beyond the levels previously
established. Furthermore the WCL S106 commitment to install traffic lights at
the junction of Gipsy Lane and Coventry Road ensures that the additional
traffic generated by the WCL restoration works provide robust traffic controls.
7.11 As part of WCL’s planning application for the infilling of the Griff No 4 quarry, a
Transport Statement3 was prepared by Mayer Brown as part of the relted EIA.
With that assessment paragraph 2.8 and associated Table 2.2 set out historic
tonnages sold from Hanson’s operation in the period 2001 – 2010. These
figures showed a minimum output of 39,860tonnes for 2010 and a maximum
of 235,126 for the year 2003. With the exception of 2010, the annual output
from Griff exceeded 85,000tonnes and in most years was near or above
200,000tonnes. This was stated to be quarry tonnage.
7.12 Section 2.9 also advised that ‘In addition, there is also a black top coating
plant located within the site which generates 40 HGV movements per day’.
7.13 Therefore overall the Mayer Brown indicated approximately 100 vehicle trips
per day being generated by the quarry and asphalt plant operations each
day.
7.14 Section 4.4 of the Mayer Brown Transport Statement indicated that the WCL
operation would generate approximately 200 deliveries per weekday (i.e. a
total of 400 HGV trips per day) and 50 during Saturday, the majority of these
being 20 tonne vehicles.
7.15 Paragraph 2.15 of that report highlighted 46 accidents of which only 1 was
serious and none involved HGV’s.
7.16 Paragraph 6.9 of the Mayer Brown report concluded that the WCL infilling
proposals would result in a minimal increase in vehicular trips within the local
highway network, and that there are no transportation or highways matters
that should preclude the granting of planning permission.
7.17 The committee report attached to the decision on the WCL application
indicated reduced vehicle movements compared to the Mayer Brown report
and advised at paragraph 1.8 that:-
7.18 ‘The site would be accessed via the existing Quarry access off Gipsy Lane.
The application states that the development would generate an average of
126 vehicle movements (63 vehicles entering and leaving the site) per day.’
7.19 The committee report goes on to advise that ‘notwithstanding this conclusion,
the proposed development would generate additional traffic locally as the
result of infilling the quarry and operation of the recycling facility. The access
from the site onto Gipsy Lane is satisfactory for the level of traffic proposed
and the highway network can accommodate this intensification in traffic
3 https://planning.warwickshire.gov.uk/swiftlg/apas/run/WCHDISPLAYMEDIA.showImage?theSeqNo=8313&theApnkey=7351&theModule=1
MQP Griff Quarry Planning Application Statement
June 2015
27
movements in the main. However, there are existing highway safety concerns
in respect of the operation of the junction of Gipsy Lane and Coventry Road
which would be exacerbated by the introduction of further slow moving
HGV’s. It is considered that the junction requires upgrading and that the
introduction of signals would resolve this concern. The applicant has agreed
to fund (either directly or via a financial contribution made to the Highway
Authority) signalising of the junction. This could be secured by a Section 106
legal agreement.’
7.20 The report therefore suggest that improvements are to be provided by WCL
at the Gipsy Lane / Coventry Road junction in order to accommodate the
additional traffic generated by the WCL proposal.
Transport Impacts - Discussion
7.21 As the asphalt plant was already operational at that time; as mineral reserves
at Griff 4 and 5 are still available to be worked (see the LAA); and as the
Mayer Brown report makes it clear that the existing Hanson / MQP operations
were regularly generating in excess of 200,000 tonnes of aggregate and 40
loads a day of asphalt; the current application will represent a reduction in
the active tonnage coming from the quarry.
7.22 The current proposals – as a worst case, assume 50,000 tonnes of asphalt sales
and 50,000 tonnes of imports and an average lorry load size of 17 tonnes.
Therefore over 270 working days per year this equates to 11 delivered loads
per day and 11 imported loads per day. Assuming a worst case where HGV’s
do not back haul imports and exports, this equates to 22 loads per day or 44
two way movements.
7.23 As the Mayer Brown report indicated, the asphalt plant already accounts for
40 movements per day – not materially different from the levels already
permitted. Taking the former quarrying activities into account it can be seen
that previous operations have generated over 100 movements per day.
7.24 In summary therefore the proposed retention of the asphalt plant, even with
the ability to import up to 50,000 tonnes per annum, will result in a significant
reduction in vehicle movements compared to those previously generated.
