1 WEST SUSSEX JOINT MINERALS LOCAL PLAN (updated 2017)
This Plan covers the whole of West Sussex so it is drawn up by the County Council and the National Park Authority together. The Plan determines how many aggregates – mainly sand and gravel – will be extracted in the period to 2033 and where they will come from. Sand and gravel are divided into sharp sand and gravel, and soft sand, which includes the specialised mineral silica sand.
The main area where soft sand is found is the National Park and its borders. Sites were considered by the Authority and these included the Wickford Bridge site and the Horncroft site, both said to contain silica sand and both in the National Park. The Government assumption is that minerals extraction won’t take place in National Parks unless there are exceptional circumstances or it is in the public interest. But we live in changing times. At the time of the last Minerals Plan, there was no
inkling that silica sand existed in West Sussex.
Silica sand contains a very high proportion of quartz. It is too rarefied for building. The highest grades
of silica (99%+) are used for manufacturing glass and specialised uses like television screens. Some
lower grades (95%+) are used for golf courses, agriculture and horticulture, children’s playgrounds etc.
This is a growing market. Need is assessed nationally, not on a local basis. Longer planning permissions
are given for silica (10/15 years) than for soft sand sites (7 years).
The Joint Minerals Authority commissioned a report last year on silica and soft sand in the National
Park. It was reluctant to release this until the Plan had been published for consultation. The effect was
that a lot of background papers would have to be considered very quickly, so the Wiggonholt
Association obtained a copy of the sand report under the Environmental Information Regulations. The
report revealed that there was probably a great deal of silica sand in the National Park, and that some of
this could be used to meet a future national shortage of high-grade silica, for which distant markets are
We saw the first version of the Plan when it went to committee last month. The Authority has taken the
position that there will be no new sites for sand extraction within the National Park. It has adopted a
stance of “managed retreat”. It has allocated only one new soft sand site in West Sussex (outside the
Park at Ham Farm near Steyning). Shortages will be made up from neighbouring counties but there are
no details yet. This is an admirable stance. However the Sand Report has found that the main national
sites for highest-grade silica in the rest of the country are on the wane. This means that if there is a
shortage the Park could be called upon to fill it. So the report is a bit of a bombshell. It provides quite a
lot of ammunition for anyone who wants to extract silica sand. Horncroft seems particularly vulnerable
as it appears to have a number of high-quality deposits. Some tests were carried out by the owner’s
expert, and others by an independent operator. There was also a control test on a dormant site nearby.
The Wickford Bridge site is less likely to have high-quality silica, but since the tests were carried out on
molehills they may not be very accurate.
I should add that there will be no new sites allocated for sharp sand and gravel: it will all be marinedredged
and landed on the south coast. This type of aggregate is not much found within the Park. At
the same time there is great pressure from the district councils to turn the ports into marinas and
housing. The long-term effect of port closure would be more land-won aggregate.
National minerals policy is agreed by working parties composed of operators, local authorities and
central government, so West Sussex is to be congratulated on a complete change of attitude to minerals
extraction. But this doesn’t mean that its Plan won’t be challenged. Owners of sites and the operators
are bound to seize on the anomalies between the sand report and the published Plan. These will be
2 thrashed out at Public Examination and then the Inspector will decide. So it is at the very least up to us
to suggest improvements to the Plan which will make it sounder. It’s also a matter of self-interest as we
don’t want the misery that extraction brings with it.
The next two years are going to be interesting. We’ve worked for 20 years to get to this point. First we
kept our own site secure, then we promoted the birth of the National Park. We supported alternative
materials, and always kept a watching brief on the minerals scene. Now is our chance to help the
Minerals Planning Authority make the Plan truly watertight while paying attention to the vulnerable sites
So, the key points are:
• Refusal by the Minerals Authority to allocate further sand sites in the National Park unless they
can be justified by exceptional circumstances or the public interest (a second runway at Gatwick?).
