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Annex 2

Report to Hampshire County Council, New Forest National Park Authority, Portsmouth City Council & Southampton City Council

The Planning Inspectorate Room 3/25 Hawk Wing Temple Quay House 2 The Square Temple Quay Bristol BS1 6PN

0117 372 8128 e-mail: [email protected]

by Stephen J Pratt BA(Hons) MRTPI

an Inspector appointed by the Secretary of State for Communities and Local Government

29 May 2007

PLANNING & COMPULSORY PURCHASE ACT 2004

(SECTION 20)

REPORT ON THE EXAMINATION INTO THE

HAMPSHIRE MINERALS & WASTE CORE STRATEGY

DEVELOPMENT PLAN DOCUMENT

Documents submitted for Examination on 31 May & 23 October 2006 Examination hearings held on 23 January-2 February & 29 March 2007

mailto:[email protected]

ABBREVIATIONS

AA Appropriate Assessment under the Habitats Regulations ABP Associated British Ports AMR Annual Monitoring Report AONB Area of Outstanding Natural Beauty APCR Air Pollution Control Residues ARF Aggregate Recycling Facility CC County Council DC District Council DPD Development Plan Document EIA Environmental Impact Assessment EIP Examination in Public GO-SE Government Office for the South-East GO-SW Government Office for the South-West GPZ Groundwater Source Protection Zone HCC Hampshire County Council HMWCS Hampshire Minerals & Waste Core Strategy LDF Local Development Framework LDS Local Development Scheme LPA Landfill Potential Area LTP Local Transport Plan M&WDF Minerals & Waste Development Framework M&WLP Hampshire, Portsmouth & Southampton Minerals & Waste Local Plan MOD Ministry of Defence MPA Minerals Planning Authority MPS Minerals Policy Statement MRA Mineral Resource Area mt million tonnes mtpa million tonnes per annum MWPA Minerals & Waste Planning Authorities (Hampshire County Council, New Forest National Park Authority, Portsmouth City Council & Southampton City Council) NE North-East NFNP New Forest National Park NFNPA New Forest National Park Authority OS Ordnance Survey ¶ paragraph PPC Pollution Prevention & Control PPS Planning Policy Statement RPG Regional Planning Guidance RSS Regional Spatial Strategy SA Sustainability Appraisal SAC Special Areas of Conservation SCI Statement of Community Involvement SDNP South Downs National Park SEERA South-East England Regional Assembly SEERAWP South-East England Regional Aggregates Working Party SEP South-East Plan SERTAB South-East Regional Technical Advisory Body for Waste SPA Special Protection Area SPD Supplementary Planning Document SSSI Site of Special Scientific Interest SW South-West SWP South-West Plan SWRA South-West Regional Assembly tpa tonnes per annum WPA Waste Planning Authority

Hampshire Minerals & Waste Core Strategy Development Plan Document Inspector’s Report on the Examination under Section 20 of the 2004 Act

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Introduction

1. Under the terms of Section 20(5) of the Planning & Compulsory Purchase Act 2004, the purpose of the independent examination of a development plan document (DPD) is to determine:

a. whether it satisfies the requirements of s19 & s24(1) of the 2004 Act, the regulations under s17(7), and any regulations under s36 relating to the preparation of the document;

b. whether it is sound. 2. This report contains my assessment of the Hampshire Minerals & Waste Core Strategy (HMWCS) on the above matters, along with my recommendations and the reasons for them, as required by section 20(7) of the 2004 Act. 3. My role is to consider the soundness of the submitted HMWCS against the tests of soundness set out in PPS12 (¶ 4.24). My report firstly assesses this DPD against the procedural and conformity tests, and then deals with the key planning issues considered during the Examination in terms of the soundness tests of coherence, consistency and effectiveness. My overall conclusion is that this DPD is sound, provided it is changed in the ways specified. The annexes to my report set out the detailed changes required to ensure that the plan meets all the tests of soundness, including those suggested by the MWPA [HCD20/21]. References to documents in the core evidence base and Core Documents list are shown thus [ ]. All references to the MWPA cover the partner Minerals & Waste Planning Authorities for Hampshire County Council, New Forest National Park Authority and Portsmouth & Southampton City Councils. 4. There are two elements of the HMWCS. The first DPD to be submitted relates to the area covered by Hampshire County Council (HCC), including most of the New Forest National Park (NFNP) within its boundary [CCD64]. The second element of the DPD covers the small part of the NFNP within Wiltshire [CCD75]. This part of the DPD was subject to a shortened preparation and consultation process, begun in April 2006, when the National Park Authority (NFNPA) took up its planning responsibilities. The strategy and policies are identical for both areas. I distinguish the two elements of the HMWCS only where it is necessary in my assessment of soundness. 5. The MWPA have submitted a wide range of evidence to support and justify the policies and content of this DPD. In addition to the accompanying Technical Document [CCD66], Topic Papers [TP1-TP5] and Examination statements outline the MWPAs’ broad case on each topic, explain how the policies and approach of this DPD are derived through earlier consultation with the community and stakeholders, how it reflects local issues, priorities and key characteristics of the area, consistency with national and regional policies, and relationship to the sustainability appraisal and Statements of Community Involvement. Self-Assessments of Soundness have also been undertaken [CCD62/CCD95]. 6. The MWPA submitted several suggested changes to the HMWCS (including the Key Diagram) shortly before the hearings commenced, in order to address valid points made in the representations [HCD20]. Following discussions at the hearing sessions, further suggested changes were submitted to clarify various aspects of the DPD, including amendments to the wording of the policies and accompanying text [HCD21]. These are “suggested” rather than “formally proposed” changes, with the intention of assisting me where minor changes might be necessary to make the Strategy sound. The MWPA believe that none of these suggested changes undermine the substance of the Strategy or the sustainability appraisal already undertaken, and would not prejudice the participatory processes previously carried out. All representors were informed of both sets of changes, which were also published on HCC’s web-site. Although representations were not specifically invited, I have taken into account any comments made by representors, both at the hearings and in writing.


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7. In accordance with national policy, this DPD is presumed to be sound unless it is shown to be otherwise by evidence considered during the Examination (PPS12; ¶ 4.24). Normally, I would not expect to recommend so many changes to a submitted DPD. However, in this case, the MWPA clearly recognised that some parts of the Strategy need further clarification to avoid any misinterpretation or misunderstanding of the application of the policies and the relationship of the Strategy to subsequent DPDs. None of my recommended changes materially alter the substance of the overall plan and its policies, or undermine the sustainability appraisal and participatory processes already undertaken. The detailed changes required are set out in Annexes A-C of my report. 8. The main changes required to make this DPD sound include amendments:

• to deal with the incorporation of the Wiltshire area of the New Forest National Park into the Strategy; • to ensure that the Strategy is consistent with the latest national policy guidance in MPS1 & PPS25; • to the policies and accompanying text to deal with the issue of accommodating a declining proportion of London’s waste; • to the policies and accompanying text relating to sand and gravel, including maintenance of a 7-year landbank and the approach to making provision for post-2016 requirements; • to deal with the approach to aggregate recycling facilities; • to clarify and elaborate the application and operation of various policies, the relationship to, and role of subsequent DPDs, and the definitions of various designated areas.

9. This is the first Minerals & Waste Core Strategy to have reached this stage under the provisions of the 2004 Act. The MWPA have had to interpret the legislation and initial national and other advice published during the preparation of this DPD. With more recent and emerging guidance, it might look somewhat different to the submitted version. Consequently, this Core Strategy should not be seen as a template for others to follow, but rather as part of the evolutionary process of interpreting the 2004 Act. 10. The submitted DPD does have some shortcomings, but with the various amendments suggested and recommended, I am satisfied that it meets the tests of soundness and provides a sound basis for preparing subsequent DPDs, which will determine in more detail where minerals and waste management facilities are to be located. In making my binding recommendations, I have sought to achieve an efficient and pragmatic way of delivering the aims of the new LDF system, whilst ensuring that the final document is sound and avoiding any unnecessary delay.


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Procedural and conformity tests

Procedural tests

Test 1 - Consistency with the Local Development Scheme

1.1 The HMWCS is included within the approved LDSs for Hampshire, NFNPA, Portsmouth & Southampton [CCD48/49/58/76A]. It reflects the intentions, content and timescale of the latest LDSs, and is one of the first DPDs in the MWPAs’ M&WDFs/LDFs. The subsequent Hampshire Minerals Plan and Hampshire Waste Management Plan DPDs will cover detailed site and area allocations. Future changes in the LDSs will update the position and timetable for preparing these subsequent DPDs.

1.2 At the time of submission, GO-SE/GO-SW pointed out that since NFNPA’s LDS had not been adopted and there was no reference to the incorporation of the Wiltshire area of the New Forest into the HMWCS in HCC’s LDS, this element of the DPD was unsound. However, NFNPA’s LDS was formally submitted to GO-SE in January 2007 and came into effect on 23 February 2007 [CCD76A]. The description of this DPD in this LDS is the same as in HCC’s LDS, and includes details of the consultation arrangements and timescale. The original shortcoming has thus been resolved and I can see no public disbenefit in preparing and consulting on this element of the DPD before a LDS was formally in place. Consequently, there is no procedural reason to prevent this element of the DPD from proceeding.

1.3 Since the preparation of this Core Strategy is consistent with the latest LDSs, this soundness test has been met.

Test 2 - Compliance with the Statement of Community Involvement and associated Regulations

2.1 During the preparation of the main HMWCS, the Statements of Community Involvement (SCI) for the constituent authorities were being prepared, and were adopted during 2006 [TP3/CCD63/69/71]. The preparation of the DPD took account of these emerging SCIs and reflected the process of community involvement set out in them and in the 2004 Regulations. The statements submitted outline the process of consultation at each stage, including consultation and stakeholder meetings held in connection with the Materials Resources Strategy, leading to the key document setting the context for the HMWCS: More From Less [CCD40]. The MWPA also followed the procedures leading up to the Examination under Regulations 25-31, including a Regulation 31 statement [CCD65], and advertising and notifying parties of the opening of the hearings of the Examination, as required by Regulation 34.

2.2 The consultation arrangements for the Wiltshire area of the New Forest are set out in the core evidence [TP5]. NFNPA’s SCI was submitted in October 2006 [CCD77] and was formally adopted on 28 March 2007 [CCD97]. NFNPA confirms that the consultation process on the Wiltshire element was largely undertaken in line with the relevant Regulations, taking full account of the emerging SCI. All households in the area were informed at the initial stage and those responding were consulted at the later stages. All documents were also advertised, made available for inspection and published on NFNPA’s web-site. This represented consultation in excess of the minimum required by the 2004 Regulations. The Consultation Statement [CCD93] confirms that all issues and comments raised by consultees and local residents were considered, and I cannot see that anyone was prejudiced by the nature or timescale of the consultation process. Although the process was streamlined over a shorter period, I am satisfied that all the necessary consultation was undertaken for this element of the DPD, in accordance with the relevant Regulations.


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2.3 There is some concern that not all sections of the community were involved in the plan-preparation process, including those who may be “hard-to-reach”, citing people in the Bickton area. However, the MWPA confirm that all the relevant bodies in the area (including District & Parish Councils, local residents groups and local councillors) were consulted during the preparation of this DPD, in line with the draft SCI, a reasonably high proportion of local residents were aware of the procedure, and the process was advertised in the local press. Although public meetings were not thought appropriate at this strategic level, they will be held at the site allocation stage as part of the consultation process for subsequent DPDs. Similar points apply in the New Milton/Highcliffe area, where local residents will be fully involved at the site selection stage.

2.4 It is important to strike a reasonable balance in the degree of public consultation, tailored to fit the issues being discussed. Having examined the details of the MWPA’s consultation process, I am satisfied that the level and nature of consultation and participation was appropriate for this strategic DPD and that the minimum requirements of the Regulations have been met. Consequently, this soundness test has been met.

Test 3 - Sustainability Appraisal

3.1 The MWPA undertook an Integrated Sustainability Appraisal as an integral and iterative part of preparing the HMWCS. This included an initial Scoping Report [CCD42], appraisal of Options and selection of Preferred Options in an Interim Sustainability Report [CCD44], and an appraisal of the Strategy in a Final Sustainability Report [CCD60]. The wording of some of the submitted policies does not fully reflect the conclusions of the Final Sustainability Report, which recommends a “catch-all” clause covering social, economic and environmental impacts. However, this is unnecessary, since most matters are already covered by the environmental policies and the DPD confirms that the plan and its policies need to be read as a whole (¶ 25.1).

3.2 Much of this SA work was carried out before the final version of national guidance was available, but in line with the guidance available at the time and in the spirit of later guidance. The SA framework is also consistent with the “five guiding principles” in the latest national sustainability strategy (“Securing the Future”) [NCD40]. It properly identifies the process carried out, the baseline information and outcomes, responds to the spatial vision and objectives, and assesses all the various options considered and the implications of the preferred strategy, along with the changes to the policies. It also provided a strategic input into the preparation of this DPD and addressed some of the key sustainability issues and challenges in the area. There are no serious challenges to the adequacy or content of the SA already undertaken.

3.3 A similar process of Integrated Sustainability Appraisal was undertaken for the incorporation of the Wiltshire area of the NFNP into the HMWCS. This included a Scoping Report and Final Sustainability Appraisal Report [CCD94], which assessed whether there were any factors that would justify a different conclusion to those already derived for the main area of the Strategy. It tested specific and generic options, and concluded that the HMWCS recognises the environmental characteristics of the whole of the NFNP and would have no significant effect on this part of the NFNP if the policies operate effectively. Consequently, I am satisfied that the process and methodology were consistent with that undertaken for the main element of the HMWCS and provide a coherent and compatible approach for this aspect of the SA.


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3.4 The requirement to undertake an Appropriate Assessment of plans under the Conservation (Natural Habitats, &C.) Regulations 1994 is an important element of SA, which became apparent during the preparation of this DPD. The MWPA undertook an initial assessment [CCD66; Appx 4], which concluded that the plan would be unlikely to have a significant effect on protected European sites because of the Strategy’s approach to development and the application of Policy DC2 which safeguards internationally designated sites. A further assessment, undertaken in November 2006 came to similar conclusions [CCD81]. A more thorough assessment will be undertaken at the site-selection stage in subsequent DPDs, including the effect on protected sites within and adjoining the NFNP in Hampshire & Wiltshire, in line with Natural England’s views.

3.5 The HMWCS does not itself make any site-specific proposals for minerals and waste developments, and the Mineral Resource Areas & Landfill Potential Areas specifically exclude European SAC/SPA sites. The Safeguarded Sand & Gravel Deposits and Strategic Waste Facilities areas of search might include such sites, but they would be protected from incompatible development by Policy DC2. Any adverse impact on protected species is covered under other legislation, addressed by Policy DC7, and will be dealt with at the site-specific stage. Consequently, I am satisfied that this approach is appropriate, particularly given the specific protection afforded by Policy DC2.

3.6 Although a separate AA was not undertaken for the Wiltshire area of the NFNP, as an area immediately adjoining the main part of the HMWCS, this is effectively covered in the assessment carried out for the lead Strategy. Since the character and policies applying to this part of the NFNP are similar to those of the rest of the NFNP, I cannot see that the HMWCS would have any significant impact on the protected area provided that the relevant policies are applied consistently.

3.7 Having examined the sequence of events and process of undertaking SA of the Strategy during its preparation, I am satisfied that its development has been informed by the ongoing sustainability appraisal process and the procedure meets the legislative requirements and the spirit of national guidance. I therefore conclude that the plan and its policies have been properly subjected to sustainability appraisal and this soundness test has been met.