The worst case traffic numbers are less than half of the levels that Hanson has
previously operated at.
7.25 In reality it is more likely that some of the HGV’s importing stone will back haul
asphalt to customers. In this case, the figures could drop to 25% or less of
previous output levels. Furthermore, these figures all assume an annual output
from the asphalt plant of 50,000 tonnes per annum is achieved. Any lessening
of this tonnage will lower traffic movements even further.
7.26 Taking the above into account, it is MQP’s view that the data supports a view
that the retention of the asphalt plant can be easily accommodated in the
existing permitted tonnages allowed at the site. The WCL permission has
resulted in a commitment for them to install traffic lights connected to their
MQP Griff Quarry Planning Application Statement
June 2015
28
infilling operations. This commitment linked to MQP’s intention to operate at a
much lower limit than has existed previously will therefore ensure that the
proposed development should not result in any adverse impact on traffic
numbers. This position is of course already well established and was taken into
account by the MPA when determining the WCL application.
7.27 As the proposals will result in reduced levels of traffic compared to the historic
background levels and as commitments already exist for improvements to the
Gipsy Lane / Coventry Road junction, the proposals appear to be well within
the capabilities of the road network.
Ecological Impacts
7.28 There are no areas of habitat being disturbed as part of the proposals as the
application area comprises a well used asphalt plant yard and stocking area
which is continually active. There are no waterbodies or vegetation on the
active parts of the site which might house protected species.
7.29 All vegetation on the existing Site boundaries is to be retained in its current
form and is not therefore under threat.
7.30 No adverse ecological impacts are therefore anticipated.
Landscape and Visual Impact Measures
7.31 The proposed development is already well contained within the Site and
remains largely hidden behind the existing bunds and vegetation.
7.32 Views of the asphalt plant site are limited and restricted to longer distances.
7.33 Views from the north are prevented by the screening bund and the
vegetation alongside Gipsy Lane. – See Figure 3.2 above.
7.34 Views from the west are restricted by screening on the quarry edge. The worst
case views from the west arise from the eastern limit of car park at the Griffin
pub some 540m from the Site.
7.35 To the east the existing topography and vegetation mean that views into the
site are non-existent except for long distance views of the top of the stack
and the adjacent mixer building – see Fig 7.1. The properties that have this
view are at the western limit of Caroline Close and the playing fields of
Chetwynd Junior school, both of which are 1.5km distant from the Site, and sit
immediately adjacent to the main railway Line.
7.36 The Northbourne Drive housing estate sits closer to the site than the Chetwynd
school area but, the layout of the Northbourne Drive estate and the
topography and mature hedgerows and vegetation separating it from the
Site mean that views towards the site are heavily restricted and there is little
visual impact there.
MQP Griff Quarry Planning Application Statement
June 2015
29
Figure 7.1View from field entrance level with Abbotsbury way Nuneaton – 1,250m from the Site. This shows the worst
case veiw of the section of plant above the screening bund when viewed from the East.
7.37 Whilst the plant is visible, the landscape between the plant and the
Chetwynd School area is crossed by numerous high and low level electricity
lines relating to the national grid and the main railway line such that the
distant plant is not a significant feature in the landscape.
7.38 From the south views of the Site are possible over the WCL operations and the
Quarry’ssouthern screening bund, from a distance of some 900m. Again,
whilst such views exist, the asphalt plant is not a prominent feature in the
landscape.
Figure 7.2 View from Marston Lane Cemetery extension
7.39 Figure 7.2 makes it clear that whilst the existing operations are visible, they are
distant and not significant features in the landscape.
Asphalt plant site
MQP Griff Quarry Planning Application Statement
June 2015
30
7.40 In summary whilst the Site can be seen from some locations, those views are
distant and well established such that retention of the plant will not result any
new significant adverse impacts.
Cultural Heritage
7.41 As mentioned above, the nearest heritage sites are grade 2 listed structures
that are both over 500m from the Site and sit next to much more intrusive land
uses and developments without undue effect. Furthermore any effects that
do arise will be temporary only.
7.42 As a consequence no material cultural heritage impacts will arise from the
retention of the existing Site and its uses.
Hydrology and Hydrogeology.
7.43 The surrounding land is a mixture of the rock types found in the quarry and it is
known that the natural water table surrounding the existing quarry sits much
higher level than the quarry floor.
