FOREST OF DEAN CINDERFORD NORTHERN QUARTER AREA ACTION PLAN DPD
EXAMINATION – OCTOBER 2011
SESSIONS 13 & 14 – WEDNESDAY 19 OCTOBER 2011
HEARING STATEMENT by THE COAL AUTHORITY (169659)
ENVIRONMENT; LANDSCAPE; MINERALS; WASTE and ENERGY (Policies 26-30)
DELIVERY; PHASING (Policies 3-5); IMPLEMENTATION; MONITORING and REVIEW
MINERAL SAFEGUARDING & MINING LEGACY
Whole AAP Fails Soundness Tests (Consistency, Evidence and Justified)
The Coal Authority Examination Commentary – Mineral Safeguarding and Mining
Legacy
Inspector’s Issues for ENVIRONMENT; LANDSCAPE; MINERALS; WASTE and
ENERGY (Policies 26-30) i) Are the proposals for growth and change in this area appropriate and ii) justified in terms of their landscape, environmental and ecological/biodiversity impacts?
Are the proposals consistent with national minerals, waste and energy policies and guidance, as well as the Core Strategy?
Inspector’s Issues for DELIVERY; PHASING (Policies 3-5); IMPLEMENTATION;
MONITORING and REVIEW i) Are the proposals deliverable in the timescale envisaged and with the phasing proposed, including in terms of providing the necessary supporting infrastructure? ii) Is the plan reasonably flexible to assist implementation and does it enable adequate monitoring and review of its effectiveness and delivery?
1. The Coal Authority has raised issues in the response to the Publication Cinderford
Northern Quarter Area Action Plan which largely related to the about-turn the AAP had made on plan content relating to mineral sterilisation and mining legacy. The examination of this
AAP will follow the examination into the Core Strategy where it appears that the Council are potentially proposing some changes which may be pertinent.

Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
2. The representations made by The Coal Authority relate to omissions from the AAP in relation to the Overall Plan ( Rep Ref No. CNQPD11); Mineral Sterilisation ( Rep Ref No.
CNQPD12 ); and Ground Stability arising from Mining Legacy ( Rep Ref No. CNQPD13 ). It is noted that the Council in its document detailing the representations also indicates the Council
Response and indicates ‘Officer Recommendation’ which intimate potential suggested changes. The status of this document is unclear, however to aid the discussion at the
Examination Hearing The Coal Authority would confirm that if the Council were to put forward detailed changes in line with those intimated in the officer’s recommendation and council response that we would broadly support the direction of travel suggested. Unfortunately the
Council has not indicated any view on the detailed suggestions for change The Coal
Authority put in their formal representations.
Mining Legacy
3. The scale, intensity and nature of the mining legacy present within this AAP means that it is an important locally distinctive issue that needs to be addressed by the AAP. PPG14 requires development plans to set out both a strategic policy and a development management policy on the issue of ground instability. The DPD is the appropriate document to set out a suitable development management framework. The AAP area has extensive mining legacy spread throughout the whole plan boundary, this includes in excess of 150 mine entries, shallow mine workings, potential historic shallow workings, coal outcrops, former surface mining. In the context of the Forest of Dean the AAP covers an area of concentrated mining legacy such that it is a fundamental issue that the AAP must adequately address and appropriately plan for in order to be Sound.
4. The Coal Authority would reiterate that land instability and mining legacy is not normally a complete constraint on the new development, rather it can be argued that because mining legacy matters have been addressed the new development is safe, stable and sustainable.
Mining legacy will however have the potential to impact on how sites should be planned, the relative costs of developing and their deliverability. If mining legacy is not appropriately remediated then the development will be at serious risk and public safety will be unduly compromised.
5. Mine entries have the potential to cause a serious public safety hazard, many of the old mine shafts pose risks to public safety by unexpected collapses. The ground opens up and material slumps into the shaft leaving the shaft itself exposed and uncovered. Addressing the legacy of coal mining is important. The Coal Authority has a duty to protect public safety
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659) under Section 3 of the Coal Industry Act 1994 and operates both a Mines Rescue Service and a comprehensive 24 hour, 365 days a year emergency response service to deal with any incidents which pose a risk to the safety of the public that are associated with former coal mining anywhere across the coalfields of England, Scotland and Wales. The Coal Authority is seeking to influence both policy making and development/land use management to raise this issue in order to ensure mining legacy matters are adequately addressed and considered.