Conformity tests

Test 4a - Spatial plan

4.1 The key principles of spatial planning are set out in PPS1 (¶ 30-32) & PPS12 (¶ 1.8-1.11). The HMWCS contains a spatial vision at the beginning of the DPD, describing Hampshire at the end of the plan period in terms of minerals and waste management. It confirms that the Strategy is a vital part of achieving this vision and that the changes required go beyond physical land-use decisions. This DPD has several spatial elements, which recognise separate geographical areas, including discrete market areas for minerals and designated areas and “areas of search” for minerals and waste development. Many of the policies provide a spatial dimension, including the potential for locating facilities close to markets and waste sources.

4.2 The strategic objectives address minerals and waste management, but extend wider than land-use issues, covering social, economic and environmental matters. The Strategy also takes account of community needs, reflecting the participative process of community engagement and involvement of stakeholders. The means of deliverability are set out in the Implementation Plan (Appx 4). Although the time-period of this DPD covers a period shorter than that of the emerging RSS, it looks forward to 2026 and would cover some 13 years from the likely adoption date, consistent with the guidance in PPS12. The MWPA are also committed to reviewing the DPD within 5 years of its adoption.


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4.3 The preparation of this DPD has taken account of other relevant strategies, including the national review of the Waste Strategy 2000 and the emerging Regional Spatial Strategy. SEERA confirms that the DPD implements the spatial elements of the RSS. At local level, the DPD has taken account of the Material Resources Strategy, Joint Municipal Waste Management Strategy, various Local Transport Plans and Community Strategies in Hampshire & Wiltshire. In most cases, the DPD makes it clear how it relates to these other plans and strategies, with some flexibility to accommodate changing circumstances. The MWPA’s suggested changes clarify the relationship between the HMWCS and subsequent DPDs, which I deal with under Soundness Test 7.

4.4 Several key policies in the HMWCS will help to influence the district councils’ policy stance on issues such as sustainable design/construction and resource management. District & County Councils within and adjoining the area have been consulted throughout the plan-making process and their views have been taken into account. Apart from the need to safeguard mineral reserves from incompatible development, there are few areas that overlap with the district councils’ planning roles. The detailed boundaries of Mineral Consultation Areas and other designated “areas of search” will be included on the Proposals Maps of subsequent DPDs. The infrastructure investment programmes and views of other agencies and service providers have also been taken into account.

4.5 Consequently, I conclude that the HMWCS is a spatial plan which has properly had regard to other relevant plans, policies and strategies within and adjoining its area, and this soundness test can be met.

Test 4b - Consistency with national planning policies

4.6 The key national planning policies include the latest version of MPS1 & PPS10, along with the accompanying Practice & Companion Guides. New PPS25, PPS7 & PPS9 are also relevant, along with the National & Regional Guidelines for Aggregates Provision (June 2003). However, the introductory section of the HMWCS (¶ 5.1) should be updated to reflect the current situation.

4.7 I am satisfied that the HMWCS is broadly consistent with the thrust of national policy as it existed when it was prepared. However, new MPS1 & PPS25 were published at the end of the plan-preparation period and were not specifically covered in the MWPA’s Self-Assessment of Soundness. The MWPA suggest some changes to the policies, text and Key Diagram to bring the HMWCS into line with the guidance in new PPS25, which I deal with under the relevant policies, later in my report. At the hearings, the MWPA considered the HMWCS is consistent with new MPS1, but in assessing its soundness, I consider some further amendments are necessary. I deal with these matters under Soundness Test 7.

4.8 There are some elements of the HMWCS that are not fully consistent with national policy. In some cases (such as development in the NFNP), it is more restrictive, whilst in other cases (such as waste/recycling targets), it aims to improve on national policy. GO-SE has indicated that issues such as not making provision to accommodate some of London’s waste, the policy for development in the NFNP, and the approach to Local Development Orders, are not consistent with national policy. The MWPA suggest some amendments to deal with these and other points, which I cover under Soundness Test 7. With these exceptions, I consider the HMWCS is generally consistent with national policy.

Recommendation 1

In order to make the Strategy sound, paragraph 5.1 should be amended to reflect the latest position in terms of national planning policy guidance (Change No. 3 in Annex A to my report).


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Test 4c - Conformity with the Regional Spatial Strategy

4.9 Section 24(1) of the 2004 Act requires the DPD to be in general conformity with the RSS. The current RSS is RPG9 (June 2006), which sets out the regional minerals and waste strategy. Since it was only approved last year, it has considerable weight. A complete review of RPG9 is now being undertaken (the South-East Plan (SEP)), and the EIP has recently concluded. The Panel Report is expected in July 2007, with Proposed Modifications in September 2007 and final approval in Spring 2008. PPS12 (¶ 4.19) confirms that “considerable weight” can be given to a draft RSS only when the EIP has been completed and Proposed Modifications have been published. In this case, most of the minerals and waste policies are unchanged from the June 2006 version, but some new elements (such as a detailed apportionment of provision for accommodating London’s waste) are included and have been challenged. Consequently, although these elements of the draft RSS are part of the policy context within which the HMWCS has been prepared and will be implemented, they can have only limited weight. Policies in the existing County Structure Plans and adopted Minerals & Waste Local Plans are “saved” until September 2007.

4.10 Since the final version of draft RSS was not published until towards the end of the preparation of the HMWCS, this DPD has its foundations in the approved RPG9 (June 2006), rather than the emerging draft RSS. The MWPA confirm that they do not wish to delay the adoption of the HMWCS until the draft RSS is finalised. Their preference is to undertake an early review of the DPD when the latest RSS is approved, and take on board any revised/detailed apportionment figures at that time. I consider this should be made clear in the introductory section of the DPD, confirming that an early review of the HMWCS will be undertaken if it is no longer in general conformity with the RSS as approved.

4.11 At submission stage, SEERA considered the HMWCS was not in general conformity with the RSS since it does not make provision for the disposal to landfill of a proportion of London’s waste, as required by Policy W3 of RPG9 (June 2006). SEERA has offered to withdraw its objection if changes are made to the HMWCS to reflect the aims of RPG9 Policy W3, and agreed changes have been set out in the MWPA’s suggested changes. I deal with this key issue of conformity under Soundness Test 7, later in my report. Apart from this issue, the HMWCS is in general conformity with the approved and emerging RSS. SEERA and others raise points about the conformity of other aspects of the DPD with approved and emerging RSS, including landfill and specialist facilities. However, these do not undermine its general conformity with the approved RSS, and I return to these matters under Soundness Test 7.

4.12 SWRA has confirmed that the Core Strategy as it applies to the Wiltshire area of the NFNP is in general conformity with approved RPG10 and the emerging RSS for the South-West (SWP). SWRA raises some concerns about Policy S7, but these do not affect the general conformity of this element of the DPD, and I deal with these matters under Soundness Test 7.

4.13 Apart from the issue of making provision for London’s waste and the other areas of potential inconsistency which I deal with later, and with an amendment to confirm the need for an early review of the DPD, I consider the HMWCS is in general conformity with the approved and emerging RSS.

Recommendation 2 In order to make the Strategy sound, additional text should be added to paragraph 6.4 to confirm that an early review of the DPD will be undertaken if it is no longer in general conformity with the emerging RSS as finally approved (Change No. 4 in Annex A of my report).


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Test 5 - Community Strategy

5.1 Several Community Strategies are relevant to this DPD, including those for Hampshire, Southampton & Portsmouth [LCD01-03], details of which are outlined in the core evidence [CCD66/TP3]. Key themes include protecting and enhancing the environment; supporting the economy; preparing for global warming; reducing the causes of environmental change and damage; minimising waste production; maximising recycling, re-use and composting; disposing of waste sustainably; improving urban design; and combating fly-tipping. Most of these issues and aspirations are reflected in this DPD and all the Local Strategic Partnerships were consulted at all stages during the plan-preparation period.

5.2 NFNPA is not required to prepare a Community Strategy itself, and that prepared by New Forest DC is covered by HCC’s Community Strategy. In terms of the Wiltshire part of the NFNP, the HMWCS has taken into account key themes in the Community Strategies for Wiltshire and Salisbury & South Wiltshire. These include increased use of renewable energy; minimising waste; increasing re-use and recycling targets; restoring mineral sites; and reducing the impact of traffic.

5.3 Since this DPD addresses relevant key themes in the Community Strategies and helps to deliver key elements of these strategies, I conclude that the Core Strategy meets this soundness test.

Coherence, Consistency and Effectiveness tests

Test 6 - Consistency within and between DPDs

6.1 This is the first DPD to be prepared by the MWPA, so consistency and coherence between it and subsequent DPDs can only be tested when other DPDs are prepared. However, the submitted DPD is internally consistent and provides a sound approach to spatial planning, seeking to balance conflicting issues and securing a sustainable future for Hampshire in terms of minerals and waste management. The Spatial Strategy Policies S1-S18 help to achieve the strategic objectives set out in Section 11 of the HMWCS, whilst the objectives of the policies are consistent within the DPD. In general terms, this DPD provides a coherent and consistent framework, which reflects identified social, economic and environmental issues in terms of minerals and waste management matters relevant to Hampshire & the New Forest, and provides a sound basis for preparing subsequent DPDs. I deal with detailed aspects of internal consistency under Soundness Test 7.

6.2 The HMWCS broadly reflects regional work and policies on the apportionment of minerals and waste, and helps to provide an integrated approach with other relevant minerals and waste planning documents in the South-East of England. Being prepared jointly by HCC, NFNPA and Portsmouth & Southampton City Councils, it provides an integrated and consistent approach across Hampshire & the NFNP. The more recent incorporation of the Wiltshire area of the NFNP into the HMWCS ensures a consistent approach across the whole of the National Park. No overlaps with the plans and strategies of other planning authorities have been identified and there are no obvious gaps or omissions in coverage of minerals and waste management issues.

6.3 The HMWCS is one of the first of the new Minerals & Waste DPDs to be submitted in this region, but the neighbouring authorities have been consulted during its preparation and their views have been taken into account. As for cross-boundary issues, I deal with the question of accommodating a declining proportion of London’s waste and the impact on highways and transport outside Hampshire later in my report. The MWPA work closely with Dorset CC on minerals and transport issues in the NFNP, particularly given the demand for sand


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and gravel in East Dorset and the environmental constraints in that area. There is also a close working relationship with Wiltshire CC on minerals and waste issues, including cross-boundary movement of minerals, waste and traffic. Information on the import/export of waste to and from Hampshire is included in the core evidence base [CD66]. The HMWCS notes that Hampshire contains some specialist facilities of national significance for dealing with specialist treatment of imported waste, and also confirms that some minerals (marine-dredged and crushed rock) are imported from the English Channel and from other parts of the UK. I return to these aspects under Soundness Test 7.

6.4 I am therefore satisfied that the Core Strategy meets this soundness test.

Test 7 - Appropriate strategies and policies

7.1 Most of the remaining issues concerning the soundness of this DPD can be considered under this heading. They include the key planning issues identified for the Examination, covering the Spatial Strategy, Sustainability and Resource Efficiency, Waste Growth & Demand for Natural Resources, Self-Sufficiency (including provision for London’s waste), Recycling & Composting, Landfill & Specialist Facilities, Minerals (including sand and gravel, recycled/secondary aggregates, wharves and depots, safeguarding and sterilisation of reserves), Site Selection, Development Control policies, specific areas (including Bordon and Walkford Farm/Roeshot), Key Diagram, and issues arising from the incorporation of the Wiltshire area of the New Forest National Park into the Strategy.

Spatial Strategy

Key issue - Is the Spatial Strategy soundly based and appropriate for Hampshire & the New Forest?

7.2 I have already concluded that the Strategy is generally consistent with national and regional policy, apart from detailed aspects which I deal with later in my report. Section 4 of the HMWCS sets out key minerals and waste issues in terms of Hampshire & the NFNP, including population and economic growth, the countryside, heavy goods traffic, environmental designations, climate change, permitted reserves of sand and gravel, aggregate wharves, current landfill capacity, export of waste outside Hampshire and the need to optimise waste management systems. These issues reflect the Material Resources Strategy, and are specifically addressed in the HMWCS.

7.3 A wide range of alternative options and strategies was considered during the plan-preparation stage, both in consultation with the public and stakeholders and in the SA. Specific and generic options were tested to ensure that they would not be compromised by changing circumstances, and all reasonable options suggested as a result of consultation were considered and assessed by the SA.

7.4 There is some concern that the consultation for the Wiltshire area of the NFNP may not have identified and considered all realistic options for this area. However, the options for mineral and waste policy in this relatively small area are somewhat limited, given the statutory framework and tight planning constraints that apply to development within National Parks. The area is similar in character to the rest of the NFNP and justifies a consistent approach across the National Park. The same options as for the main Strategy were put before residents and stakeholders in this area, no new issues or options were raised that had not been previously considered in the main HMWCS, and all the points made were fully considered. Given the similarity in character and policy to the rest of the NFNP, I can see no need to develop alternative or hypothetical options specific to this area at the Issues/Preferred Options stages. I am therefore satisfied that all relevant options for the Wiltshire area of the NFNP were properly considered and addressed.


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7.5 The spatial vision is clearly set out in the introduction to this DPD, and evolved from work on the Material Resources Strategy and consultation responses. In my view, the spatial vision is realistic, yet challenging, provides a sound basis for the spatial strategy, and is followed through into the various policies, including Core Policies S1-S8 comprising the Spatial Strategy itself.

7.6 The strategy objectives directly relate to the spatial vision and spatial strategy. There is some criticism about the detailed wording of some of the objectives, but I am satisfied they are sound. There is some concern that more consideration should be given to transport issues in a specific objective, but this is implicit within Objectives (i), (v) & (x). Moreover, the principles of limiting transport impact in the criteria for locating facilities, encouraging sustainable transport and considering transport impact are embedded in the overall strategy and policies, including the site-selection criteria in Appendix 2. Mineral Resource Areas are related to the proximity of Mineral & Waste Lorry Routes, and the area of search for Strategic Waste Facilities is based on the proximity to waste generation.

7.7 However, there is a need to emphasise the importance of transport-related concerns, particularly cross-border movements, and I endorse the additional text (¶ 10.1 & 10.4) suggested by the MWPA. Objectives to educate and encourage waste reduction and a change in building standards are not required, since they are covered in the Implementation Plan (under Policies S1 & S2 in Appendix 4). Locally designated sites are covered under Objective (x).

7.8 The MWPA suggest several other minor amendments and additions to the text of the introductory section of the HMWCS. In most cases, these clarify, correct or update various parts of the introductory text, and are not contentious. Of particular importance are the additions which give more details about the subsequent DPDs and the Proposals Map, which assist in the understanding of the MWPAs’ M&WLDF and the relationship with the district councils’ LDFs (¶ 13.1 & 13.2). Another significant addition gives further explanation about the operation of the HMWCS and its policies, including various designated areas and “areas of search”, in a new introduction to the Spatial Strategy section (¶ 14.0-14.3). In my view, these additions provide essential text to understand the operation of the HMWCS and the application of its policies, and ensure that it is sound.

7.9 Consequently, I conclude that the Spatial Strategy is soundly based and appropriate for this area, consistent with national and regional policy, reflecting community views, and providing a sound basis for the spatial policies in the Core Strategy. With the suggested amendments, this soundness test will be met.

Recommendation 3 In order to make the Strategy sound, the following amendments are required: (a) additional text should be added to paragraphs 10.1 & 10.4 to recognise the importance of transport concerns, including cross-boundary implications, when considering the location of future minerals and waste sites; (b) additional text should be added to paragraphs 13.1 & 13.2 of the DPD, along with a new Introduction to the Spatial Strategy (paragraphs 14.0-14.3), giving further details about subsequent DPDs, the relationship with District Councils’ LDFs and the operation of the Strategy and application of its policies; (Change Nos. 5-8 & 10 in Annex A of my report).