7.44 At present ground water drains into the site and is collected in a sump at the
south west corner of the quarry, along with rainwater. Water is then pumped
from the sump into a series of four settlement ponds on the eastern boundary
of the site where the water is cleansed before being discharged to the
adjacent canal in accordance with a discharge license.
7.45 The asphalt operations have been designed to ensure that the ground water
is not adversely affected by the operations. Indeed many parts of the site
where asphalt operations are undertaken are hard surfaced. All fuel tanks are
appropriately designed e.g. by bunding or using double skinned tanks etc.
7.46 This arrangement will continue under the proposed development.
Environmental Effects – Summary
7.47 In summary, as the proposed development is one that is both existing and
well established, no new environmental impacts are expected to arise.
Furthermore, as MQP does not anticipate undertaking any further mineral
extraction at Griff No 4 quarry, the total amount of traffic likely to be
generated by the continued use, even relying on imported stone, will be 50%
or less than the established outputs for the quarry.
7.48 Existing noise conditions already control noise levels from the asphalt plant
both in the daytime and night time periods. These can be applied to any new
planning permission.
7.49 Air quality is controlled under the PPC permit and again these controls will
remain in place.
7.50 As the site is an existing active operation there are no ecological or
archaeological considerations on the site. The nearest listed buildings are
MQP Griff Quarry Planning Application Statement
June 2015
31
over 500m to the west and their settings are not affected by the asphalt plant
and its associated operations.
7.51 Visually the asphalt plant is very well hidden with the only views being longer
distance and interrupted views. All views are well established and no new
impact will arise that have not already been established for several decades.
The landscape around the Site is not subject to any special designations.
7.52 The northern part of Griff No 4 and southern parts of Griff no 3 quarries do sit
within a geological SSSI related to the strata exposed during quarrying. The
SSSI has been applied across a broad area but in reality the area of interest is
restricted to the open quarry faces where rock exposures and stratigraphy
can be easily examined. The application area sits away from the key rock
exposures and proposes no changes to the ground conditions. As no
changes are proposed to what already exists and is well accepted, it is
concluded that no adverse impact will arise to the SSSI by the continued use
of the Site.
7.53 In conclusion there are no environmental reasons to refuse the continued use
of the Site and any impacts that do arise can be dealt with using appropriate
planning conditions.
8 Need for the development
8.1 The proposed development is required to maintain an existing and proven
business line. The asphalt plant has been established for many years and is a
recognised supplier of asphalt into the midlands. Its position close to the M6,
M1, A5 and M69 roads allows a wide distribution area.
8.2 Griff forms one of a chain of plants that manufacture asphalt across the
midlands for MQP and its position sits neatly between some of MQP’s larger
operations such as Cliffe Hill in Leicestershire and Wednesbury in the West
midlands. As a result Griff often provide support for these larger plants during
periods when those larger sites have a major contract to supply or during
periods of maintenance / breakdowns. This is important as road contracts
are often run to tight deadlines to ensure resurfacing works are done within
minimum disruption to traffic flows. A back up facility ensures that if the major
plant suffers any delays, contract timescales can be achieved.
8.3 In the Warwickshire area there are few asphalt plants, the main ones of note
being Griff, Mancetter and Ling Hall. Only Mancetter has the ability to supply
its own stone, all others rely on imports, and the one site that can supply its
own stone cannot provide every grade of aggregate required. Therefore the
proposed development is not materially different to approvals given by the
council to other operators in the county.
8.4 Whilst it may be possible to find an alternative location for an asphalt plant,
the existing plant sits in an established location and in a quarry site that will be
subject to active infilling and recycling works until 2032. This being the case,
MQP Griff Quarry Planning Application Statement
June 2015
32
the justification for the cost and disruption for relocating the existing plant to
another site appears to be unwarranted.
8.5 Should the Griff asphalt plant have to close (although under the existing
planning permissions the plant structure does not have to be removed until
2032), MQP will have to serve its customers by importing the same volume of
asphalt into the county but from its Leicestershire and West Midlands sites. The
net effect of this would be to put the same amount of vehicles onto
Warwickshire’s roads as would result from the proposal to retain the plant at
Griff No 4. On this basis there seems little benefit to preventing the continued
importation of material to Griff No 4 for coating.
8.6 On this basis there is a clear and well established need for an asphalt plant at
this site and its strategic importance for supplying stone for MQP and Hanson
is a key commercial consideration for them especially when supplying
Highway Authority and Highways England contracts to maintain the strategic
highway network.