6. MPG3 details the particular role that The Coal Authority has in relation to formulating development plan policies for Coal. MPG3 in paragraph 14 talks about priority being given to proposals which bring about environmental improvements, including the restoration of previously derelict areas or the stabilisation of unstable ground. The role for the
Development Plan would be further supported by paragraph 2 of PPG14 which indicates the need for guidance should be set out at all stages of planning.
7. PPG14 Paragraphs 25 to 30 set out the obligations on development plans to consider ground stability issues. Paragraph 26 makes it clear that there is a need for strategic policy guidance on ground stability, whilst Paragraph 27 makes it clear that more detailed development management policies should also be drawn up. Although PPG14 was written when the old system of development plans was in place, the twin track approach of strategic and detailed policies is equally applicable to the current LDF system. A strategic policy should be incorporated in the Core Strategy, with detailed development management style policies being included within this AAP (and then in other AAPs or DPDs as appropriate for other parts of the Forest of Dean). Paragraph 30 of PPG14 goes onto make it clear that development proposals (i.e. allocations etc) put forward in development plans should take into account the presence of physical conditions, which will include mining legacy. The AAP is considered fundamentally unsound as presently set out.
8. The Coal Authority has suggested that the Policy CSP1 in the Core Strategy (5th Bullet point) be amended as follows to set out a relevant planning policy context:
 “The impact of the development on any land contamination or risk to the development from ground instability including from mining legacy - whether it is necessary to
provide mitigation or remediation…”
9. By the time of this examination hearing we will have the benefit of knowing how the
Council have chosen to respond to the Core Strategy which will then raise an issue of conformity between this AAP and the Core Strategy to be further considered.
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
10. The Coal Authority had previously made comments on the Preferred Options Report in
November 2009 both in support of the AAP content and in objection. The Coal Authority made a further ‘no-comment’ in March 2011 on the further consultation changes which did not address our areas of concern.
11. Unfortunately for unknown reasons the Council has decided to remove plan content from the AAP which The Coal Authority had previously supported , including the former ‘Policy 29’ which specifically addressed mining legacy. The AAP is now considered to fail the test of being locally distinctive, it does not set out an appropriate policy context to address planning issues within the site and the decision to ignore material planning considerations is not justified. The AAP lacks the necessary conformity to national planning policy set out in
PPG14, MPG3 and MPS1.
12. At the preferred options stage The Coal Authority made the following comment:
“Given the extensive legacy of coal mining activities within the AAP boundary, and the potential for this to give rise to land stability issues (as recognised elsewhere within the
AAP), it would be helpful to make reference to PPG14 within the section on National
Planning Policy Guidance. The following additional paragraph is suggested for inclusion:
“The Cinderford Northern Quarter has previously experienced mining activities which have left an environmental legacy. This legacy has the potential to lead to public safety hazards unless there is awareness and any risks have been fully considered, with appropriate treatment/mitigation measures being incorporated within new developments. The AAP area may be affected by former mine workings at shallow depth, and there are also recorded mine entries and a former surface coal mine site within the plan boundary. In line with the requirements of PPG14 Development on Unstable Land (1990), the AAP therefore seeks to ensure that land is thoroughly investigated for mining legacy problems, with any issues then being appropriately treated to ensure that future development is safe and stable.”
13. Unfortunately the AAP has only responded positively in a partial manner to some of our previously made comment and has removed Policy 29 which now leaves the AAP deficient in the area of mining legacy and land instability policy such that it does not comply with national policy in PPG14, is ineffective and the AAP is unjustified.