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Sustainability and Resource Efficiency

Key issue - Will the Strategy facilitate the sustainable and efficient use of resources?

7.10 Policy S1 makes a bold statement, reflecting the aspirations and direction of national and regional policy, and demonstrates the need for an effective approach to resource management. It seeks a change in behaviour, helping to deliver a resource management approach integral to the spatial vision, and gives a strong steer to sustainable construction. It directly complements the spatial vision and provides specific requirements and criteria against which new development will be assessed. This will influence development over the whole area, as well as detailed policies on sustainable design at district level, and also complements RPG9 (Policies W2 & M1). Rather than merely being a vision, I am satisfied that it should form a key policy relating to all development at the outset of this DPD.

Waste growth and demand for natural resources

Key issue - Will the Strategy ensure that the growth in waste and demand for natural resources is reduced?

7.11 Policy S2 sets targets, with figures and forecasts for waste and aggregate production in the accompanying text, which directly reflect those in Policies W1 & M1 of RPG9. In fact, it provides a more targeted and stronger approach than the RPG9 policies, with the headline figures of waste provision and aggregate consumption being stabilised at 2025 & 2016 levels respectively, consistent with RPG9. Supplementary evidence confirms that the estimates have a sound basis [HCD10]. Listing the target percentages for waste reduction in the figures might assist monitoring, but these will be set out in the Annual Monitoring Report (AMR), and could lead to unnecessary confusion. Policy S2 also reflects stakeholders’ aspirations to reduce demand for aggregates by doubling the supply of recycled/secondary aggregates and reducing the production of waste.

7.12 Although the planning system is only one of the main agents of change or influence, it has an important role to play in ensuring the reduction of waste and use of aggregates. Policy S2 provides a strong influence on waste production and aggregate consumption, providing the overall framework for this element of the planning system, as highlighted in the Implementation Plan (Appx 4). The MWPA have a direct role to play, with HCC influencing waste management through the Joint Municipal Waste Management Strategy and its links with Project Integra and the main waste operators, and promoting the use of recycled aggregate in road maintenance. In my view, Policy S2 provides a sound basis for future minerals and waste planning in Hampshire & the NFNP, and is legitimately included as a policy, rather than as a broad aspiration. It can be monitored through the AMR, and if the targets in Policy S2 are not being met, the AMR can consider what measures are needed to reduce waste production and aggregate demand.

7.13 The Strategy addresses the provision of waste handling capacity and waste management facilities through an advanced waste management system, setting the context and direction of travel for the future, with illustrative capacity requirements, and outlining some of the facilities that will be needed. Matters such as population and household growth are addressed at regional level, and the DPD has taken these points on board. However, the future increase in households is not likely to significantly increase the overall production of waste, since household waste accounts for only a small proportion of total waste generated. There also seems to be no direct link between the level of new house-building and local aggregates production.


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7.14 Although population and economic growth may put pressure on land around existing areas of development and increase competition for sites needed for minerals and waste facilities, there is enough flexibility in the Strategy to accommodate anticipated changes. Regular monitoring by the AMR will ensure that changes in waste production and aggregates consumption can be addressed. The DPD (¶ 15.5) will also accommodate future sub-regional apportionment for aggregates when more up-to-date figures are published, with Policy S8 providing the headline figure for aggregate production, in line with the sub-regional figures.

7.15 There is some concern that Policy S2 may not include all the relevant waste streams and types of minerals. The MWPA confirm that the policy only applies to solid waste, and later suggests that this is amended to controlled waste [HCD20], which is a more appropriate and accurate definition. Construction, demolition and excavation waste is not covered, nor is waste water, consistent with national guidance in PPS10 & RPG9.

7.16 I therefore conclude that Policy S2 will help to stabilise the rate of growth in waste and reduce the consumption of primary aggregates. Apart from the suggested minor change to the policy, no further changes are needed to ensure that this element of the Strategy is sound.

Recommendation 4 In order to make the Strategy sound, Policy S2 should be amended by referring to controlled waste in the opening sentence (Change No.11 in Annex A of my report). Self-Sufficiency

Key issues - Will the Strategy ensure that Hampshire achieves self-sufficiency in waste management capacity and disposal, and should it make provision to accommodate a declining amount of London’s waste?

7.17 The aim of achieving self-sufficiency in waste management capacity set out in Policy S3 directly reflects specific objectives in the HMWCS, as well as national/ regional policy in PPS10 & RPG9 (Policy W4). Both RPG9 and the emerging SEP require WPAs to plan for net self-sufficiency in waste management capacity by providing infrastructure to cope with the amount of waste arising and requiring management within their boundaries. The HMWCS follows this approach, although Hampshire is unlikely to reach self-sufficiency until 2016 given the need to reverse current imports/exports of waste. Policy S3 will be delivered by identifying sufficient sites to meet requirements in the subsequent Hampshire Minerals and Waste Management Plans. I am satisfied that this aim and this approach is soundly based and consistent with national and regional policy.

Making Provision for London’s waste

7.18 The main shortcoming of Policy S3 is its failure to make any provision to accommodate some of London’s waste. RPG9 Policy W3 requires the provision of waste management capacity to meet a declining amount of waste from London, usually limited to landfill in line with Landfill Directive targets, which by 2016 should only provide for residues of waste that have been subject to recycling or other recovery processes. RPG9 Policy W4 also requires capacity to be provided for waste from London, where appropriate and consistent with Policy W3.

7.19 Draft SEP Policy W3 takes this a stage further by setting an apportionment figure for each WPA for accommodating London’s waste. For Hampshire, this amounts to 1.4mt (2006-2015) & 0.8mt (2016-2025), totalling some 2.2mt overall (8.4% of this element of London’s waste). The MWPA have no objection to the principle of apportionment, but challenge the detailed figures, and further


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figures have been submitted to the SEP EIP [HCD05/TCD17]. I understand that SERTAB now suggest that the status-quo should apply until 2016, with apportionment applying after then, but this issue is unlikely to be resolved for some time, and the draft figures can have little weight at this stage.

7.20 As submitted, the HMWCS resists the proposed apportionment on the basis that Hampshire has no readily available landfill sites to accommodate London’s waste which are accessible by sustainable means of transport. It recognises that Hampshire may accept London’s waste, in the course of normal waste business and commercial arrangements, but makes no specific provision for landfill sites to accommodate the disposal of such waste. However, at the time the HMWCS was submitted, there was insufficient evidence to support this approach and many of the arguments sought to challenge approved regional policy.

7.21 RPG9 Policy W3 requires all WPAs collectively to meet a regional provision, in the interests of regional self-sufficiency, and each WPA has a part to play in delivering this key element of regional strategy. I realise that the delivery of RPG9 Policy W3 depends not only on the WPA, but also on other players in the waste industry, and I recognise that the waste industry and other WPAs could provide sites to meet this requirement. However, Hampshire’s approach could make it all the more difficult for this element of the RSS to be delivered because of its failure to make the required provision, with the risk that this element of the RSS will not be fully delivered. By deliberately failing to make specific provision to accommodate any of London’s waste throughout the period of the Strategy, the HMWCS is not only inconsistent with national policy in PPS12 & PPS10, but is also out of general conformity with RPG9 and directly contrary to approved regional policy. Consequently, I consider this element of the submitted DPD is clearly unsound.

7.22 However, RPG9 Policy W4 provides some flexibility and introduces the question of appropriateness in making provision for London’s waste. Since approved RPG9 includes no specific figures for this element of provision and the apportionment figures in the emerging SEP have limited weight, the MWPA can consider the appropriateness of making such provision when preparing this DPD. Local testing through the plan-making process is allowed for in draft SEP [RCD04; Section D6; ¶6.6], which is particularly relevant when the detailed apportionment figures have not been fully tested and ratified. I also note the MWPAs’ views on the shortcomings of the current draft apportionment figures. In these circumstances, it seems reasonable to examine the potential to accommodate a proportion of London’s waste in Hampshire in more detail, in order to assess the implications and practicality of this requirement.

7.23 The MWPAs’ Topic Paper [TP1] undertakes this task and provides evidence to justify the proposed course of action. It assesses the implications of making the necessary provision, including the potential to accommodate London’s non-hazardous waste within Hampshire at existing and new landfill sites. Availability of suitable landfill capacity is one of the key factors when assessing this matter. At present, there is about 8mt of existing landfill capacity, nearly all in SW Hampshire over 125km from London, with only two sites of any scale. By 2015, RPG9 estimates a shortfall of almost 16mt of non-hazardous landfill capacity to meet Hampshire’s own needs, which underlines the relative lack of suitable and readily available landfill sites in this county. Hampshire clearly has a considerable challenge in meeting its own needs for non-hazardous landfill capacity, without taking account of any additional provision to accommodate London’s waste. The MWPA also argue that it is not appropriate to provide for landfilling of London’s waste because there are insufficient suitable non-hazardous landfill opportunities in the right locations; accepting untreated London waste would conflict with the Strategy and disadvantage Hampshire’s businesses; and London’s requirements are unreasonable and unambitious.


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7.24 To make provision for London’s waste would mean identifying landfill capacity to accommodate some 2.2mt of additional waste. Preliminary work on identifying future landfill sites, as part of the Hampshire Minerals Plan, reveals that most of the potential sites are in SW Hampshire, far from London and not accessible by sustainable transport means, all of which would need to be carefully assessed against environmental and other factors. If provision were to be made to accommodate a proportion of London’s waste, this would require new sites to be identified in SW Hampshire, or major land-raising projects would have to be proposed covering extensive areas of NE Hampshire, where there are environmental constraints, including the Thames Basin Heaths SPA & AONBs. There is also the relatively long lead-time needed to provide additional landfill sites, most of which could not be used for landfill until mineral extraction has ceased. Consequently, there are serious doubts about the practicality, deliverability and commercial reality of identifying additional landfill sites in these areas in the short term.

7.25 The basic conclusion that Hampshire has insufficient readily available and commercially viable non-hazardous landfill opportunities within reasonable distance of London or accessible by sustainable means of transport is soundly based. Moreover, SEERA is satisfied that Hampshire cannot meet the draft apportionment figure in the emerging SEP to accommodate London’s waste up to 2016. In view of these specific circumstances, I can see very real difficulties that Hampshire would face if it had to make specific provision to accommodate an element of London’s waste, particularly in the short term. Consequently, it seems to me that there are specific and particular local reasons why Hampshire could not identify additional landfill sites to accommodate London’s waste in the period up to 2016 with any confidence of certainty or deliverability.

7.26 I recognise that the failure to accommodate some of London’s waste in Hampshire in the short term could put more pressure on other areas to make the necessary provision, and could encourage others to make similar arguments about non-provision. However, Hampshire has some distinct local circumstances, largely related to geology, hydrogeology, the need to protect groundwater and the lack of suitable, accessible and available landfill sites close to London. Applying a rigid and dogmatic approach to this element of provision merely results in uncertainty and lack of deliverability, and fails to recognise the reality of the practical constraints in Hampshire.

7.27 Furthermore, only very small quantities of waste from London are currently landfilled in Hampshire (less than 800tpa or less than 0.1% of London’s exported waste). The proportion of London’s waste to be exported to Hampshire is less than 9% of the total in the draft apportionment figures, whilst some other WPAs have more opportunities to accommodate such waste at existing landfill sites. Consequently, the implications of failing to make provision to accommodate London’s waste in the short term are unlikely to be serious or significant.

7.28 The suggested changes to Policy S3 confirm that no specific provision will be made for London’s waste before 2016, but provision after this date will be considered in a review of this DPD. Other changes to the accompanying text confirm this approach, summarise the conclusions of the Topic Report, and confirm that the question of providing landfill for London’s waste will be reconsidered when the Hampshire Minerals Plan is reviewed after 2008. This revised approach is also reflected in similar changes to Policy S6.

7.29 SEERA confirms that the agreed amendments reflect the difficulties Hampshire face in accepting more than the current small amounts of London’s waste in the short term. SEERA also accepts that waste exports from London will continue to be driven by existing contracts and commercial operation of the waste market. In reality, apportionment would not start until 2016 and the


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matter needs to be kept under review. The SA work already undertaken has considered options relating to accommodating London’s waste, which have been subject to consultation, and the Topic Paper [TP1] fully assesses the implications of accommodating London’s waste. Moreover, the suggested changes do not materially alter the substance of the Strategy in the short term, but clarify the application of the policy in the medium-long term without prejudicing the interests of stakeholders.

7.30 In my view, the suggested approach would overcome the basic shortcoming of the submitted DPD in failing to make specific provision to accommodate a proportion of London’s waste, as well as reflecting Hampshire’s particular circumstances and practical difficulties with its lack of readily available and suitably located landfill sites to accommodate some of London’s waste in the shorter term. I recognise that delaying consideration of the possibility of providing for London’s waste to the future may cause difficulties in the short term, in the context of meeting RPG9’s policy objectives. But in reality, particularly given the relatively small amount of London’s waste that is currently exported to Hampshire and envisaged in the draft apportionment in the emerging SEP, I consider the suggested approach would be unlikely to seriously undermine the implementation of RPG9 or the emerging SEP, particularly given the absence of any specific targets or apportionment in the approved RPG9. If circumstances change with the formal approval of the SEP, this can be reconsidered as part of a review of this DPD, as recommended earlier in my report.

7.31 I therefore conclude that the submitted HMWCS is unsound in terms of failing to make any provision to accommodate a declining amount of London’s waste. However, the changes suggested and agreed by the MWPA & SEERA would overcome this shortcoming and provide a soundly-based approach to this issue in the short and longer term.

Other issues

7.32 The only other issue relating to self-sufficiency is whether Policy S3 should accommodate movement of waste between catchment areas, including sewage sludge. However, the concept of self-sufficiency already provides some flexibility in movements of waste across boundaries. Although the HMWCS aims to balance waste management capacity with waste arising in Hampshire, some cross-boundary movements are inevitable, especially where the nearest available site is just across the county boundary, where small amounts of waste are involved, or where wastes require special treatment or disposal. In terms of overall sustainability, this is the correct approach, dealing with waste as close as possible to its generation, consistent with PPS10. RPG9 Policies W3 & W4 do not preclude cross-boundary movements, either within or between regions. Although business or commercial arrangements for using waste management capacity within or outside the county are largely outside the control of this DPD, I consider the Strategy provides enough flexibility to accommodate cross-boundary movements of waste, including waste such as sewage sludge.

Recommendation 5

In order to make the Strategy sound, the following changes are required: (a) amend Policy S3 to confirm that the question of making provision to accommodate London’s waste post-2016 will be considered when the Strategy is reviewed, and clarify the approach to this matter in the accompanying text (Change Nos. 12-14 in Annex A to my report); (b) amend Policy S6 and the accompanying text to reflect these changes (Change Nos. 16-17 in Annex A to my report).


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Recycling, Composting, Recovery and Treatment

Key issue - Will the Strategy ensure a progressive increase in recycling and composting rates for all municipal, commercial and industrial waste?

7.33 The MWPA confirm that the figures in Policies S4 & S5 directly reflect Policy W6 of RPG9, which sets an overall recycling/composting target of 60% by 2020. The detailed figures for waste management capacity in Policy S5 are robust and justified in the core evidence [CCD66]. They do not exactly equate to those in RPG9 Policy W7, but the basic figures set out in this DPD (¶ 15.2) are compatible and can be used for monitoring purposes. Any differences relate to the use of more up-to-date and reliable information and projections, and are broadly consistent with the figures and approach used in RPG9. SEERA has no concerns about any differences in the figures.