9 Planning Policy
9.1 Policy in Warwickshire relevant to this proposal is primarily driven by the
County Council and national policy documents rather than local council
policy. These are briefly considered below. The key considerations are that:-
The plant sits inside an active mineral and waste site that is likely to be
active until 2032 under the existing planning permissions;
The proposed use is temporary only linked to the restoration of the
quarry.
Mineral extraction at Griff No 4 Quarry is time limited to 31 October
2015 although the planning permission will endure to 2032 to allow for
infilling and restoration. The plant and structures do not need to be
removed from site until the site is finally restored – probably circa 2032.
Permission to retain the structures therefore already existing via the
main quarrying permission.
Permission to import 25,000 tonnes of stone per annum has already
been granted to the asphalt operation. In addition WCL has
permission to import unspecified but inert materials for producing
recycled aggregate.
The WCL Permission, which also covers the plant site, allows for the
production of recycled aggregate from the site.
The application site sits within a geological SSSI although has no
adverse effect on it.
The wider area around Griff Quarry sits within the West Midlands green
belt;
MQP Griff Quarry Planning Application Statement
June 2015
33
The asphalt plant has been operating in an acceptable manner for
several decades relying predominantly upon imported stone for
much of the last decade due to the inferior quality of the available
stone at Griff;
National Planning Policy Framework (NPPF) requires the safeguarding
of existing planned or potential sites for ....... the manufacture of
coated materials.... etc;
National Planning Policy Guidance (NPPG) on safeguarding advises
that Planning authorities should consider the possibility of combining
safeguarded sites for storage, handling and transport of minerals with
those for processing and distribution of recycled and secondary
aggregate.
9.2 The proposed development seeks the retention and operation of the existing
asphalt plant using imported mineral and possibly recycled materials as might
be made available from the other operations within Griff No 4 Quarry.
National Planning Policy Framework (NPPF)
9.3 NPPF must be taken into account in the preparation of local and
neighbourhood plans, and is a material consideration in planning decisions.
Planning policies and decisions must reflect and where appropriate promote
relevant EU obligations and statutory requirements.
9.4 Section 38(6) of the Planning and Compulsory Purchase Act 2004 and section
70(2) of the Town and Country Planning Act 1990 require that a determination
of any planning application must be in accordance with the development
plan unless material considerations indicate otherwise.
9.5 Paragraph 7 of NPPF sets out the three dimensions to sustainable
development as being;
An economic role
A social role
An environmental role
9.6 The proposed development fits these aims by both underpinning built
development, as well as providing jobs in its own right, all in a sustainable
way. The materials produced will contribute to maintaining existing and
building new infrastructure and other facilities necessary for vibrant healthy
communities to exist at all. Whilst the use is industrial in nature the
development has been designed to restrict its impacts up on the environment
to acceptable levels whilst not compromising the ability to supply asphalt to
the construction sector. The existing use has been proven to be
environmentally acceptable in this location having operated for many years.
This continuation of that use will enable Warwickshire to remain self sufficient
in the supply of asphalt. In this way the proposals meet these three
dimensions.
MQP Griff Quarry Planning Application Statement
June 2015
34
9.7 The NPPF provides the most up to date policy on mineral matters but where
differences arise between the Warwickshire Minerals Local Plan (the MLP) and
the NPPF, the NPPF takes precedence.
9.8 Chapter 13 of the NPPF recognises the need to provide a steady and
adequate supply of minerals and recognises the importance of related
facilities. In this regard Local Planning Authorities are required to safeguard
existing, planned and potential sites for, the manufacture of coated
materials.
9.9 The mineral, waste and asphalt plant activities at Griff have, in several
planning decisions, previously been confirmed as not being inappropriate in
the green belt (see planning history section above). Whilst the cessation of
mineral extraction at Griff No 4 Quarry should occur from 31 October 2015,
the mineral consent its self remains live to 2032 to allow for restoration. The
condition requiring removal of the plant structures is linked to the final
restoration, therefore it seems that the structures could remain on site to 2032.
9.10 The NPPF confirms that the Government aims to pursue economic growth in
order to create jobs and prosperity and gives significant weight to the need
to support economic growth through the planning system. Furthermore it
states that investment in business should not be over burdened by the
combined requirements of planning policy expectations.