14. The AAP therefore fails to comply with national planning policy in PPG14 and MPG3.
We note that some of the wording we requested previously has been included with paragraphs 5.117 and 5.119; however this potentially positive work has been undermined by
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659) the removal of a suitable policy. The Coal Authority previously supported the inclusion of a specific policy to address the mining legacy within the AAP area. The reinstatement of a suitable policy is considered essential in order to ensure that coal mining legacy issues are addressed within new development proposals in line with the requirements of PPG14.
15. The plan is unbalanced in its overall policy framework with regard to the sphere of potential environmental constraints. Suitable policies are included to address flood risk and contaminated land; however land stability is not addressed. In the context of major development this is considered to be a fundamental omission as ground conditions on this site are likely to be a significant influence on features such as layout and will influence the development economics of the viability of developing the site and the delivery of the AAP.
As an example where substantial grouting or filling is required to address mining legacy this can be a potentially prohibitive ground preparation cost. However if the alternative method of removing the surface coal is explored and found to be viable then this can be undertaken in some circumstances at nil cost to the developer by a suitable operator who then leaves a stable and developable new surface following the prior extraction activity.
16. As an example of cost and delivery, an operator looked at a 5Ha site which required stabilisation by grouting to address historical surface workings. The cost of such grouting would have been some £1.2million, whereas the alternative was for the developer to have nil cost by allowing a coal operator to undertake the prior extraction of the coal and sell the extracted mineral. Consequently it is considered vital that the options for dealing with land instability and the suitability or not of prior extraction of the coal and fireclay should be set out in policy to allow the AAP ambitions to be adequately and effectively delivered.
17. In its representation on the Publication AAP, The Coal Authority requested the reinstatement of a Policy (the former Policy 29 amended) addressing minerals issues to read as below:
“Policy xx – Minerals
The Council will require development proposals to be supported by ground investigations to determine the extent and condition of the fill to establish the need for deep piles or ground improvement techniques to deal with the ground conditions. In addition, the Council will encourage proposals to be supported by the mapping, assessment and appropriate treatment of any remaining mine entries and/or voids. Any mineral related proposals within the Masterplan area will be considered in light of the overall regeneration objectives for the area and relevant policies within the Area Action Plan, Forest of Dean Core Strategy and
Gloucestershire Minerals Local Plan (until such time as it is replaced by the Minerals Core
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
Strategy). Any proposals for freemining of the site would require support and consent from the Forestry Commission (Deputy Gaveller) and planning consent from the Council.
Supporting Text
The Cinderford Northern Quarter has previously experienced mining activities which have left an environmental legacy. This legacy has the potential to lead to public safety hazards unless there is awareness and any risks have been fully considered, with appropriate treatment/mitigation measures being incorporated within new developments. The AAP area may be affected by former mine workings at shallow depth, and there are also recorded mine entries and a former surface coal mine site within the plan boundary. In line with the requirements of PPG14 Development on Unstable Land (1990), the AAP therefore seeks to ensure that land is thoroughly investigated for mining legacy problems, with any issues then being appropriately treated to ensure that future development is safe and stable.
”
18. It is noted within the Council’s response to Representation CNQPD10 that the Council will continue to liaise with The Coal Authority. Unfortunately the Council has made no effort to discuss our representations or seek any resolution to this issue ahead of the examination hearings. The ‘officer recommendation’ in the Council’s record of representations appears to indicate that the LPA may be prepared to incorporate our suggested change in the precise form. However there is no clarity as to whether this is a firm proposal or not?
19. The Council fundamentally misunderstand national policy requirements set out in PPG14 and MPG3. Addressing ground instability, including that arising from mining legacy is not a
‘minerals planning issue’. The LPA appear to want to pass their obligations onto the Mineral
Planning Authority which is fundamentally flawed. The LPA has a duty in its plan-making role and its development management function to consider ground stability arising from mining legacy. The Council operates the ‘risk-based’ approach to mining legacy in their development management function in order to meet the consultation obligations set by The
Coal Authority as a statutory consultee on planning applications. The Coal Authority is also a specific consultation body on all DPDs in England, not just mineral DPDs. The Coal
Authority has pursued representations and appeared at examinations throughout England and without exception Inspectors have agreed that PPG14 requires district-level DPDs to address this national planning policy requirement.