7.34 These policies will be delivered by identifying sufficient sites to meet these requirements in the subsequent Hampshire Waste Management Plan, along with limitations on waste-to-landfill and measures to deal with the treatment/disposal of municipal waste under HCC/MWPAs’ control. Plenty of potential/existing sites have come forward, including waste management and aggregate recycling facilities, as part of initial work on the subsequent DPD.

7.35 Current recycling/composting rates in Hampshire are about 30-33%. Work undertaken for the Material Resources Strategy confirms that a 50-60% recycling/composting rate is achievable, with sustainability benefits. This would significantly increase current rates, bringing them into line with some of the best authorities in England and Europe. This increase will be achieved in two ways: by providing new recycling facilities and driving recycling. The MWPA, through their planning role and as partners in Project Integra, can significantly influence the achievement of the proposed recycling/composting rates, as outlined in the Joint Municipal Waste Management Strategy. Regular monitoring will ensure that progress is maintained in achieving the proposed recycling/composting rates.

7.36 As for commercial waste, the Strategy takes sufficient account of this waste type as part of an innovative approach to combine municipal, commercial and industrial wastes, including combined collections and handling arrangements. There is little distinction in this type of waste and it does not require any special facilities, and so there is no need for a separate policy. Additional composting facilities will improve the recycling and re-use of green waste, including both household and commercial elements, whilst additional facilities for dealing with construction/demolition waste will help to improve recycling and re-use of these materials. The Strategy indicates the additional capacity required, SERTAB regularly monitors the requirement, and the precise number of sites will depend on the nature and scale of the facilities proposed.

7.37 The situation on waste management capacity is less clear, due to the variations in capacity of existing sites, differences in capacity limits set by the planning and PPC regimes, and shortcomings in the information base. Policy S5 indicates total capacity requirements of 1.86mt for recycling/composting and 0.93mt for recovery/treatment, much of which is already in place. To provide some flexibility and indicate the broad amount of additional capacity required over the plan period, a range of 1.0-1.2mt for recycling/composting and 0.4-0.5mt for recovery/treatment provides a reasonable and realistic approach. The MWPA suggest a minor addition to confirm that additional provision can be made by new sites or expanding capacity at existing sites, which I endorse.

7.38 In my view, this provides sufficient guidance to the subsequent Waste Management Plan about the quantity of additional capacity required. Any additional Strategic Waste Management Facilities would be directed to the two “areas of search” in north-east and south Hampshire, as shown on the Key


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Diagram and addressed under Policy S16. The site-selection process in Policy S18 & Appendix 2 would also apply to new sites and facilities. The subsequent DPD will also identify sites to provide any additional capacity required to handle commercial and industrial waste, although much of this could be combined with the infrastructure for handling municipal waste as a single, similar waste stream. Reviews of existing sites and facilities will also be undertaken at this stage.

7.39 Policy DC13 provides the locational criteria for waste management and recycling developments. There is some concern that the HMWCS does not identify sites and areas suitable for new or enhanced waste management facilities, including sites coming forward outside the plan. However, it is unrealistic at the strategic level of this DPD to identify all the waste management sites and facilities that may be needed to manage Hampshire’s waste in the future. Policy S5 indicates the extra capacity required and the Strategy identifies broad types of sites, including areas for landfill, waste recovery and treatment. Large scale waste management facilities, including recycling/transfer sites and other areas/sites for waste management facilities, along with smaller-scale facilities and specialist facilities identified in Policy S7, will be identified in the Waste Management Plan. Policy DC13 is designed to evaluate proposals that are not included within the Strategy, and provides a coherent and consistent approach, ensuring sufficient opportunities for providing waste management facilities in appropriate locations, consistent with national policy in PPS10.

7.40 As to whether Policy DC13 should include a presumption against waste management/recycling facilities in National Parks, this would not accord with the site-selection procedure (¶ 24.4 & Appx 2) and Policy DC2 of the HMWCS, or with national policy in PPS10 (E(c)). There is also concern about the definition of previously developed land. However, mineral and landfill sites with conditions requiring restoration are not included within this definition, consistent with the latest national guidance in PPS3. As for Aggregate Recycling Facilities, it is appropriate to include these under Policy DC13 and confirm that the locational criteria also apply to this type of facility, as the MWPA suggest. The more specific locational requirements for such uses would be covered by Policies DC13, S17 & DC22, and could be considered as part of the identification of suitable waste management sites/areas in the subsequent Waste Management & Mineral Plans.

7.41 With the suggested and recommended changes outlined above, I conclude that the HMWCS provides a soundly-based approach to the targets for recycling and composting and the provision of the necessary waste management facilities.

Recommendation 6 In order to make the Strategy sound, the following amendments are required: (a) amend the table accompanying paragraph 17.11 to confirm that provision can be met by new sites and expanded capacity at existing sites (Change No. 15 in Annex A of my report); (b) amend Policy DC13 to include Aggregate Recycling Facilities and refer to both the Hampshire Waste Management and Minerals Plans (Change No. 48 in Annex A of my report).


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Landfill

Key issue - Is the Strategy for dealing with landfill and hazardous waste capacity soundly based and appropriate for Hampshire & the New Forest?

7.42 Policy S6 seeks to provide up to 5.2mt of non-hazardous landfill capacity up to 2020 within the Landfill Potential Area defined on the Key Diagram. It also indicates that 18.5mt of non-recyclable inert waste will be used for restoring mineral and landfill sites, for engineering and infrastructure projects, and other beneficial reuse. The landfill requirement figure has been calculated from the sum of the annual capacity figures, phased to provide a reduced reliance on landfill to reflect regional targets in RPG9 Policy W5, taking account of existing void capacity when the HMWCS was produced.

7.43 The figures are based on known data and estimates, supported in the core evidence [CCD66/HCD11], and the overall pace of reduction in landfill is in line with the regional targets in RPG9. There is a slight difference between the balance of inert/non-inert landfill compared with the figures in RPG9 Policy W5, with a higher provision for inert landfill and a lower provision for non-hazardous landfill. This is due to the lack of opportunities in Hampshire for non-hazardous landfill, greater opportunity for using inert waste, a well-developed provision of alternative waste disposal measures (including municipal waste incineration), and stakeholder aspirations to cease landfilling of untreated municipal waste by 2015 and achieve self-sufficiency by 2016. Various options on differing balances of recycling, composting, landfill and treatment were assessed by the SA and the most sustainable option has been taken forward. The proposed provision will also contribute to regional landfill requirements set out in RPG9 Policy W13. SEERA is generally content with the MWPAs’ approach, which I consider is soundly-based.

7.44 The MWPA suggest some changes to Policy S6 and the accompanying text to reflect earlier suggested amendments relating to the issue of accommodating London’s waste, which I have dealt with earlier. To make provision for accommodating a declining amount of London’s waste, the landfill capacity figure would have to be increased by some 2.2mt. However, amended Policy S6 confirms that provision for London’s landfill requirements post-2016 will be considered in a review of the HMWCS, clarified in the accompanying text (¶ 18.6), which would address SEERA’s concerns. The suggested increase to 5.3mt in landfill capacity takes account of the existing landfill site in the Wiltshire part of the NFNP. Other suggested changes to the accompanying text are necessary to update existing landfill capacity and take account of the latest national guidance in PPS25, as well as clarifying the nature and purpose of the Landfill Potential Area. I endorse these suggested changes.

7.45 As for the remaining issues, the Strategy’s approach of linking landfill and mineral voids seems appropriate, since there are several existing mineral sites in Hampshire that would benefit from restoration by landfill. The use of voids created by other forms of development is not as sustainable, due to visual impact, land-take, engineering requirements and pollution impact, as the SA confirms. In the future, significant voids will be created by mineral extraction, in excess of Hampshire’s landfill requirements, but not all will be suitable for non-hazardous waste. Restoration to other uses, such as nature conservation, will be considered under Policy DC12. The evaluation process for new mineral sites incorporates their potential suitability for non-hazardous landfill, and surcharging of existing landfill sites is being considered as part of the review of existing sites. It therefore seems reasonable to link these two activities, especially since the HMWCS does not envisage any proposals for landraising. Sites to meet the requirements of Policy S6 will be nominated, considered and proposed in the subsequent Minerals & Waste Management Plans.


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7.46 In response to requests for this DPD to give a clearer picture of the nature and distribution of existing waste treatment facilities, some basic information is provided in the DPD, more detailed information is set out in the core evidence [CCD66/CCD50] and further details will be given in subsequent DPDs. The requirement for pre-treatment of municipal waste, required by the Landfill Directive, is set out in Environment Agency guidance documents, which allows for landfilling of residual municipal waste without treatment provided that the MWPA are working towards recycling targets. The process of landfilling residues from treated waste is far more onerous. Given Hampshire’s performance in municipal waste recycling and waste management and the absence of suitable existing and potential landfill voids, I am satisfied that the proposed approach reflects local circumstances without offending the requirements of the Landfill Directive.

7.47 There has been some misunderstanding about the nature and purpose of the (Non-Hazardous) Landfill Potential Areas (LPA). The MWPA now define these as “broad areas of interest which have potential for non-hazardous landfill, from within which, subject to geological and planning evaluation, sites, locations and “areas of search” may be identified” (Suggested change to Glossary). The LPAs lie within the Mineral Resource Areas, and their general extent is illustrated on the Key Diagram. The LPAs exclude areas unsuitable for non-hazardous landfill, such as urban areas, buffer zones, flood risk areas, designated landscapes and nature conservation sites. The MWPA suggest clarifying and updating the areas which have been excluded (¶ 18.13), which I endorse. The latest version of the Key Diagram reflects the Environment Agency’s most recent hydrogeological information, and other policies (eg. Policy DC14) will safeguard the environment and groundwater.

7.48 LPAs translate specific locational criteria (¶ 18.13 & 20.16) into illustrative areas of search for future provision of non-hazardous landfill sites, for which detailed boundaries will be drawn up in subsequent DPDs. However, they only indicate the broad areas where future landfill sites may be found, and much will depend on detailed assessment of the suitability of specific sites at later stages. I therefore conclude that these LPAs are an essential spatial element of the Strategy, providing firm guidance and direction to subsequent DPDs.

7.49 Policy DC14 sets out the locational criteria for landfill sites. There is no need for the policy to include a presumption against landfill sites in the National Parks & AONBs, since these areas are automatically excluded from the LPAs and are covered by Policy DC2. Issues about monitoring and enforcement are regulatory matters which do not need to be included in this policy. Concerns about the potential adverse impact on the environment, on surface/ground water and on the local economy would be dealt with at the site-selection stage, under Policy S18 & Appendix 2. I also note that all Groundwater Protection Zones are excluded from the LPAs. RPG9 Policy W13 deals with landfill gas collection and energy generation. Consequently, apart from some minor amendments to the wording of the policy and accompanying text which do not affect overall soundness, I can see no need for any further changes to Policy DC14.

7.50 With the recommended changes, I conclude that the approach of the Strategy for dealing with landfill and non-hazardous waste capacity is soundly based, justified by robust and reliable evidence, and is consistent with national and regional guidance.

Recommendation 7 In order to make the Strategy sound, the text accompanying Policy S6 should be amended, to clarify the nature of the Landfill Protection Areas, and update the figures of landfill capacity, in line with the MWPAs’ suggested changes (Change Nos. 18-19 in Annex A to my report).


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Specialist facilities

Key issue - Is the aim of the Strategy to increase hazardous waste management capacity soundly based and fully justified?

7.51 Figures from the Environment Agency confirm that hazardous waste accounts for only 3% of Hampshire’s total waste production, and the provision figures in Policy S7 are based on robust and reliable data based on work undertaken for More From Less. Hampshire is well provided for with existing hazardous waste management facilities, including the nationally significant incinerator at Fawley and several plants dealing with oily wastes. There is a shortfall of sites for managing Air Pollution Control Residues (APCR), separate cells for stabilised non-reactive hazardous wastes, and the treatment of contaminated soils. The provision set out in Policy S7 will address these shortfalls and help to make Hampshire self-sufficient in the treatment of specialist waste, as well as complementing RPG9 Policy W15. The subsequent Waste Management Plan DPD will identify suitable locations for the required facilities.

7.52 As for the remaining issues, accommodating an element of London’s hazardous waste is not specifically mentioned, since RPG9 does not apply any apportionment to this type of waste. There is no indication that London intends or wishes to export such waste, but the Fawley incinerator provides a regional facility to deal with hazardous waste from London and elsewhere. More common hazardous wastes, such as batteries, refrigerator gases, end-of-life vehicles, tyres and WEEE Directive waste only account for a minor proportion of the total waste generated in Hampshire. Sites, collection systems and handling/treatment facilities are already in place to deal with most of these waste streams, and current and future requirements were assessed in the Material Resources Strategy. Policy DC13 provides the locational criteria for such facilities that may be required in the future, and the review referred to in Policy S7 would include assessing the potential of sites and facilities to deal with specific hazardous waste streams. Infrastructure and sewerage/effluent treatment provision will also be dealt with by Policy S7. Environmental and other constraints will be addressed through the site-selection process and Policies DC1-DC13, whilst the potential hazards of nutrient run-off from waste facilities would be addressed at the planning application/site allocation stage and through the planning/PPC regime.

7.53 At a late stage in the proceedings, SWRA raised concerns about the need for Policy S7 to make provision for landfilling APCRs from incinerators in Hampshire. However, Policy S7 already makes provision for waste management capacity for recycling/treatment of APCRs. The amount of such waste is relatively small (20,000tpa), and is insufficient to justify a commercially viable treatment/ disposal facility in Hampshire. Such waste is currently taken for treatment in Manchester/Liverpool and disposed of in Cheshire/Gloucestershire. Work undertaken for the South East Region identifies a need for hazardous waste landfill in the east of the region, but HCC is investigating the possibility of a recycling plant for APCRs, including manufacturing a recycled product. Due to the specialist nature of the waste and the scale of the facilities needed for treatment/ disposal, I consider there is no need to identify any specific landfill capacity to dispose of this material, given the overall aim of self-sufficiency.

7.54 I therefore conclude that the approach to the provision for specialist waste management and treatment facilities is soundly based and fully justified, and no changes are needed to the submitted policy and text.


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Minerals – Sand & Gravel

Key issues - Is the Strategy on sand and gravel production consistent with national and regional guidance, with appropriate provision levels, and is the policy on landbanks, “strategic reserve” and sub-area apportionment soundly based and appropriate for Hampshire and the New Forest?

7.55 Policy S8 seeks to maintain production of land-won sand and gravel at a rate of 2.63mtpa until 2020, mainly from the Mineral Resource Areas (MRA) shown on the Key Diagram, and sets out an apportionment for each of the sub-areas within the plan area up to 2016. The justification for this policy is set out in a Topic Paper [TP2] and the production figure reflects the sub-regional apportionment in RPG9 Policy M3. Although the apportionment figure was unsuccessfully challenged at the previous RPG9 EIP, the MWPA are committed to meeting this figure, consistent with the latest national guidance in MPS1. Policy S8 also confirms that the figure will be adjusted when the regional apportionment is reviewed, and so I am satisfied that this element of the DPD is soundly based.

7.56 However, the sub-regional apportionment is not inflexible, and the practicality of making this level of provision can be tested at local level, as MPS1 (¶ 3.8) and Policy DC15 (¶ 25.68) confirm. This will be undertaken in detail in the Hampshire Minerals Plan, but in the meantime, the suggested amended wording of Policy S8 will ensure that the minimum provision is made. I recognise that past experience shows that the supply of sand and gravel has consistently been below the overall apportionment level for Hampshire, and there has been a downward trend in actual supply of sand and gravel. However, no alternative provision figures, backed up by firm and soundly-based evidence, have been put forward by the MWPA or other parties.