9.11 The NPPF states that decisions should encourage the effective use of land by
re-using land that has been previously developed, provided that it is not of
high environmental value.
Safeguarding Asphalt (Coated Materials) Plant Sites.
9.12 As the Warwickshire Minerals Local Plan pre dates NPPF, it clearly has not had
the opportunity to safeguard such sites. However, it seems logical that as the
LAA recognises a very restricted number of hard rock sites it would be
reasonable to assume that the safeguarding of an existing asphalt plants at
the two active sites would be appropriate.
9.13 Paragraph 144 of NPPF requires that great weight be given to the benefit of
mineral extraction, including to the economy. Whilst the proposed
development does not propose mineral extraction per se, what it does
propose is the provision of coated materials, an aggregate product, which is
one of the obvious contributors to the economy arising directly from the
obligation to maintain a steady and adequate supply of aggregate
materials. The LAA makes it clear that Warwickshire is a net importer of
Crushed rock and therefore, due to its lack of active quarry sites, it may still
assist in its fulfilment of its commitments to the construction industry by making
sure that sufficient facilities to produce materials such as coated stone are
available in the county.
9.14 The key aim of paragraph 144 is therefore to recognise the economic benefit
of aggregate provision in its many forms (e.g. dry aggregate, concrete or
MQP Griff Quarry Planning Application Statement
June 2015
35
coated stone,) to the economy and to give it great weight in determining
planning applications. The source of that aggregate (i.e. whether recycled or
primary) is equally important to underpinning economic development as,
without good road surfaces, economic activity will inevitably suffer for the
wider economy. It is therefore considered that applying great weight should
also be afforded to the provision to the Griff asphalt plant due to the existing
established benefit to the economy.
Green Belt
9.15 Paragraph 79 of the NPPF makes clear the need to maintain openness and
prevent the coalescence of urban areas. A key consideration in the current
proposal is that the development is temporary only and is linked to the life of
the active quarry and infilling operations. Once the quarry site is restored, the
asphalt plant will be removed. This will ensure that long term openness is
maintained.
9.16 Paragraph 89 adds that whilst the construction of new buildings is
inappropriate in the Green Belt there are certain exceptions. Paragraph 90
advises that certain forms of development are not inappropriate in Green Belt
provided they preserve the openness of the Green Belt and do not conflict
with the purposes of including land in Green Belt. These include:-
mineral extraction;
engineering operations;
9.17 Therefore whilst new buildings in the Green Belt are usually inappropriate,
certain forms of development are not inappropriate and this includes minerals
extraction and engineering operations. Asphalt plants in active mineral sites
appear to meet these criteria. Furthermore inappropriate development in
the Green Belt can be permissible if very special circumstances arise.
9.18 The permission that allows the Griff Site to operate is a mineral extraction
consent with associated waste elements and already allows the existing plant
to remain to circa 2032.
9.19 NPPF requires planning authorities to safeguard existing, planned and
potential sites for concrete batching as well as sites for the handling,
processing and distribution of substitute, recycled and secondary aggregate
materials.
9.20 NPPF recognises that mineral development is not inappropriate in the Green
Belt; safeguarding of coated materials sites is promoted at mineral sites; it
therefore follows that coated materials facilities in quarries in the green belt
should be not inappropriate, especially where they are temporary only.
Green Belt - Very Special Circumstances
MQP Griff Quarry Planning Application Statement
June 2015
36
9.21 The LAA makes it clear that at present Warwickshire is heavily reliant on
imported crushed rock to meet its steady and adequate supply of aggregate
minerals. Indeed only one asphalt plant in the county can provide its own
source of aggregate (Mancetter).
9.22 Therefore, it is concluded that very special circumstances exist at Griff that
that justify the retention of the asphalt plant. The key points are;
There is a demonstrable need for asphalt in Warwickshire and wider
West Midlands;
Openness will not be adversely affected as the development site is an
existing permitted development so no additional land will be
affected;
The permitted development is temporary only as the Site is fully
restored by the 2032.
That the Griff Site is a mineral excavation and is therefore not
inappropriate in the Green Belt;
The only views of the operation are distant and / or intermittent ones;
The Griff asphalt plant site is a key element in Warwickshire
maintaining a steady and adequate supply of coated materials;
NPPF Safeguarding policy recognises that existing and potential
coated material sites should be safeguarded ;
Asphalt is a hot product that can only be used when it is at a high
temperature. Once loaded into a lorry, the asphalt immediately starts
to cool and becomes more difficult to work and lay the cooler it gets.