Mineral Safeguarding
20. The definition of Minerals Safeguarding Areas (MSAs) is a matter for Gloucestershire
County Council as the Mineral Planning Authority; however the obligation to protect known
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659) reserves from sterilisation from other forms of development, and promote workable mineral resources to be extracted prior to permanent development on site applies to both tiers of
Planning Authority. Avoidance of the unnecessary sterilisation of the mineral resource is considered necessary in order to meet the guidance in paragraph 13 of MPS1 and paragraph
22 of MPG3. The MPG/MPS series of National Planning Policy applies to all Local
Authorities and to all DPDs being published.
21. The Forest of Dean Core Strategy is not unique in being promoted ahead of the relevant
Minerals DPD, in such circumstances the District Core Strategy cannot refer to a Mineral
Safeguarding Area which does not exist. However the broad principles of mineral safeguarding can be applied.
22. The Coal Authority believes that the coal supply in Britain should contain a significant proportion of indigenous production and the electricity generators made similar statements in their submissions to the 2006 Energy Review. This will offer energy security which is an important Government priority, plus the carbon footprint of indigenously produced coal is materially less than imported coal. MPS1 states that there should be the “...aim to source mineral supplies indigenously, to avoid exporting potential environmental damage, whilst recognising the primary role that market conditions play;...” More recently, The Energy White
Paper considered the issue of safeguarding and stated that “...the Government believes that these factors reflect a value in maintaining access to economically recoverable reserves of coal...” The Coal Authority consider that to achieve these Government aims it is vital that areas such as the Forest of Dean where surface coal resources exist should be appropriately safeguarded through use of an MSA.
23. MPG3 on Coal sets out some brief guidance on how development plans should address
Coal, this includes statements in paragraphs 12 and 37 to ensure that coal resources are not unnecessarily sterilised. Within paragraph 11 it indicates that the main guidance for the appropriate development plan policy approach is set out in MPG1 (now MPS1), and PPG12
(now PPS12). MPS1 sets out the overall approach towards safeguarding of mineral resources, as part of the national objectives for minerals planning it sets out in paragraph 9 as including “to safeguard mineral resources as far as possible.” MPS1 goes on in paragraph
13 to detail the approach that LDDs should take towards safeguarding. The main approach being to
“define Mineral Safeguarding Areas (MSAs) in LDDs, in order that proven resources are not needlessly sterilised by non-mineral development, although there is no presumption that resources defined in MSAs will be worked.”
And then to
“encourage the prior extraction
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659) of minerals, where practicable, if it is necessary for non-mineral development to take place in
MSAs.”
24. The Forest of Dean Core Strategy fails to identify mineral safeguarding as a principle in
Policy CSP1. By the time of this examination hearing we will have the benefit of knowing how the Council have chosen to respond to the Core Strategy which will then raise an issue of conformity between this AAP and the Core Strategy to be further considered. The Council appear to be potentially proposing to put some policy framework into place in the Core
Strategy.
25. The BGS Guide states that “MSAs are areas of known mineral resources that are of sufficient economic or conservation value to warrant protection for generations to come” . It notes that their purpose is “not to preclude automatically other forms of development, but to make sure that mineral resources are adequately and effectively considered in land-use planning decisions” . The Coal Authority’s Surface Coal Resource Plan has been developed in conjunction with British Geological Survey and surface mining operators specifically for use within the planning process. It represents the best available geological and minerals resource information for the area, as required by paragraph 32 of the MPS1 Practice Guide, and therefore demonstrates the existence of proven and economically viable coal resources for planning purposes. The whole AAP is underlain by surface coal resources, which have been partially worked previously. Even in areas previously worked there are often large amounts of economically viable coal suitable for extraction by surface methods, this is because many forms of historic mining were relatively inefficient or areas of coal were left to provide ground support. As identified earlier the prior extraction of existing coal resources can be the most effective method of addressing mining legacy.
26. When combined with the evidence outlined above, which demonstrates that there will be a continued demand for coal over the DPD period, the Coal Authority is of the opinion that there is a clear justification for safeguarding coal through the definition of an MSA covering the surface coal resource area (a matter for the Gloucestershire Minerals Core Strategy).