Landbanks

7.57 Both MPS1 & RPG9 Policy M3 require MPAs to plan to maintain a landbank of at least 7 years of planning permissions for land-won sand and gravel. As submitted, the HMWCS makes no specific commitment to maintain this landbank, and makes no reference to this matter in Policy S8. Hampshire currently has permitted reserves of almost 10.9mt, equal to a landbank of just over 4 years for the whole county, with landbanks ranging from 0.8-6.5 years in the separate sub-areas. In the past, production of sand and gravel has fallen below the level of apportionment, but this could be due to many reasons, including the possible lack of permitted and identified sites, and the import of quantities of alternative materials from adjoining counties or by sea.

7.58 I recognise that there is no specific requirement in national policy to build landbanks into the development plan process and that the question of maintaining a 7-year landbank partly depends on planning applications being granted. However, I consider the commitment to maintain a 7-year landbank should be explicitly referred to, since it will help to address the current shortfall in the landbank and provide firm guidance to subsequent DPDs in terms of the scale and number of sites or areas that need to be identified. It will also help to ensure security and adequacy of supply, consistent with RPG9 Policy M3 and the latest national guidance in MPS1. The MWPA are content to include such a commitment in Policy S8, continuing Policy 17 in the adopted M&WLP, and this needed to make the Strategy sound. Since the question of maintaining a landbank largely depends on the minerals industry bringing sites forward, I am satisfied that the MWPA can do little more than to endeavour to maintain the landbank in this instance.


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7.59 The MWPA confirm that the Hampshire Minerals Plan will identify preferred sites to provide sand and gravel until at least 2017. However, these sites will not form part of the landbank until planning permission has been granted. The commitment to maintain a 7-year landbank will not necessarily conflict with its continued maintenance beyond the end of the plan period, since this is a rolling process, or cause difficulties when the regional apportionment figures are reviewed. Nor should it cause any unnecessary blight; that would depend on the number and location of sites or areas identified in subsequent DPDs.

7.60 The apportionment levels in Policy S8 will be delivered by identifying specific sites, general locations and “areas of search” in the subsequent Hampshire Minerals Plan, consistent with the latest guidance in MPS1 and its accompanying Practice Guide. The precise boundaries of the MRAs will also be defined in this subsequent DPD. Planning applications and other proposals for sand and gravel extraction would be covered by Policy DC15. Any previous misunderstanding about the nature and purpose of the designated MRAs and the role of the subsequent DPD would be overcome by the suggested changes to the text accompanying Policies S6 & S8 (¶ 18.13/20.16) and the Glossary definition. These suggested changes would provide the clarification necessary to make this aspect of the DPD sound, particularly in terms of landbanks.

Strategic Reserve

7.61 There is considerable concern about the nature of the “strategic reserve” and how this will be addressed. As submitted, the HMWCS allocates some of the sand and gravel production required for 2017-2020 to a non-spatial “strategic reserve”, for which sites will not be identified until the need is clarified. It recognises the need for a “strategic reserve” of 10.52mt, but only intends to identify sites to meet this provision when a review of the regional apportionment figure (due at the end of 2008) is known. This approach is justified due to the alleged uncertainty in the post-2016 period, because the SEP & SWP are not yet finalised; the fact that the RAWP figures only run to 2016 and will be reviewed in 2008; and the falling trends in production of sand and gravel in Hampshire.

7.62 I recognise the element of uncertainty and need for some flexibility in future provision, particularly with the forthcoming revised sub-regional apportionment, and also the need to avoid over-provision or a mismatch between the local apportionment figure and sites on the ground. It is also important to recognise the needs of local markets and the need to avoid unnecessary blight. However, national and regional guidance is clear in requiring MPAs to make the necessary provision to meet the sub-regional apportionment throughout the plan period in the form of specific sites, preferred areas and/or areas of search. This is in order to show how the MPA proposes to provide for the necessary supply of economically workable minerals and give a clear guide to mineral operators and others about the places where mineral extraction is expected. By failing to indicate where this longer-term “strategic reserve” is likely to be located, the MPA is failing in its national and regional duties in making the necessary provision for future sand and gravel working and makes the plan unsound.

7.63 As a result of discussions at the hearing sessions, the MWPA have reconsidered their approach. Although specific sites to meet this “strategic reserve” post-2016 will not be identified in the Hampshire Minerals Plan, provision for this element will be made by means of “areas of search” and policies in this subsequent DPD. The need to maintain a 7-year landbank will ensure that adequate provision is made throughout the plan period and, as time progresses, the subsequent DPDs will ensure that specific sites or areas of search will be identified to make the necessary provision. The commitment in Policy S8 to adjust the provision following the review of the sub-regional apportionment will ensure that the DPD is kept up-to-date and in line with the latest figures and


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trends. I endorse the suggested amendments to the policy and accompanying text, which would bring the HMWCS into line with the latest national policy in MPS1 (A1; 3.7), provide the necessary clarity and flexibility in terms of longer-term provision without causing any unnecessary blight, and ensure that it is sound in this regard.

Sub-area apportionment

7.64 In order to provide some local distinctivity and reflect the local market areas for sand and gravel in Hampshire, a sub-area apportionment is proposed up to 2016, essentially based on the geographical distribution of deposits and their corresponding markets. This is a new approach in this DPD, with the aim of meeting local needs from indigenous materials. It is calculated using the historic patterns of production, similar to that used in the sub-regional apportionment. There is little evidence that previous patterns of aggregate supply and demand will significantly change in Hampshire in the future, since it tends to have distinct market areas, and informal studies suggest that there is little transfer of aggregate between geographic areas.

7.65 To significantly alter the balance of supply and production from past trends could fundamentally alter the Strategy, with the risk of both under and over-supply, sites not coming forward, impact on competitiveness and manufacture of recycled/secondary aggregates, and problems of heavy lorries travelling further, including across the NFNP. Little correlation between sand and gravel supply and house-building has been found, and the amounts of aggregate used in maintaining infrastructure are unlikely to change significantly. Although this approach requires the consideration of both county-wide and local landbanks at the planning application stage, the accompanying text (¶ 20.15 as amended) confirms that if the local apportionment cannot be met, the policy would be reviewed and the shortfall would be found from other sub-areas.

7.66 Consequently, I consider the sub-area apportionment provides an element of flexibility and local distinctiveness, and helps to focus future provision on distinct resource and market areas. It is appropriate for this local apportionment to apply to 2016, since a more up-to-date sub-regional apportionment will be available in 2008 to cover the period beyond 2016. As such, I conclude that the principle of local apportionment for sand and gravel is justified and reflects Hampshire’s local circumstances, resources and markets.

7.67 There is some concern about the precise figures for particular sub-areas, including the indicative new provision required. The Forest sub-area excludes the NFNP, but is a relatively small area with the highest apportionment. A range of 0-5.483mt is the indicative new provision, based on existing sites and the balance of apportionment which, given the existing quarries and deposits within this sub-area, is justified. Reduced provision in one sub-area would require increases in other sub-areas, to meet the overall sub-regional apportionment. The MWPA confirm that not all provision is expected to come from the Plumley Wood/Ringwood area, and the precise location and extent of any new sites, along with environmental and other impacts, will be fully addressed in the subsequent DPD and at the detailed planning application stage. The MWPA also work closely with Dorset CC on minerals and transport issues relating to the NFNP. I can also see little basis for a further sub-division of the Forest sub-area, particularly since it is already the smallest of the sub-areas.

7.68 As for the other sub-areas, I reach similar conclusions about the provision figures, which are based on the same methodology and seem soundly based. I am also satisfied that the full range of spatial options have been considered, and that there is sufficient supportive evidence to justify the preferred option and amount of sand and gravel to be found from each of the sub-areas.


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7.69 However, the table accompanying Policy S8 gives an indicative range of new provision for the Downland and Forest sub-areas. This arises from the existence of “preferred areas” in the adopted M&WLP and also relates to particular sites where planning applications are expected. However, these sites and preferred areas do not yet have planning permission and are to be reviewed in the Hampshire Minerals Plan. It is misleading to provide an “indicative” range of new provision, dependent on particular planning applications or sites coming forward, since actual provision and requirements will depend on the sites and areas identified in the subsequent DPD coming forward and being approved. This element of the accompanying figures and text (including the Key Diagram) should therefore be amended to indicate the full range of indicative provision required, for clarity and to ensure that this element of the HMWCS is sound.

Other issues

7.70 There is some dispute as to whether the HMWCS should provide for the supply of sand and gravel rather than production, to ensure that the annual apportionment is actually produced and provide sufficient flexibility to ensure adequate supplies of sand and gravel. However, both national and regional guidance refer to provision being made to meet the sub-regional apportionment, which is what this DPD does. It is unrealistic to estimate the actual production rates from existing and future sites without knowing the merits and operational details of each site. Actual supply is dependent on the output of particular quarries and on market demand at the time. The suggested amendment to the opening sentence of Policy S8, confirming that provision will be made for the production of the required amount of sand and gravel helps to clarify the situation and bring it into line with MPS1. I also endorse the suggested change confirming that local needs will be met from indigenous materials, which will ensure that this element of the DPD is sound in terms of national and regional policy.

7.71 Issues about the import of other materials, such as limestone, need to be monitored, since some may be used as alternatives to gravel, whilst crushed rock is imported because Hampshire has no hard rock reserves. However, the quantities of these imported materials are not great and are part of the accepted cross-boundary movements and imports of minerals. They do not count towards the sub-regional apportionment, since that relates to the production of indigenous sand and gravel from within Hampshire. The identification of “preferred areas” and sites for future sand and gravel working in the subsequent DPD will ensure that sufficient and specific provision is made for production of the required amount of aggregates in the future.

7.72 There is also some concern about whether the policy should differentiate between soft sand and sharp sand and gravel, and between primary and secondary aggregates supply. Recent figures indicate that soft sand accounts for about 20% of total sand and gravel sales. The adopted M&WLP distinguishes between soft sand and sharp sand and gravel, with separate landbanks. However, it seems that there is no longer a reliable distinction between these materials, either in monitoring or production, and some mineral companies are able to process the product to suit markets. Some do not differentiate these materials when providing information, and there is insufficient data to assess production and market demand. Although SEERAWP include figures for both soft sand and sharp sand and gravel in the latest monitoring report [HCD06], there is no general requirement to differentiate between these materials in MPS1 or RPG9. Should later reports require a distinction to be made, this can be accommodated in a review of this DPD. Later policies in this DPD differentiate between primary and secondary aggregates.


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7.73 As regards the potential for expansion of marine-dredged sand and gravel, this is partly related to the capacity of existing wharves and depots to handle imported minerals, both marine-dredged sand and gravel and crushed rock, which I deal with later in my report. However, the Topic Paper [TP1] confirms that Hampshire’s existing wharves have sufficient capacity to handle considerably more material if the need arises, and that market demand is the limiting factor. The MPAs have little influence over the issue of licences, but should demand for marine-dredged sand and gravel increase, there seems to be sufficient capacity at the existing wharves and depots, subject to the review of wharf capacity that will be undertaken in the Hampshire Minerals Plan.

7.74 The HMWCS adopts a precautionary approach to sand and gravel working in the National Parks & AONBs, which reduces the risk to sensitive landscapes and habitats. Policy DC2 effectively precludes mineral extraction within National Parks and AONBs, whilst the MRAs also exclude these designated landscapes. This is consistent with national policy in MPS1 & PPS7. The MWPA confirm that there are sufficient deposits of sand and gravel outside the National Parks and AONBs. Although there may be instances where sand and gravel extraction may not be incompatible with these designations, there would need to be some exceptional circumstances to allow this in the context of national policy, particularly where an AA would be required under the Habitat Regulations. I therefore conclude that the approach to sand and gravel extraction in National Parks & AONBs in Hampshire is consistent with national and regional guidance.

7.75 There has been some misunderstanding and confusion about the nature and purpose of the MRAs. They are an integral spatial element of this DPD, and translate locational criteria into illustrative “areas of search” for sand and gravel working. The principle also sensibly links mineral extraction to the possibility of subsequent restoration by landfill. The terminology of Mineral Resource Area does not fit precisely with the definitions used in MPS1, and there may be some confusion with the Mineral Consultation Areas and Mineral Safeguarding Maps referred to elsewhere in this DPD. However, the suggested Glossary definition of the MRA would overcome any doubt or confusion about the nature and purpose of this broad “area of search”, and the subsequent Hampshire Minerals Plan will focus on specific sites and “preferred areas” where sand and gravel extraction may be proposed or anticipated in the future.

7.76 As for the question of excluding buffer zones from the MRAs, it is difficult to show these at the detail and scale required on the illustrative Key Diagram. However, it is important to refer to this constraint in the Strategy, to provide the necessary guidance to subsequent DPDs. The MWPA’s suggestion, confirming that buffer zones will be reviewed when the detailed MRA boundaries are defined in the subsequent DPD, will clarify this matter and ensure that the DPD is sound.

7.77 As for the extent of the MRAs themselves, I deal with some of the specific areas later in my report. The MWPA confirm that they are based on reliable geological information and no-one has challenged the existence of sand and gravel deposits within the areas illustrated on the Key Diagram. The broad extent of the MRAs has also been reviewed to reflect the latest hydrogeological information and PPS25. Initial work on the Hampshire Minerals Plan indicates that there should be no shortage of potential sites to meet the required provision.

7.78 Policy DC15 provides locational guidance and criteria for planning applications to extract sand and gravel, and direct the search for such areas and sites, along with Policy S18 and the process and factors in Appendix 2. The MWPA suggest some minor amendments to the policy and accompanying text, to confirm that approval is contingent on all the criteria being met, clarify the policy within National Parks & AONBs, and qualify the reference to the landbank. These changes are necessary in the interests of clarity, consistency with national policy


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and soundness. Detailed issues, such as the impact on aviation and airfield areas, including bird-strike areas, would be considered at the site-selection stage and by Policy DC12 where restoration is concerned.

7.79 The remaining issues concern the location of future sand and gravel extraction. The policy envisages most future mineral working taking place within the designated MRAs, subject to meeting specified criteria, including environmental and access factors. Except for small-scale extensions or extraction related to other developments, it is reasonable to exclude sand and gravel extraction outside of the designated areas, as advised in MPS1. There are also “preferred areas” for sand and gravel working in the adopted M&WLP. In the period before these areas become translated into similar areas or sites in the Hampshire Minerals Plan, it is appropriate for sand and gravel extraction to be permitted within these areas, as Policy DC15(a) confirms.

7.80 Generally, sand and gravel extraction should be restricted to permitted sites, sites/areas identified in the adopted M&WLP and future sites in “preferred areas” in the Hampshire Minerals Plan. Policy DC15(c) also allows for other sites to come forward subject to questions of the landbank, acceptability and need. Along with minor windfalls as a result of extraction prior to development, this provides a degree of flexibility if current or future sites do not come forward. Consequently, I conclude that Policy DC15, as amended, is consistent with Policy S8 and national and regional policy, and will provide a sound basis for considering future proposals for sand and gravel extraction.

Recommendation 8 In order to make the Strategy sound, the following changes are required: (a) amend Policy S8 and the accompanying text to: (i) confirm that provision will be made for the production of the required amount of land-won sand and gravel, with a local apportionment to meet local needs from indigenous materials; (ii) confirm a commitment to maintain a landbank of at least 7 years; (iii) confirm that provision for the post-2016 “strategic reserve” will be made by means of areas of search and policies in the Hampshire Minerals Plan; (iv) include a commitment to review the policy if the local apportionment cannot be met (paragraph 20.15); (v) amend the indicative “new” provision (2005-2016) in the table above paragraph 20.13 and on the Key Diagram for Downland (5.183 million tonnes) and Forest (excluding New Forest National Park (5.483 million tonnes) sub-areas; (vi) clarify the status of the “preferred areas” in the adopted Minerals & Waste Local Plan in paragraph 20.13; (vii) clarify the nature and role of the Mineral Resource Areas and the locational criteria in paragraph 20.16; (b) amend Policy DC15 and the accompanying text, to clarify the application of the criteria and approach of the policy in terms of the landbank; (Changes Nos. 20-24 & 49-50 in Annex A of my report).


