Tel:
Email:
020 8541 7593
Sue.janota@surreycc.gov.uk
Head of Planning Services
Elmbridge Borough Council
Civic Centre
High Street
Esher
Surrey
KT10 9SD
Environment & Infrastructure
Directorate
Spatial Planning Team
Surrey County Council
County Hall
Kingston upon Thames
KT1 2DN
Sent to: consultation@elmbridge.gov.uk
17 March 2014
Dear Ms Fossett
Elmbridge Local Plan: Proposed Submission Development Management Plan – February
2014
Comments by Surrey County Council
Thank you for consulting Surrey County Council on the Proposed Submission version of the
Development Management Plan for Elmbridge.
We have responded previously to consultations on the Plan, most recently on the draft version
(our response dated 17 May 2013). The main issues identified related to Policy DM5 (now renumbered DM20) and the implications for providing additional school places to meet forecast needs, Policy DM11 (now renumbered DM12) on heritage, Policy DM16 (now renumbered DM2) on design and amenity and Paragraph 2.105 (now renumbered 2.23) on access and parking.
In relation to this Proposed Submission version, we support the additional wording in paragraph
2.91 that recognises that there may be exceptional circumstances when limited community or social infrastructure development of open space within the urban area could be acceptable. This would address our concern that the Plan should recognise that exceptionally there may be a need to develop open space in the urban area to accommodate new school development to meet local needs. We also support the inclusion of County Sites of Archaeological Importance in Policy
DM12 – Heritage and the includion of the additional wording we suggested in paragraph 2.23.
In relation to minerals and waste we would like to see the following minor amendments:

Policy DM2 - Design and Amenity - Insert a new paragraph after paragraph b as follows:
“Proposals should provide for the efficient use of minerals and incorporate a proportion of recycled or secondary aggregate to reduce the demand for land-won sand and gravel.”
Contd/…..


Insert a new paragraph after paragraph 2.4 as follows:
“Minerals are a finite resource. It is important to conserve mineral resources given that sharp sands & gravels found in Surrey are expected to diminish markedly from around 2026. This policy will help to conserve mineral resources by advocating more efficient use of minerals in construction and the incorporation of recycled and secondary aggre gates in new development proposals.”
These suggested minor amendments, which we do not consider as being so significant as to raise issues of soundness, and the reasoning behind them are included in the attached Appendix.
If you have any queries, please do not hesitate to contact Sue Janota. We are not intending to participate at the oral examination.
Yours sincerely
Sue Janota
Spatial Planning Team Manager

Appendix
Detailed comments on Policy DM2 made by Surrey County Council on the Proposed
Submission Development Management Plan
The following comments include suggested minor amendments that we would wish to see made, but are not so significant as to raise issues of soundness.
The mineral planning authority (MPA) commented at the Draft Plan stage that Policy DM16 and the supporting text should be amended to include explicit references to promote sustainable construction in terms of providing for the more efficient use of minerals, the inclusion of some recycled aggregates in new development proposals and an explanation as to why this is important given future concerns over mineral supply. This was in order to facilitate the implementation of Surrey Minerals Plan Core Strategy DPD (SMP CS DPD) Policy MC4 and help to reduce the need to import both land-won and marine sand and gravel from areas much further afield. The Borough Council is understood to have decided not to incorporate this change because it was already reflected in Elmbridge Core Strategy Policy CS27 as well as the Design and Character SPD.
The waste planning authority (WPA) welcomes the fact that Elmbridge Core Strategy Policy
CS27 fully addresses the sustainable waste management aspects of sustainable construction reflecting the requirements of the Surrey Waste Plan 2008. However, it does not fully reflect the mineral conservation aspects of sustainable construction promoted in SMP CS DPD Objective 1 and Policy MC4. Objective 1 encourages the use of substitute materials in construction. Policy
MC4 requires partnership working between the MPA and the Borough Council to provide for the efficient use of minerals and enable the incorporation of a proportion of recycled or secondary aggregate in new projects.
The Borough C ouncil’s Design and Character SPD (18 April 2012) helpfully requires consideration to be given to the reuse or recycling of any existing building materials. However, it falls short of explicitly encouraging the efficient use of minerals in new projects. Further, it does not go far enough to promote the use of recycled or secondary aggregates in construction. This is because this reference is likely to be interpreted as being confined to site derived material rather than the more likely scenario in which recycled or secondary aggregates would need to be brought in from specialist recycling facilities elsewhere in the county. This will result either when the existing building materials are found to be unsuitable for re-use on site, or insufficient in volume to justify the necessary investment in bringing in crushing and screening equipment to enable the material to be recycled and reused on site, or when the area of land is too small to allow crushing and screening operations to be carried out on site.
The Bo rough Council’s view that the MPA’s concerns are already addressed may be due to the partial overlap that exists between the sustainable waste management and the mineral conservation aspects of sustainable construction. However, the MPA’s view is that this overlap is not sufficient to adequately address its concerns which relate to an impending issue concerning future mineral supply in the county. This relates to resources of sharp sand & gravel in Surrey necessary for the production of concreting aggregates which are anticipated to diminish markedly from around 2026 onwards. This matter is highlighted in paragraphs 4.6, 4.7 and 4.16 of the
Local Aggregate Assessment (October 2013).
The MPA’s concern therefore has a direct impact on the provision of minerals which is highlighted under para 156 of the NPPF as being a strategic priority. It is noted that para 179 of the NPPF requires local planning authorities to work collaboratively with other bodies to ensure that strategic priorities across local boundaries are properly co-ordinated and clearly reflected in individual Local Plans.

The MPA is reliant on the co-operation of district / borough councils on this subject to ensure the effective implementation of SMP Policy MC4, given their responsibility for determining the vast majority of development in Surrey. The MPA notes that Planning Practice Guidance (6 March
2014) para 014 / reference ID: 9-014-20140306 in relation to the Duty to Co-operate does state that close cooperation between district local planning authorities and county councils in two tier local planning authority areas will be critical to ensure that both tiers are effective when planning for strategic matters such as minerals, waste, transport and education.
Given concerns over future mineral supply, the MPA has been proactive in planning to increase the supply of recycled and secondary aggregates produced in Surrey. Firstly, in July 2011, the
MPA adopted the SMP CS DPD. Policy MC5 seeks to increase the production of recycled and secondary aggregates in the county from 0.42 (SCC Local Aggregate Assessment - Oct 2013, page 9) to at least 0.8 million tonnes per annum (mtpa) between 2011 and 2016 and at least 0.9 mtpa by 2026. Secondly, in February 2014, the County Council adopted the Aggregates
Recycling Joint Development Plan Document (ARJDPD) for the Minerals and Waste Plans. This
DPD allocates sites for the production of recycled and secondary aggregates and includes a policy to promote such development on non-allocated sites.
To over come the MPA’s concern, the following minor amendments are suggested:
1. Policy DM2 - Design and Amenity
Insert a new para after para b as follows: “Proposals should provide for the efficient use of minerals and incorporate a proportion of recycled or secondary aggregate to reduce the demand for landwon sand and gravel.”
2. Insert a new para after para 2.4 as follows:
“Minerals are a finite resource. It is important to conserve mineral resources given that sharp sands & gravels found in Surrey are expected to diminish markedly from around 2026. This policy will help to conserve mineral resources by advocating more efficient use of minerals in construction and the incorporation of recycled and secondary aggregates in new development proposals .”