This should be supported by the inclusion of appropriate policy criteria in the district LDFs including the Forest of Dean Cinderford Northern Quarter AAP to avoid the unnecessary sterilisation of resources where specific land allocations are taking place. This policy should include the encouragement of the prior extraction of coal, where practicable, if it is necessary for non-minerals development to take place within the MSA as a matter of principle. To not do so is fundamentally unsound and contrary to national policy.
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
27. The purpose of such an approach would be to alert applicants to the presence of surface coal resources and ensure that this is taken into account as a material consideration during the assessment of planning applications for the development envisaged by the AAP. In allocating land in the AAP the Council should already have assessed the issue of whether allocation is justified in terms of the impact it may have on the sterilisation of mineral resources. As the AAP has not addressed this then it still remains a matter to be addressed through a suitable policy context for delivery. As a matter of principle The Coal Authority does not wish to prevent the delivery of development sites that have been determined locally as suitable for allocation/development for the wide range of planning reasons. However it is imperative that there is an appropriate policy context to ensure the consideration in delivery of mineral sterilisation and the potential for the prior extraction of mineral resources to avoid that sterilisation.
28. The Coal Authority is aware of many circumstances where prior extraction has been successfully undertaken even within urban areas, including metropolitan areas on small sites. There is a history of prior extraction of coal resources successfully operating at a very small scale in urban areas, including across the heavily urbanised north-east and the westmidlands and other metropolitan areas shows how such schemes can be undertaken without raising any amenity issues for local communities. Prior extraction can often be undertaken as part of normal groundworks and is not therefore a delaying facto r that some Council’s seek to argue. In the context of this AAP as works will almost certainly be required to address mining legacy issues, then prior extraction is likely to be even more appropriate.
29. The Coal Authority requested the following change to the Core Strategy:
Amend Policy CSP1 as follows by an amendment to the first paragraph and the addition of a new bullet point:
“Design, environmental protection and enhancement (strategic objective: providing quality environments)
The design and construction of new development must take into account important characteristics of the environment and conserve, preserve or otherwise respect them in a manner that maintains or enhances their contribution to the environment, including their wider context. New development should demonstrate an efficient use of resources, including prevention of the sterilisation of resources. It should respect wider natural corridors and other natural areas, providing green infrastructure where necessary.

The impact that development will have on the sterilisation of mineral resources and consideration of the potential for the prior extraction of those mineral resources ahead of development …”
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
The Council in their response to the representation appear to indicate that they are willing to make a proposed change on similar but not identical grounds. If this is the case this will set out the conformity context for this AAP.
30. At the preferred options stage on this AAP, The Coal Authority supported and made the following comment on Policy 31:
“The Coal Authority welcomes the recognition within paragraph 7.109 of the AAP that coal resources are present within the Northern Quarter area. The inclusion of a criterion relating to the prior extraction of minerals within Policy 31 is also supported. However, given the legacy of former coal mining within this area (see further comments below), it is considered that policy 31 could make reference to the fact that the extraction of any remnant shallow coal resources may provide a sustainable option for treating any land instability problems in advance of development taking place. This potential benefit is specifically recognised within paragraph 14 of MPG3, which states that policies should give priority to proposals which will bring about environmental improvements, for example by the stabilisation of unstable ground. The following minor amendments to the 5 th criterion of Policy 31 are therefore suggested:
 “Potential extraction prior to commencement where appropriate (particularly where this w ould assist in the treatment of land stability issues in advance of development)”
31. Unfortunately the Council has chosen to remove the former Policy 31 leaving a fundamental policy vacuum for addressing the issues of mineral safeguarding and the potential impacts of mineral sterilisation on the surface coal resource. The Coal Authority as the relevant specific consultation body is charged by the Secretary of State for Energy and
Climate Change with ensuring that surface coal resources are not needlessly sterilised in accordance with national policy set out in MPS1.