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Minerals – Recycled and secondary aggregates

Key issues – Is the Strategy for recycled and secondary aggregates consistent with national and regional guidance, with proposed provision based on sound, robust and credible evidence, and does it take sufficient account of the needs of Aggregate Recycling Facilities?

7.81 Policy S9 aims to provide production capacity to supply 1.7mtpa of recycled and secondary aggregates, along with reprocessing of 100,000 tonnes of incinerator bottom ash. Sites to meet this provision will be identified in the Hampshire Minerals Plan. The figures in Policy S9 are challenging, but are based on the higher rates of recycling set out in RPG9 Policy M2, reflect the detailed methodology carried out at regional level and are supported by the SA and core evidence [CCD66]. They are based on work undertaken for the Material Resources Strategy, are realistic and within the acceptable margins of error, in the context of the scale of new development required. Policy S9 also reflects the detailed apportionment set out in Policy M2 of the emerging SEP, even though these figures are not yet formally approved.

7.82 The figures reflect the existing provision of sites to produce recycled/ secondary aggregates, and the required provision to meet regional targets, including the manufacture of recycled aggregates for the construction industry, processing of incinerator bottom ash, rail ballast, ARFs, “skip” type operations and on-site reprocessing. There is a lack of detailed information on all these types of materials, but provision of secondary aggregates and recycled materials will contribute to the production required in RPG9/SEP Policy M2 and reduce the need to extract primary aggregates. Any challenge to the regional recycling targets is one for the emerging SEP, rather than for this DPD. Consequently, I am satisfied that the figures and the approach of Policy S9 are soundly based.

Aggregate Recycling Facilities (ARF)

7.83 There is some concern that the Strategy should recognise the distinction between sites for manufacturing recycled/secondary aggregates and other recycling/waste management operations. This has much to do with making sufficient provision for ARFs, for which there is acknowledged need and demand. National and regional guidance does not require any distinction to be made between secondary/recycled aggregates, although the text accompanying Policy S9 (¶ 20.19) does summarise the existing facilities. Construction, demolition and excavation (C D & E) wastes are dealt with together, as in national and regional policy. Even though not all of this waste is suitable for ARFs, I consider there is no need to separate out particular types of waste. The MWPA also confirm that a distinction will be made in the Hampshire Minerals and Waste Management Plans, particularly given the need for increased capacity for such facilities and the role of these strategic facilities in delivering the high quality products needed in construction and other work.

7.84 As a result of discussions at the hearings, the MWPA suggest some amendments to the text accompanying Policy S9 (¶ 20.19-20.21) to highlight the importance and role of ARFs, along with the locational requirements. ARFs are not necessarily ruled out in the countryside, and will be considered under the site location criteria and factors in Policy S18 and Appendix 2. Strategic sites for the manufacture of recycled/secondary aggregates, including processing of C D & E wastes at ARFs, will be identified in the Hampshire Minerals Plan, along with the proportion of recycled/secondary aggregates to be delivered by strategic ARFs. Further information on the location of existing facilities is provided in the supporting evidence [CCD66].


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7.85 These suggested amendments would go a long way towards addressing these concerns and ensure that sufficient priority is given to the provision of strategic facilities to produce recycled aggregates. They would also distinguish the differences between ARFs and other waste/recycling facilities and help to ensure that the provision levels set out in Policy S8 are actually provided. With these amendments, there is no need for a separate strategic or development control policy covering ARFs.

7.86 Consequently, I conclude that the strategy for recycled and secondary aggregates, as amended, is consistent with national and regional policy, sufficiently recognises the importance and role of ARFs, and is soundly based.

Recommendation 9 In order to make the Strategy sound, the text accompanying Policy S9 should be amended to clarify the existing situation on Aggregate Recycling Facilities, including the number of sites, locational requirements, the provision of additional sites, and the role of subsequent DPDs (Change Nos. 25-27 in Annex A to my report).

Chalk, Clay, Oil & Gas

Key issue - Are the policies for the extraction of chalk and clay and the exploration, appraisal and development of oil and gas soundly based, appropriate for Hampshire & the New Forest and consistent with national and regional guidance?

Chalk

7.87 Policy S10 supports small-scale extraction of chalk for agricultural and industrial uses, but opposes its extraction for use as aggregate, fill or engineering material. Chalk is a widely available mineral resource in Hampshire, with several permitted chalk pits supplying chalk, mainly for agricultural use. Demand for chalk is unlikely to change much during the plan period, and the submitted policy will ensure that this mineral is used effectively and efficiently without any unnecessary environmental damage. Policy DC16 permits chalk extraction where there is an agricultural or industrial need that cannot be met from another source which outweighs any environmental, transport or other impacts. This policy places similar restrictions to those imposed on other mineral activities by other policies in this DPD. In my view, it is an appropriate policy framework for considering proposals for chalk extraction in the future.

Clay

7.88 Policy S11 seeks to maintain a 25-year reserve of brick-making clay, but does not support its export for other uses, continuing Policy 27 in the adopted M&WLP. Safeguarding the supply of brick-making clay is an important element of national and regional policy in MPS1 & RPG9 (Policy M4; ¶11.44), and Policy S11 helps to ensure that existing reserves are safeguarded for local brickworks. However, the export of clay from existing sites could have adverse amenity and traffic consequences and result in deposits being worked out sooner, increasing the possibility of extensions to existing clay pits in relatively constrained locations.

7.89 Although there is a need to recognise the potential for clay to be used for other purposes, the DPD makes it clear that clay for these uses would have to be found from other sources, in order to protect existing clay deposits used locally for brick-making. Other engineering materials and methods may be available to avoid the use of clay at landfill sites, and other sources of clay may become available from major transport projects, such as Crossrail. Much of Hampshire,


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including many existing quarries and landfill sites, are underlain by clay and, in the future, the need to use clay for landfill engineering may reduce as landfill requirements decline due to more sustainable waste management methods.

7.90 Questions about the availability of clay of sufficient quantity and quality for this purpose would be dealt with at the planning application stage as part of the “need” test in Policy DC17. It would be very difficult to estimate the amount of, and demand for, clay which meets the necessary permeability specification from existing sand and gravel workings or other sources in Hampshire with any certainty or accuracy, particularly in view of the lack of detailed information. The HMWCS favours the extraction of clay at existing sand and gravel sites, but does not preclude proposals to extract clay elsewhere for these purposes. Apart from identifying “preferred areas” for clay extraction in the adopted M&WLP and Hampshire Minerals Plan, the MWPA do not intend to identify specific sites for this purpose, largely due to the lack of interest in promoting such sites from the minerals/landfill industry. In my view, this is a soundly-based approach.

7.91 Policy DC17 sets out the criteria for permitting the extraction of clay, reflecting the approach in Policy S11 & RPG9 (¶ 11.43), and provides a sound framework for considering future proposals for extracting clay, including the use of clay for landfill engineering and other purposes. Environmental and other factors would be considered under other policies in this DPD. Consequently, I conclude that the approach of this DPD to the extraction of clay is soundly based.

Oil and gas

7.92 Policy S12 supports the exploration, appraisal and commercial production of oil and gas, except within the NFNP, continuing the approach established in the adopted M&WLP. This approach reflects national guidance in PPS7 & MPS1, which confirm that major developments should not take place in National Parks, apart from in exceptional circumstances and where they are in the public interest. Although the policy omits any references to the proposed South Downs National Park (SDNP) and AONBs, any proposed oil and gas developments in these areas would automatically be subject to Policy DC2. This confirms that major proposals which prejudice the purpose of designated National Parks and AONBs will not be permitted unless the need for the development outweighs the adverse impact and all proposals will be subject to the most rigorous examination. This broadly reflects national guidance in PPS7 & MPS1 and is consistent with RPG9 and the emerging SEP. Since oil and gas are significant in national terms, whilst sand and gravel is relatively abundant and tends to be carried out on a greater scale, I am satisfied that a different approach is justified in terms of these mineral resources.

7.93 The NFNP would be particularly vulnerable to oil and gas development, with its international/national nature conservation designations and unique environmental features. However, oil and gas is already being exploited in the proposed SDNP without undue impact, and any future proposals would be assessed against Policy DC2. Consequently, it is wholly appropriate to adopt the more restrictive approach proposed in the NFNP. Similar points apply to Policy DC19, which sets out the criteria for permitting oil and gas exploration, appraisal and production, precluding such proposals within the NFNP and reflecting Policy S12. I therefore conclude that there is sufficient local justification for the policy relating to oil and gas development and that the approach is soundly based.


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Wharves and Rail Depots

Key issue - Is the Strategy for Wharves and Rail Depots consistent with national and regional guidance, soundly based and appropriate for Hampshire & the New Forest, particularly in terms of the adequacy of provision for importing crushed rock?

7.94 Policy S13 supports the sustainable transport of minerals and waste and provides for associated rail depots, sidings and wharves. RPG9 Policy M5 requires MPAs to assess the need for wharf and rail facilities for handling and distributing imported minerals and processed materials and identify strategic sites for safeguarding. The emerging SEP encourages the use of sustainable transport for movement of minerals and waste, whilst both national and regional policy envisage an increased supply of marine-dredged sand and gravel in the future. All this points to a need to identify and safeguard the necessary facilities for handling, transporting and distributing minerals and waste materials. However, RPG9 does not set out any apportionment for the import of such materials, or identify capacity requirements.

7.95 The MWPA confirm that the HMWCS safeguards all wharves and depots for the import of crushed rock and marine-dredged sand and gravel, apart from the Port of Southampton, for which ABP is the statutory authority. This DPD does not itself identify strategic sites for wharves and depots or indicate whether present capacity will be maintained, increased or reduced, since this will be considered in a review of existing/future capacity in the subsequent Hampshire Minerals Plan. Until the results of this review are known, all existing wharves and rail depots are safeguarded under Policies S13 & S14, in line with MPS1 (¶ 13) & RPG9 Policy M5. At present, considerable quantities of crushed rock are imported into Hampshire, either by rail or via dockside wharves. Topic Paper [TP2] provides an overview of the current capacity at existing wharves, and estimates current throughput of some 2.29mtpa and a maximum capacity of 4.39mtpa.

7.96 Policies S13 & S14 provide the general safeguarding necessary for existing wharves and rail depots, without being specific. Initial work on the review of facilities confirms that existing wharves have the capacity to handle almost twice as much material as currently occurs. Future requirements, including any additional capacity necessary will be identified in the subsequent DPD, following completion of the review of existing facilities. In the meantime, the potential capacity available at existing wharves and depots will enable increased demand to be met. In my view, this strategy reflects national and regional policy (including the latest guidance in MPS1), will ensure sufficient protection of existing facilities and enable specific provision to accommodate the required capacity.

7.97 There is some concern that existing facilities will not be able to accommodate future handling and distribution of minerals, particularly the import of crushed rock at wharves in the Southampton area. Although Southampton Docks has imported considerable quantities of crushed rock into Hampshire, due to commercial considerations it now handles other materials, but the previous importer does not see the constraints over its availability as a problem. Crushed rock is also imported at other wharves and depots in the Southampton area. The HMWCS (¶ 20.6) confirms that the import of crushed rock is an invaluable aggregate mineral resource for Hampshire, particularly since it has no indigenous hard rock resources.

7.98 However, although there are no controls on the quantities of crushed rock and other materials that are imported into Hampshire, such materials do not form part of the sub-regional apportionment for the county, since it is to some extent dependent on market demand. Furthermore, there are no estimates available at county-level of the future quantity of crushed rock imports. I recognise that


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Southampton Docks is one of the few deep-water docks able to handle long vessels, but the use of this facility to import and handle crushed rock or other minerals is not directly within the MPA’s control, and largely depend on commercial considerations and operators’ needs.

7.99 I realise that Dibden Bay is allocated as a new deep-water wharf in the approved Structure Plan and adopted New Forest Local Plan (2005), which acknowledge its national and regional significance. It is also a location where deep-draught ships (such as those carrying aggregates) can be handled. However, there are no current plans to bring forward such a facility, and a similar proposal was rejected by the Secretary of State in 2003. There is no certainty that such a proposal (including an aggregates wharf) would be developed within the period of this DPD, particularly given the timescale involved, the history of this project and its potential impact on habitats, biodiversity and designated landscapes. The regional need for such a facility, including potential locations and the role of Southampton, has not been established in RPG9 or the emerging SEP. No recent assessment or EIA/SA/AA of a specific site or proposal has been undertaken, which would be needed if the site was to be highlighted or proposed in this DPD. Consequently, I find there is insufficient evidence to justify the inclusion of such a strategic proposal in this Core Strategy at this time, either as a new proposal or to offset any lack of availability of Southampton Docks. If such a proposal came forward as part of the site-selection stage in subsequent DPDs, it could be considered against the framework of this DPD, either as a proposal or an “omission” site.

7.100 In all these circumstances, particularly given the potential capacity available for importing crushed rock and other minerals at existing wharves and depots, I can see no need to identify the need for additional facilities at this stage, in advance of the detailed review envisaged in the subsequent DPD. In the meantime, there seems to be sufficient potential for the existing wharves and depots to accommodate any increased demand for additional capacity to import crushed rock and marine aggregates without the need for further facilities, deep-water or otherwise. Consequently, I cannot see sufficient justification to make specific provision for new deep-water wharves to handle long-distance transportation of crushed rock in this strategic DPD at this stage.

7.101 However, the MWPA suggest amending Policy S13 to recognise the significance of longer sea voyages for minerals, as well as short-sea shipping, since this is an important aspect of the movement of such materials. The MWPA also suggest amendments to the accompanying text (¶ 21.2) to properly reflect the existing situation. With these suggested amendments, I consider the strategic policy relating to wharves and rail depots is soundly based.

7.102 Policy DC18 supports additional infrastructure to enable sustainable transport of minerals and waste materials, including new or extended wharves and rail depots, subject to site suitability. As part of the review of wharves and depots, any new facilities would be subject to Policy S18 and the process and factors set out in Appendix 2. I am satisfied that this provides an appropriate and supportive policy framework to consider proposals for new and extended facilities at the planning application stage and in subsequent DPDs.

Recommendation 10

In order to make the Strategy sound, the following changes are required: (a) amend Policy S13 to acknowledge the need for longer distance sea shipping of minerals and waste materials; (b) amend paragraph 21.2 to more accurately reflect the existing situation in terms of import of crushed rock; (Change Nos. 28-29 in Annex A of my report).


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Safeguarding existing sites

Key issue - Is the Strategy to safeguard existing minerals and waste sites and resist development that would sterilise mineral deposits without prior extraction soundly based and consistent with national and regional guidance?

7.103 The MWPA confirm the intention to safeguard all strategic minerals and waste sites which are needed to meet future requirements, including existing, permitted and operational minerals and waste facilities, including wharves and depots, pending a review of such facilities in the Hampshire Minerals and Waste Management Plans. At present, some of these facilities are safeguarded by the adopted M&WLP and others have gained permission since adoption. Details of specific sites are listed in the core evidence [TP2/CCD89], and will be safeguarded by HMWCS Policy S14, subject to the forthcoming review of facilities. Existing mineral deposits are shown illustratively on the Key Diagram as Safeguarded Sand & Gravel Deposits. In my view, these policies broadly reflect national/ regional policy to safeguard minerals and waste sites and prevent sterilisation of known mineral deposits, as set out in MPS1 & RPG9 (Policy M5).