Having a manufacturing source close to the end user is therefore
important to successfully laying the asphalt and avoiding a high
wastage factor.
The continuation of supply of asphalt from an established location to
a well-established market;
There is potential to use recycled materials in asphalt production from
the recycling operations;
The Warwickshire Minerals Local Plan dates back to 1995 and has yet
to be updated to incorporate the NPPF guidance. In these
circumstances the latter takes presence over the former where there
is a conflict between MLP policy and NPPF. It is our view that it would
be appropriate to safeguard the Griff Site for coated materials under
the NPPF policy.
9.23 In these circumstances it is considered that the proposed development is
acceptable and that very special circumstances exist to justify the retention
of the asphalt plant within the Site.
MQP Griff Quarry Planning Application Statement
June 2015
37
Minerals Local Plan for Warwickshire (Feb 1995) (the MLP)
9.24 The Minerals Local Plan adopted in 1995 is saved although a number of
policies within have been allowed to expire. A revised minerals local plan is
currently being prepared but is not yet available for consultation.
9.25 Particularly relevant to the current proposal is Policy M7 (d) which requires
that proposals for operations ancillary or secondary to mineral extraction will
normally be expected to be sited adjacent to primary plant. The use of such
plant will be restricted to processes principally using minerals produced from
the site. Where appropriate conditions may be imposed or agreements
sought to control the life-span of ancillary and secondary to mineral
extraction.
9.26 All of the hard rock sites in the county sit within the green belt and policy M7d
promotes ancillary uses at those sites. Policy would therefore seem to support
such ancillary uses in the green belt.
9.27 The asphalt plant at the Site is permitted as part of the Griff No 4 quarrying
operation, but as appropriate reserves dwindled and mineral quality lessened
(for coating purposes), permission was granted to allow the use of imported
materials for coating. Since 2007 the asphalt plant has relied almost
exclusively on imported materials for this purpose. Breedon Aggregates Ling
Hall plant is likewise understood to be heavily reliant on imported stone to
enable the production of coated products.
9.28 This being the case, the importation of stone to the asphalt plant at Griff
would appear to have a precedent as per the Ling Hall decision (ref
RBC/10CM018 Granted on 21-Apr-2011), as well as the previous permission to
import 63+ PSV stone to Griff.
9.29 Policy M6 requires the assessment of proposals on their overall likely impact
on, (amongst others) ‘Operational and Economic Need’ and ‘green belt’.
9.30 The LAA makes it clear that there is only a very limited active supply of
crushed rock in Warwickshire, with there being 3 hard rock quarries only one
of which is actively producing stone. On this basis the county is heavily reliant
on imported crushed rock anyway.
9.31 There are no protected sites that are adversely affected despite the Site
sitting within the Griff geological SSSI. On this basis the development accords
with the development plan.
9.32 Therefore in terms of the MLP the proposals accord with the saved policies.
9.33 There is a well established need in the county for road surfacing materials and
the Griff asphalt plant has assisted in satisfying that need for many years. It is
also clear that, as there is only one operational hard rock quarry in the
county, coated stone from sources other than Mancetter quarry rely on
materials imported from Leicestershire et al.
MQP Griff Quarry Planning Application Statement
June 2015
38
Nuneaton and Bedworth
9.34 The adopted development plan in Nuneaton and Bedworth currently
comprises:
Saved policies from the Nuneaton and Bedworth Local Plan 2006;
The Local Plan 2006 Proposals Map; and
Supplementary Planning Documents (SPD's).
9.35 The Proposals Map only shows two items of relevance at the Griff site these
being the general green belt designation of the area and secondly the Griff
geological SSSI. These are both addressed in detail above.
9.36 The employment at the Site has 5 established site based jobs, (being two
drivers and three site staff), but the operation supports many more off site
roles involved in sales, technical support and administration of the sites
function. Therefore whilst the employment numbers involved are not high,
they are none the less existing jobs that will be lost if the site was to close.
Retention of the asphalt plant will secure these jobs.
9.37 Therefore in terms of the Nuneaton and Bedworth planning policy, the
proposals accord with the relevant adopted policies, bearing in mind this is a
predominantly mineral operation.
Policy Summary
9.38 In summary, the site is already permitted for asphalt production linked to
mineral extraction and waste disposal and aggregate recovery operations.