• The Plan contains very few statistics about the figures on which it is based (e.g. expected outputs and
reserves in different sites, annual rates of supply over the last 10 years, rates of marine landings etc). These will
have to come out before the draft Plan can go much further.
• The Sand Report proposes that there will soon be national need for highest-grade silica sand,
regardless of the distance it has to travel.
• Horncroft appears to contain large deposits of this.
• Other samples suggest extensive quantities of lower grade silica sand, but there is less need for
• There appears to be little frac sand in the Park.
• The Wickford Bridge site has not been properly tested. It is a very small site and that produces
its own constraints. But there is always a danger of small operators seeking planning permission
to meet local need for a particular market.
• There is a commitment to sea-dredged aggregate but this requires safeguarding of the traditional
ports, and dredging has its own environmental problems.
The stages are now as follows:
Public consultation 14 April 2016 for eight weeks
Approval of Proposed Submission Plan October 2016
Soundness consultation Nov 2016 – Jan 2017
Submission to Government March 2017
PUBLIC EXAMINATION June 2017
Approval of any changes September 2017
Soundness consultation Oct-Nov 2017
INSPECTOR’S REPORT February 2018
Adoption March 2018
Janet Aidin, The Wiggonholt Association ©
JOINT WEST SUSSEX MINERALS LOCAL PLAN (updated 18.8.2015)
The draft policies of the Plan were issued for consultation in May 2014, followed in August by the draft sites which were being considered by the Minerals Planning Authority (MPA) which consists of West Sussex County Council and the South Downs National Park Authority. This revealed that the MPA was considering silica sand (a specialised and valuable form of soft sand) within its targeted figure for soft sand. (The two are often distinguished as ‘industrial’ and ‘building’ sand.) The Plan also makes provision for ‘sharp’ or concreting sand, and gravel, in one separate category. There are thus two categories of aggregate: Soft Sand, and Sharp Sand/Gravel. These categories are dealt with quite separately in the Plan and an abundance of one type cannot be used to compensate for a shortage of the other.
A report on the Sites Consultation was issued by the MPA in the spring of 2015. The two local silica sites, Wickford Bridge (Pulborough) and Horncroft (Bury) have not been withdrawn. The next stage has been to filter all sites in the South Downs National Park through a Sustainability Appraisal. This evaluates specific features of all sites, such as landscape quality. These two sites are both in the Park.
The MPA originally expected to publish a series of updates on the appraisals and it also wrote of consulting local communities which would be directly affected by proposed sites, such as Pulborough. (All sites affect people to some extent, but the Wickford Bridge site is adjacent to a high density of housing on the outskirts of Pulborough, at Mare Hill and in the approaches to Nutbourne and West Chiltington. The Wiggonholt Association has twice written to the MPA requesting such a consultation.
The MPA has also undertaken a Soft Sand Study, which would evaluate the amounts of soft sand in West Sussex and no doubt identify and distinguish between ‘industrial’ and ‘building’ sand (see above). The conclusions of this document are much anticipated as they will determine the amounts which the MPA must provide for in its Plan. They will also shed light on other areas of silica sand. (Silica sand was previously unknown in West Sussex and it has a higher value than building sand.)
In July, the MPA revealed that it had decided not to give out any more information to “stakeholders” (those affected by, or with an interest in, minerals extraction). All must now await the draft Minerals Plan itself, when special studies (such as the Soft Sand Study), amended policies, and the short list of sand sites will all be revealed at a blow. At this stage evaluations of each site will be published and it will be either “in” or “out” of a short list. This is likely to happen at the beginning of 2016, and the information will come in a flood. There will then be a formal consultation, probably lasting six weeks. But even if a site is “out” of the shortlist, the industry – and anyone else with an interest – will have the opportunity to challenge its exclusion before and during the public hearing on the Plan (the Examination-in-Public) which will be held by a Government inspector, probably later next year.
The Wiggonholt Association is considering what action might be taken to persuade the MPA to release some of its background papers ahead of the Draft Plan as it believes that publication as a flood would put non-professional stakeholders at a great disadvantage.