7.104 The MWPA suggest some amendments to Policy S14 to confirm that new minerals and waste sites identified in subsequent DPDs will also be safeguarded. The title of the policy should reflect this change by also referring to Future development. Further clarification is suggested in the accompanying text. These suggested changes would ensure that the policy is soundly based and go some way towards meeting valid points raised in the representations.

7.105 The accompanying text (¶ 22.4) confirms the scope and purpose of the review of existing minerals and waste sites, but leaves questions of the future capacity and provision of new facilities to this review. This is unfortunate, since this information should be available to guide the Strategy. However, the MWPA confirm that the review will consider the need for additional facilities to meet any increased demand for minerals and waste, including imported materials. The HMWCS gives sufficient flexibility to accommodate any additional provision in subsequent DPDs, when the review has been completed. Consequently, I am satisfied that Policy S14 will enable the needs of the crushed rock and other minerals and waste industries to be addressed in subsequent DPDs, particularly in terms of new wharf facilities.

7.106 Turning to Policy S15, this prevents proposals for incompatible/ permanent development taking place within areas of known mineral deposits without prior extraction. The MWPA suggest altering the title of the policy to refer to Mineral Deposits, consistent with national policy, and to include the areas identified in subsequent DPDs. Similar alterations are suggested to the accompanying text (¶ 22.5) and Key Diagram to confirm that the detailed boundaries of the Mineral Safeguarding Areas and Safeguarded Sand & Gravel Areas will be defined on the Proposals Map of the subsequent Hampshire Minerals Plan. Eventually these designated areas will be shown on the district councils’ LDF Proposals Maps. Although there is some confusion about the precise terminology and purpose of these areas, this is clarified in the Glossary and amended text accompanying Policy S15. This also confirms that Policy S15 safeguards areas of known deposits of both sand and gravel and brick-making clay, and covers points about commercial viability. I endorse these changes in the interests of clarity and soundness.

7.107 As for the remaining issues, by covering both existing and proposed sites and areas of search, and enabling prior extraction of minerals, where practicable and viable, Policy S15 fully reflects national/regional policy in RPG9/SEP. It applies a general presumption and precautionary approach to incompatible development, but also provides some flexibility by allowing for other planning


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considerations to be taken into account, without inhibiting other developments. Detailed questions, such as buffer zones will be considered when the precise boundaries of these safeguarded areas are finalised in subsequent DPDs. The policy uses the term resisted because the MWPA is a consultee, not the decision-maker, on most planning applications for non-minerals/waste development.

7.108 There is considerable concern and confusion about the nature and purpose of the Safeguarded Sand & Gravel Deposits identified under Policy S15 and shown on the Key Diagram. In fact, the accompanying text refers only to Mineral Safeguarding Areas, which are basically Mineral Consultation Areas in MPS1 terminology. No-one has challenged the existence of sand and gravel deposits within the safeguarded areas from a technical or geological viewpoint, and the detailed extent of these areas will be defined in the subsequent Hampshire Minerals Plan. However, to overcome any misunderstanding and ensure that the DPD is sound, I consider it is necessary to explain the purpose of these safeguarded areas in the text accompanying Policy S15. Essentially, they are broad areas of proven sand and gravel deposits which are protected from incompatible permanent development, but there is no presumption that these safeguarded deposits will actually be worked for minerals, reflecting the guidance in MPS1 (Companion Guide; ¶ 33). It is within the MRAs, within the safeguarded areas, where mineral extraction is likely to be permitted. I recommend accordingly.

7.109 Policy DC21 permits the extraction of minerals prior to development provided it does not prejudice the timetable or standards of the subsequent development. This provides the supportive framework necessary to such developments at the detailed planning application stage and is soundly based.

7.110 I therefore conclude that, with the suggested amendments, Policies S14 & S15 provide a soundly based approach to the safeguarding of minerals and waste sites and sterilisation of mineral deposits, consistent with national and regional policy and reflecting Hampshire’s circumstances.

Recommendation 11

In order to make the Strategy sound, the following changes are required: (a) amend Policy S14 and the accompanying text to include future sites identified subsequent DPDs and clarify the operation of the policy; (b) amend Policy S15 and the accompanying text to refer to mineral deposits, include future sites identified subsequent DPDs, clarify the purpose of the safeguarding areas and confirm that the detailed boundaries of these areas will be defined in subsequent DPDs; (Change Nos. 30-33 in Annex A of my report).

Location, Co-location, Systems & Infrastructure

Key issue - Is the Strategy for locating waste activities and waste management capacity alongside or within areas of major new development, and co-locating compatible minerals and waste activities soundly based and appropriate for Hampshire & the New Forest?

7.111 The general strategy of requiring major developments to provide the necessary waste management capacity on-site and locating waste activities alongside or within areas of new development is generally consistent with national guidance in PPS10 and RPG9. Such facilities could range from thermal or other waste treatment facilities to smaller facilities for recycling. The policy would bring sustainability benefits, dealing with waste close to where it is generated, and deserves support.


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7.112 Strategic waste management facilities are also needed to deliver the Strategy and are directed to two broad “areas of search” in the north-east and south of the county, in line with the emerging SEP. This reduces transportation distances, reflects the commercial realities of scale, catchment areas and site viability, enables sustainability benefits of a larger number of smaller facilities and reflects stakeholders’ aspirations in the work undertaken for More From Less. Such facilities could include large-scale energy-from-waste facilities, anaerobic digestion and MRFs. Suitable sites will be identified in the Hampshire Waste Management Plan, based on the overall figures set out in Policy S5, and initial work on this subsequent DPD indicates no shortage of potential sites coming forward. In my view, this is a soundly based approach to the provision of waste management facilities, including the strategic facilities required by the Strategy.

7.113 Although it would have been helpful to identify the full range and number of facilities required, this depends on the scale, location and type of facilities envisaged, and can be dealt with when specific proposals are considered in the subsequent DPD and when detailed planning applications are submitted. I am also aware that there is little guidance at regional level on the number and type of facilities required.

7.114 There is some concern about the implications for Aggregate Recycling Facilities (ARF), but such facilities would probably not be appropriate within or adjoining major developments. In terms of the general location for such facilities, the two “areas of search” would be relevant, since some ARFs could be strategic in scale. There are also likely to be sustainability and other benefits in co-locating such facilities next to other minerals and waste activities, as set out under Policy S17. These criteria, along with the other locational criteria outlined in the amended text accompanying Policy S8, would be relevant to ARFs. I therefore consider the DPD adequately recognises the particular requirements of ARFs, without the need for a separate policy.

7.115 The MWPA suggest some amendments to the text accompanying Policy S16 to clarify the policy and the role of the subsequent DPDs. I endorse these changes in the interests of clarity, consistency and soundness.

7.116 Turning to Policy S17, the strategy of co-locating compatible minerals and waste facilities in order to increase resource recovery and efficiency in terms of handling, transfer and collection of waste materials is also consistent with national policy in PPS10. ARFs are an example of such a facility which could fall within this policy. The MWPA suggest minor changes to the examples of co-location (¶ 23.8), to clarify the role of sewage treatment facilities, and I endorse these changes in the interests of clarity, consistency and soundness.

Recommendation 12

In order to make the Strategy sound, the following changes are required: (a) amend the text accompanying Policy S16 (para 23.2) to clarify the location of strategic facilities; (b) amend the text accompanying Policy S17 (para 23.8) to recognise the possibility of locating organic waste recycling/composting facilities at existing sewage treatment works; (Change Nos. 34-35 in Annex A of my report).


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Site Selection

Key issue - Is the approach to identifying sites and locations for minerals and waste development soundly based and consistent with national and regional guidance?

7.117 Policy S18 confirms that sites and locations for minerals and waste development required by this DPD will be identified in subsequent DPDs using the methodology and factors set out in Appendix 2. The MWPA confirm that potential sites will be based on a review of existing and safeguarded mineral and waste sites, including “time-limited” sites and wharves and depots, and potential sites coming forward as a result of work and representations made at the Issues & Options stages of the Hampshire Minerals and Waste Management Plans.

7.118 All potential sites will be subject to screening and detailed assessment using the methodology in Appendix 2, including SA, AA and Flood Risk Assessment, where necessary. Several work streams are involved and ongoing, and detailed options and proposals will be discussed and consulted upon as the subsequent DPDs are prepared. The MWPA suggest some minor amendments to the text accompanying Policy S18, along with the methodology and factors in Appendix 2, to clarify the approach. The selection of sites for waste management facilities will also have to take account of the locational criteria in RPG9 Policy W17. Having examined the basic site-selection process, I am satisfied that, as amended, it broadly reflects national policy in PPS10 & MPS1 and is clear, comprehensive and soundly-based. In my view, it represents a consistent and transparent way of selecting and delivering the required sites for minerals and waste developments.

7.119 The site-selection procedure will include a review of all wharves and depots to consider their suitability for expansion, including landing of crushed rock from deep-draught vessels, as clarified in the MWPA’s suggested change. This process should adequately address the future provision of these types of facilities, without the need to identify any specific sites or areas at this stage in this DPD. Paragraph 24.4. (as amended) confirms the type of small-scale minerals and waste activities that will be considered in National Parks & AONBs, consistent with national policy, and impact on these designated landscapes is specifically covered in the site-selection factors.

7.120 The MWPA confirm that the site-selection process will give preference to sites within the various “areas of search” for Strategic Facilities, MRAs and LPAs. This should be made clear in the note accompanying the site factors in Appendix 2. In addition, there is no explicit reference to traffic and highways implications in the site factors. Since this may be a relevant factor, along with proximity to the Minerals & Waste Lorry Routes, it should be made clear in the table of site factors in Appendix 2. With these recommended amendments, the site-selection process will be consistent, comprehensive and soundly based.

Recommendation 13 In order to make the Strategy sound, the text and tables in Appendix 2 should be amended to clarify the site-selection process and factors to be considered, including giving preference to sites within the relevant “areas of search”. (Changes Nos. 54-55 in Annex A of my report).


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Development Control

Key issue - Are the Development Control Policies most appropriate in all the circumstances, founded on a sound, robust and credible evidence base, and consistent with national and regional guidance and other policies in this DPD?

7.121 In this section, I deal with the Development Control policies not covered earlier in my report. This suite of policies sets out the approach the MWPA will take when considering planning applications for minerals and waste development.

7.122 Firstly, I can see no need for any caveats on some of the policies about the need to consider environmental, economic and social factors. All the policies have to be considered “in the round”, as confirmed in this DPD (¶ 25.1), and a further reference in each relevant policy to these factors is unnecessary.

7.123 Secondly, the MWPA have suggested several minor changes to the wording of the some of the policies and the accompanying text. These changes address relevant points made in the representations and help to ensure that the DPD is sound. I endorse all of these changes, including those suggested before and during the hearings, except where I indicate otherwise below.

7.124 Thirdly, many of the representations do not question the soundness of the policies, but seek to “improve” the wording of an otherwise sound policy. This is not the purpose of the examination under the new LDF system and, where the policy is sound, there is no need to consider any suggested changes which might make it “sounder”.

7.125 Policy DC1 complements Strategic Policy S1 in terms of design and construction standards to provide sustainable minerals and waste development, with criteria set out in the accompanying text. These requirements reflect good practice and the policy has a sound basis.

7.126 Policy DC2 protects sites with international and national designations from development which would prejudice their purpose. This is a key policy which relates not only to protected nature conservation sites, but also to National Parks, AONBs, SSSIs, Ancient Monuments, Listed Buildings and Conservation Areas. The MWPA suggest adding a reference to cover the settings of all such sites and areas, which would bring the policy into line with PPS9 & MPS1. Conservation Areas are locally designated areas, so should not feature in this policy or in the accompanying text. Other changes are suggested to the accompanying text, to clarify the application of the policy and address specific points made in the representations which relate to soundness, and which I endorse.

7.127 Although the policy does not specifically acknowledge the distinction between the acceptability of minerals and waste developments within various designated areas outlined in MPS1, PPS7, PPS9 & RPG9, the reference to the requirements of relevant legislation and guidance would ensure that this distinction would be applied. The text makes specific reference to the need for Appropriate Assessment under the Habitat Regulations, which is sufficient given that this is covered in other legislation. I recognise that not all mineral extraction may be incompatible with designated sites, particularly if restoration sympathetic to the needs of particular habitats takes place. However, it is reasonable for the MWPA to identify spatial preferences for such development in a precautionary way, which reduces the risk to sensitive habitats and landscapes. The policy could accommodate such circumstances as part of the rigorous examination of proposals in these designated areas. Protected species are not designated sites as such, and are covered by Policy DC7. No further changes are needed in terms of the soundness tests.


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7.128 Policy DC3 addresses the impact of minerals and waste development on the landscape and townscape, particularly in terms of visual impact. This is soundly based and uncontentious.

7.129 Policy DC4 protects sites of historic, archaeological and architectural importance and their settings. It provides an appropriate level of protection, relative to the more important designated sites in Policy DC2, and provides sufficient consideration of the effect of development on the historic environment in a sound, succinct and coherent manner.

7.130 Policy DC5 sets out the policy for minerals and waste development in the Green Belt. The MWPA suggest minor changes to the policy to add clarity, and delete the reference to Strategic Gaps, with consequent changes to the accompanying text. This would ensure that the policy is consistent with national policy in PPG2. Time-limited minerals and waste operations can be acceptable in the Green Belt, and the amended wording properly reflects this situation. Mineral extraction and consequent landfill can be permitted in the Green Belt, as confirmed in national and regional guidance, and some waste management activities may also be acceptable, as confirmed in PPS10 (¶ 3). The impact of sand and gravel extraction on businesses and employment sites can be considered at the detailed stage.

7.131 Policy DC6 aims to minimise the impact of road transport of minerals and wastes. There is some concern about additional traffic from minerals and waste developments, especially heavy goods vehicles, on the road network, particularly with current congestion. The traffic implications of such developments would be considered at the detailed stage, when sites are allocated or permitted, as part of a full Transport Assessment. I recognise that Hampshire experiences traffic congestion, especially at peak times, but the policy specifically refers to this as one of the issues to consider. Paragraph 25.29 confirms that minerals and waste developments should have good access (normally within 2km) to the designated Minerals & Lorry Routes shown on the Key Diagram, and this is a key factor in the site-selection process outlined in Appendix 2. There is some criticism of these designated routes, but they largely reflect the strategic road network identified in the LTP [LCD04], along with other routes used by lorries serving existing minerals/waste sites, and link into the national/regional freight route network. In my view, Policy DC6 provides a sound basis to assess the highways and traffic implications of minerals and waste developments.

7.132 Policy DC7 deals with the impact of minerals and waste developments on biodiversity, and is broadly consistent with national guidance in PPS9 & MPS1. Although the policy does not specifically refer to the need for mitigation and compensatory measures, this is a key element of national policy in PPS9 (¶ 1(vi)) and does not need to be repeated in the policy. However, a reference to the need for possible mitigation and compensatory measures should be included in the accompanying text, to alert readers to this possibility. Policies DC2 & DC7 distinguish between the various levels of importance of nature conservation sites, consistent with PPS9, without deflecting from the aim of protecting biodiversity. Policy DC7 confirms that development may be permitted on regionally/locally designated sites if its merits outweigh the likely impact, and also specifically refers to protected species. Policy DC12 provides opportunities to enhance biodiversity as part of restoration, but a cross-reference is not essential in Policy DC7. Apart from the recommended changes, no further amendments are necessary to ensure that Policy DC7 is sound.