32. The Forest of Dean operates in a slightly different manner to the rest of the UK in relation to the granting of consents for coal extraction (in most cases but not all) with the Gaveller having control of the licensing regime as opposed to The Coal Authority (although the
Gaveller is jointly funded by The Coal Authority and the Forestry Commission). However
The Coal Authority still has responsibility to consider issues of mineral sterilisation and it deals with all issues of mining legacy that arise in the Forest both from historic and recent mining activity. We are also the relevant statutory consultee for both development plan and development management issues in the plan area.
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
33. Whilst the plan acknowledges the presence of surface coal resources in the area in paragraph 5.121 and identifies the potential for future extraction in paragraph 5.122, there is no positive policy context in the AAP to prevent sterilisation of this important resource. Nor is there any longer any suitable policy context aimed at encouraging and facilitating the prior extraction of surface coal resources ahead of new development. In this respect the AAP fails to have regard to national policy set out in MPS1 (Planning and Minerals) and the MPS1
Practice Guide along with the BGS Document ‘A Guide to Mineral Safeguarding in England’.
34. Whilst it is for the relevant Minerals Core Strategy prepared by the County Council to designate Mineral Safeguarding Areas (MSA) that process is merely one tool in implementing national minerals planning policy. It remains a general responsibility on all
LPAs both in their plan making and development management decision making to ensure that the objectives of MPS1 are fully met. This means that the obligation to prevent the unnecessary sterilisation of minerals falls on all DPDs irrespective of whether they are within a defined MSA or not. The same general obligation applies to the promotion of the prior extraction of mineral resources ahead of non-mineral surface development. The statement set out in paragraph 5.125 of the AAP is not considered to be an effective or justified mechanism of achieving this national policy objective, therefore the AAP is considered to be
UNSOUND .
35. The removal of a policy context which the former Policy 31 provided is considered to be a retrograde step which has taken the AAP out of conformity with national policy. Inclusion of the wording in text does not address the requirements of national policy.
36. The plan in paragraph 5.125 also appears to pre-determine any due consideration of any prior extraction or other mineral extraction proposal that may come forward. This is particularly concerning given the legacy of former coal mining within this area as the extraction of any remnant shallow coal resources may provide a sustainable option for treating any land instability problems in advance of development taking place. This potential benefit is specifically recognised within paragraph 14 of MPG3, which states that policies should give priority to proposals which will bring about environmental improvements, for example by the stabilisation of unstable ground. The national importance of fireclay should not be forgotten either.
37. In response to the Publication AAP The Coal Authority requested the reinstatement of a
Policy addressing minerals issues to read as below:
“Policy xx – Minerals
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Forest of Dean Cinderford Northern Quarter AAP Examination
Sessions 13 & 14 – Wednesday 19 th October 2011
Hearing Statement by The Coal Authority (169659)
In considering development proposals in the AAP area there will need to be consideration of the impact that the proposal may have on the sterilisation of the surface mineral resources present including coal and fireclay. Where possible, practical and environmentally acceptable the potential extraction of surface mineral resources prior to the commencement of development should be actively considered. Where the prior extraction of mineral resources would assist in the mitigation and remediation of mining legacy and land stability issues in advance of development the Council will look to support proposals which raise no significant adverse effects on the locality.”
38. It is noted within the Council’s response to Representation CNQPD12 that the ‘officer recommendation’ in the Council’s record of representations appears to indicate that the LPA may be prepared to incorporate our suggested change in the precise form, but not as a policy only as text. However there is no clarity as to whether this is a firm proposal or not?
The Coal Authority considers that an appropriate policy context should be set out.
Conclusion
39. The changes The Coal Authority has suggested if incorporated will address the unsoundness of the AAP and would ensure that the AAP complies with national planning policy in MPS1, MPG3 and PPG14 and would be in conformity to the Core Strategy. It would also ensure conformity with Policy RE10 of the South West Regional Spatial Strategy which requires mineral resources to be safeguarded from sterilisation.
Anthony Northcote
Dip TP, Dip URP, MA, MInstLM, MCMI, MRTPI
Planning Advisor to The Coal Authority
16 September 2011
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