Mineral reserves remain to be worked at Griff quarry but are unlikely to be
exploited in a major way in the future. Asphalt production is likely to be reliant
on permission to import aggregate for coating.
9.39 The NPPF recognises the importance of safeguarding asphalt plant sites for
the production of coated materials and Warwickshire is reliant on imported
crushed rock for most of its asphalt needs.
9.40 NPPF accepts minerals development in the green belt need not be
inappropriate and the existence of the quarry planning permission expiring in
2032 means that this is still mineral development and does not therefore
conflict with policy. Furthermore there is potential for recycled aggregate to
be supplied from the permitted operations on site in due course once
recycling activities commence.
9.41 On the above basis the continued use of the asphalt plant is supported by
policy especially as the wider site will be in active use to 2032 anyway.
9.42 The LAA indicates that a significant volume of crushed rock is imported into
Warwickshire, particularly from Leicestershire, as there is only one active
crushed rock site in the county. The importation of mineral for asphalt
production is therefore not likely to have a major difference to existing
MQP Griff Quarry Planning Application Statement
June 2015
39
importation figures as if the Griff asphalt plant was to close, replacement
tonnage would still be imported into the county.
9.43 The need to manufacture hot asphalt products close to the end user supports
continued use in this location compared to importing hot asphalt from more
distant sites in other counties.
9.44 It is also considered that very special circumstances exist to justify the
continued operation of the plant whilst Griff No 4 quarry is still an active
development.
9.45 In very broad terms development plan policy requires that the proposed use
demonstrates a proven need and the design and environmental effects of
the proposal can be safely accommodated without any unacceptable
impacts arising.
9.46 The proposals are already accepted and well established as indeed is the
need for the products from the Site. There are no unacceptable
environmental impacts and any impacts that do arise can be (and indeed
already are) controlled by appropriate conditions as well as via the PPC
permitting system.
9.47 Warwickshire County Council, when faced with a similar request at Ling Hall
Quarry (for a variation of conditions in order to retain an asphalt coating
plant relying on imported mineral - ref RBC/10CM018) granted planning
permission and seemingly introduced a precedent that can be easily applied
to the situation at Griff as set out under this proposal.
9.48 On the above basis the proposals can be considered to be appropriate and
accord with both the Development Plan and national level policy. We
therefore consider that proposal should be approved without delay in
accordance with NPPF.
10 Conclusion
10.1 In summary MQP is seeking planning permission to retain and operate the
existing asphalt plant at Griff Quarry and to supply that operation with
materials imported by road at a rate of up to 50,000 tonnes per annum.
10.2 The existing planning permissions imply that the asphalt plant can remain on
site until final restoration, but that stone cannot be imported to the plant
beyond 31 October 2015. Theoretically the plant could remain on site to 2032,
but not be used. The continued importation of stone would therefore allow an
existing facility at an operational site to remain active, as well as maintaining
the associated jobs and contributions to the local economy.
10.3 The Applicant has operated an asphalt business at Griff for several decades
with the quarry its self having been in operation for over 50 years under a
series of different owners and planning permissions.
MQP Griff Quarry Planning Application Statement
June 2015
40
10.4 The Site is already an ever present element in the supply of asphalt to
construction works in the Birmingham, Warwickshire and south midlands
areas.
10.5 It is the Applicants belief that the continued use of the Site will assist in
maintaining the provision of coated materials to the local construction
market as well as ensuring MQP retains the flexibility to supply major road
contracts and have a back up supply option located close to the motorway
network.
10.6 The continuation of the Site will support an additional 5 roles already directly
based at the site as well as additional roles linked to the administration,
production, sales, distribution and delivery of products from the Site.
10.7 Whilst a standalone asphalt plant in the Green Belt may be seen as in-
appropriate development, being an existing permitted mineral site, such
development is not inappropriate. This therefore accords with the NPPF
paragraphs 90, 143 and 145 regarding Green Belt policy and the obligation
on mineral planning authorities to both maintain a steady and adequate
supply of aggregate; and to safeguard existing and potential ancillary plant.
10.8 A range of policies in the Development Plan documents relate to the
proposed use and are discussed above. The proposals accord with these
policies. It is therefore the Applicants view that the proposals accord with the
Development Plan.
10.9 In light of the above it is concluded that the proposed development is
needed and accords with planning policy. Therefore in accordance with
paragraph 14 of the NPPF, the proposals should be approved without delay.