7.133 Policy DC8 covers the impact of development on pollution, health, quality of life and amenity. It covers the impact on all sectors of society, including not only local residents, but also those in other sensitive properties such as businesses and hospitals. The MWPA suggest adding a reference to the


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cumulative impact of previous and existing waste facilities, which would bring the policy fully into line with PPS10. However, minerals development should also be added, to reflect the guidance in MPS1 (¶ 14), whilst recognising that minerals can only be worked where they occur.

7.134 Policy DC9 covers minerals and waste developments in public safety zones, such as Aerodrome Safeguarding Zones, and is relatively uncontentious. The detailed site-selection process would cover the impact of proposals on sensitive receptors, such as business premises and airfields.

7.135 Policy DC10 safeguards major aquifers, Groundwater Source Protection Zones (GPZ), and coastal, surface and ground waters. However, the policy needs to be amended to reflect the suggested changes to paragraphs 18.13 & 20.16 of the HMWCS, which confirm that non-hazardous landfill developments will not be permitted where they overlie major aquifers and are within GPZ I, II & III, in line with the latest guidance in PPS25. I recommend accordingly.

7.136 As submitted, Policy DC11 does not reflect the latest guidance in PPS25. Consequently, the MWPA suggest an amended policy and revised text which would be consistent with the latest national guidance. I endorse these suggested changes. As for the concern about sewer flooding, this is implicit within the general context of the policy and within national guidance, and so there is no need to amend the policy further.

7.137 Policy DC12 covers the restoration and aftercare of mineral and landfill sites, listing the objectives that should be met and other requirements. There is some concern that the timescales for aftercare do not accord with those of the Environment Agency. Policy DC12 requires aftercare provision for at least five years after restoration, which reflects the guidance in MPG7 (¶ 58(iv)/65) which confirms that five years is the current maximum period, although this can be varied or extended. The Environment Agency’s aftercare requirements differ both in scale and requirements from the planning regime, and are secured through separate legislation via the PPC regime. The MWPA suggest additional text to cover these complementary regimes, which will adequately address these concerns. The issue about the need for back-up grazing in a wider context can be overcome by deleting specific reference to the New Forest in clause (d) of the policy. I recommend accordingly.

7.138 Policies DC20, DC21 & DC22 deal with Borrow Pits, Prior Extraction of Minerals and Additional Plant, Buildings & Equipment. They complement the core policies in the Spatial Strategy, without conflicting with their aims, and broadly reflect national and regional policy. No changes are needed to these policies to meet the soundness tests.

7.139 Policy DC23 covers Local Development Orders. The MWPA suggest a minor change to the accompanying text to exclude Schedule 1 EIA development, in order to reflect the latest guidance in Circular 1/2006. This would ensure that the policy is up-to-date and sound.

7.140 With the suggested and recommended changes, I conclude that these development control policies provide a sound basis for considering minerals and waste development proposals over the period of the Strategy.

Recommendation 14 In order to make the Strategy sound, the policies and text in the Development Control section should be amended in accordance with the changes outlined above (Changes Nos. 36-47 & 51 in Annex A to my report).


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Key Diagram

7.141 The Key Diagram is an illustrative, diagrammatic indication of key elements and spatial principles of the Strategy. The MWPA confirm that it should not be used to identify individual sites and that the detailed boundaries of the Safeguarded Sand & Gravel Deposits, MRAs & LPAs will be defined on an OS base map in the subsequent Hampshire Minerals Plan. This clarification should be added to the text of the DPD and Key Diagram, as suggested. A revised Key Diagram has been produced, giving a graphically clearer presentation, which should be used in the final version of the DPD. The MWPA also suggest some minor amendments to the Minerals & Waste Lorry Routes (including the A337 from Lyndhurst-Cadnam), and have incorporated information from the latest flood risk data, making very minor alterations to the extent of some of the “areas of search”. Other minor changes to the legend to reflect the amended title of some of the areas are also put forward. I endorse all these suggested changes.

7.142 Detailed Proposals Maps will be produced in the subsequent Hampshire Minerals and Waste Management Plans, and eventually incorporated into the relevant district councils’ DPDs. Since there is no Proposals Map at present, the policies cannot make reference to a subsequent plan. A more detailed or larger-scale Key Diagram is unnecessary, given its purpose and since more detailed Proposals Maps will follow later. The “area of search” for Strategic Facilities in the north-east of the county does cover part of the Thames Basin Heaths SPA, but this covers only 10% of the total area. No site-specific proposals are made in this DPD and the detailed impact on the SPA will be dealt with at the site-selection stage if sites are proposed which might affect this protected area.

7.143 The Key Diagram appropriately shows internationally and nationally designated sites, including existing and proposed National Parks, AONBs and the Green Belt. These and other smaller-scale sites will be shown on subsequent Proposals Maps. I therefore conclude that the Key Diagram, as amended and included as Annex C to my report, would appropriately indicate the key elements of the Core Strategy.

Recommendation 15 In order to make the Strategy sound, the Key Diagram and paragraph 29.1 should be amended in accordance with the changes outlined above (Changes Nos. 52 & 56 in Annex A & Annex C of my report).

Area-based issues

7.144 A large number of representations have been received about the implications of the HMWCS on two particular areas of the county, at Bordon in the east and Walkford Farm/Roeshot in the south-west. Many of the representations relate to detailed site-specific matters, but for this Core Strategy, I only need to consider the principle of the various designations that might affect these areas.

Bordon

7.145 There are several designated areas around Bordon. A broad area of Safeguarded Sand & Gravel Deposits covers an arc to the north, west and south of the settlement, within which is a Mineral Resource Area (MRA). A smaller area of sand and gravel deposits, with a MRA and Landfill Potential Area (LPA), lies mainly to the east of the settlement. No-one challenges the existence of sand and gravel in these areas on technical or geological grounds. The main concerns relate to the impact of the safeguarded areas on existing and future development proposals and the impact of possible landfill sites, particularly given the presence of major aquifers and nature conservation sites.


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7.146 The MWPA confirm that the designations around Bordon shown on the Key Diagram are illustrative and reflect the latest hydrogeological information. The MRA excludes protected nature conservation sites and GPZ I, whilst the LPA additionally excludes all major aquifers and GPZ II & III. These areas would also be protected by Policies DC2, DC3, DC7, DC10, DC14 & DC15. The Environment Agency confirms that the criteria for designating MRAs/LPA are soundly based and the areas are correctly drawn on the Key Diagram. The Safeguarded Sand & Gravel Deposits identify and protect areas of proven mineral deposits from sterilisation by permanent development, and mineral extraction would only be expected within the MRAs or where new development is proposed.

7.147 The precise boundaries of these designations will be defined in the subsequent Hampshire Minerals & Waste Management Plans, and future sites will be selected using the criteria and process set out in Policy S18 and Appendix 2. At that stage, detailed boundaries, proximity of nature conservation and other protected sites, boreholes, watercourses, ground water protection, buffer zones from existing development and other relevant factors will be considered. Locally designated nature conservation sites would be protected by Policy DC2. The detailed impact of proposed mineral working and landfill sites will also be addressed at this stage, along with the cumulative impact of such developments on the community. The detailed operational aspects of existing and future landfill sites are outside the remit of this strategic DPD, and are covered by normal planning and waste management regimes. The impact of safeguarded sand and gravel deposits on potential development areas on former MOD land will be addressed under Policies S15 & DC21 when firm proposals are drawn up.

7.148 In these circumstances, I am satisfied that the principle of the various designations around Bordon is soundly based and the specific concerns of local residents about the detailed implications and impact of proposed minerals and waste developments will be fully addressed in subsequent DPDs.

Walkford Farm/Roeshot

7.149 Similar considerations apply to this area, where various designations apply. There are several areas of Safeguarded Sand & Gravel Deposits in the New Milton/Highcliffe/Walkford area, within which are MRAs & LPAs. The main concerns relate to the detailed impact of mineral working and subsequent landfill on specific sites in this area, particularly on traffic, amenity, nature conservation, hydrology, public health, landscape and tourism grounds.

7.150 No-one has challenged the presence of sand and gravel deposits in these areas, which have been previously identified in the adopted M&WLP. The areas of Safeguarded Sand and Gravel Deposits do not imply that mineral working will take place throughout these areas, but protect proven deposits from incompatible development. No specific sites for mineral working or landfill are proposed in this DPD. The designation of MRAs/LPAs does not imply that mineral extraction and/ or landfill will necessarily take place, since these are illustrative “areas of search”. Provided that the existing “preferred areas” in the adopted M&WLP are granted planning permission, there is no requirement for further sand and gravel sites in the Forest sub-area until after 2016. Future mineral extraction and possible subsequent landfill will depend on need, sustainability and suitable sites being identified and coming forward. At this time, questions about cumulative impact and the balance of provision between the various supply areas will also be considered. The Environment Agency confirms that there are no major aquifers or GPZs in this locality, existing watercourses and boreholes would be protected, and the general extent of the MRAs/LPAs has been correctly drawn. Public health, amenity, quality of life and water sources would be protected by Policies DC8 & DC10, along with the PPC regime.


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7.151 The detailed impact of particular minerals and waste developments will be addressed when specific sites are assessed and proposed in the subsequent DPDs as part of the site-selection process outlined in Policy S18 and Appendix 2. The impact of any additional traffic on the existing road network, and the impact on local amenity and public health, hydrology, land uses, environment, economy and tourism, along with buffer zones, will be considered when specific sites are assessed under Policy S18 & Appendix 2. In response to the concerns about the impact on the Woodland Burial Ground, the MWPA suggest adding burial grounds to the list of sensitive receptors in Appendix 2.

7.152 There is some criticism of the designated Minerals & Waste Lorry Routes in this locality, but these reflect the strategic road network set out in the LTP [LCD04] and routes currently used by heavy vehicles, including the routes through Lyndhurst. They also link into the national and regional freight route network shown in the draft South-West Plan. The detailed impact of traffic associated with minerals and waste proposals, including the impact of traffic on the roads in Dorset and lorries travelling through the New Forest, and the impact of traffic on roads which are often running at capacity and congested at peak times, will be addressed at the detailed stage when potential sites are being assessed. The possible limitations of the existing road network do not justify deleting any of the broad “areas of search” for mineral working and landfill from the Key Diagram. The implications of proven sand and gravel deposits, possible mineral working and landfill sites on proposed or potential housing sites at Roeshot Hill will also be considered at this stage. The current proposal at Downton Manor Farm will be considered at a planning appeal and at the site allocation stage.

7.153 None of these factors rule out the principle of these broad areas being designated for sand and gravel working and possible future landfill at this stage and there is insufficient evidence to justify their deletion from the Key Diagram. Consequently, I am satisfied that the principle of these various designations in the New Milton area is soundly based and the specific concerns of local residents about the detailed implications and impact of any subsequent minerals and waste developments proposed will be fully addressed in subsequent DPDs.

Other areas

7.154 Similar points have been raised about the extent of these designations in other areas of the county, but I am satisfied that the principle and general extent of these various “areas of search” and designated areas is soundly based and correctly drawn.

Issues arising from incorporation of Wiltshire Area of the New Forest National Park into the Core Strategy

7.155 I have dealt with the procedure and conformity issues relating to the incorporation of the Wiltshire area of the NFNP in earlier sections of my report. In terms of the policies to be applied within this area, the restrictive approach towards minerals and waste developments would be the same as that applicable to the rest of the National Park and covered by Policy DC2. Apart from areas of Safeguarded Sand & Gravel Deposits and areas of International/National Environmental Constraints, there are no other area-specific designations that affect this part of the NFNP, although there is an existing minerals/landfill site at Pound Bottom. There is no evidence to question the applicability of the strategic and development control policies set out in the HMWCS to this part of the NFNP.

7.156 The MWPA suggest several amendments to the text, appendices and Key Diagram of the submitted HMWCS as a result of extending the Strategy to incorporate the remaining part of the NFNP. These changes are needed to ensure that the HMWCS is sound in this regard, and I endorse them.


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Recommendation 16 In order to make the Strategy sound, the text and Key Diagram should be amended to reflect the incorporation of the Wiltshire area of the New Forest National Park (Changes Nos. 1-2, 9 & 53 in Annex A to my report).

General conclusions on soundness test 7

7.157 I therefore conclude that, with the necessary amendments to the policies and text recommended, this soundness test would be met.

Test 8 - Implementation and monitoring

8.1 The key issue in terms of soundness is whether the HMWCS contains sufficient realistic and achievable targets, indicators and milestones to monitor the performance of the Strategy and its policies, with clearly identified delivery mechanisms and timescale.

8.2 Appendix 3 of the HMWCS sets out a Monitoring Plan, with a wide range of “core” and “local” output indicators and targets related to each policy in the Strategy, many of which directly reflect national monitoring core indicators for minerals and waste. The latest AMR [CCD89] also outlines the framework for monitoring this DPD, summarising the various output indicators and the procedure for monitoring. Further local indicators will be developed as the plan-making process continues with subsequent DPDs. Appendix 4 sets out an Implementation Plan, outlining the mechanisms and actions necessary to implement the Strategy for each of the core policies, along with the main agencies and supporting bodies responsible. It also reflects some of the actions included in the Joint Municipal Waste Management Strategy [LCD05] and the mitigation measures suggested in the SA reports.

8.3 In my view, the monitoring and implementation arrangements for the HMWCS are comprehensive, realistic and achievable, and are consistent with the latest national guidance on measuring the performance of DPDs. I therefore conclude that this soundness test has been met.

Test 9 - Flexibility

9.1 The HMWCS has some distinct elements of flexibility to help it take account of changing circumstances. Many of the policies are written in a generic manner, which enables them to be applied across a variety of sites and situations to provide a robust and consistent framework for considering planning applications and site allocations. None of the policies relate to specific sites, but can be applied to such locations at the site-specific and site allocation stages. Those policies which include figures or targets have a degree of flexibility, but indicate where they may need to be changed when further guidance or higher-level policies are available (such as RPG9/SEP when finally approved and revised regional aggregate apportionment figures). The policies provide some flexibility with the geographic split between different areas of Hampshire and the broad areas of search within which detailed provision sites and facilities will be made.

9.2 The SA previously undertaken assesses many options, so if it becomes necessary to amend the preferred option, others have already been assessed to provide an awareness of the sustainability implications of any alternative strategies if circumstances change. Subsequent DPDs will provide a greater degree of detail about the precise location of minerals and waste management facilities, backed up by further SPDs, where necessary.

9.3 I therefore conclude that this soundness test has been met.


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Other Matters & Issues

10.1 Having considered the content and style of the Core Strategy against the key elements set out in PPS12, I am satisfied that it includes all the relevant elements. Further detailed policies and proposals would be more appropriately included in subsequent DPDs, resulting in a package of LDF documents which addresses all relevant aspects of minerals and waste management in Hampshire and the New Forest, reflecting the specific issues relevant to the area.

10.2 There is some concern about the level of commitment which will be needed to implement the Strategy, and the need to win over the “hearts and minds” of all those responsible. The participation of the public and other stakeholders is clearly needed in improving waste recycling rates and minimising resource consumption, and the Strategy (including Policies S1 & S2 and the Implementation Plan) provides a framework for this to take place. If the various targets are not achieved, this will be addressed in the AMR. In a resource-based holistic approach, where there are close relationships and synergies between minerals and waste developments, I am also satisfied that it is appropriate to produce a combined minerals and waste Strategy.

10.3 Some representations raise issues which go outside the context and purpose of the Core Strategy, because they relate either to detailed elements of policies or to matters outside the scope of the document. Others submitted information about specific sites to support their arguments, but the Strategy does not cover specific sites and I cannot make any recommendations about particular sites or developments.

10.4 Some points raised in the representations are not directly related to the tests of soundness or are not central to my conclusions on the overall soundness of this DPD. In some cases, the MWPA have suggested some minor changes to the wording of policies and accompanying text to reflect relevant suggestions and points made in the representations or at the hearing sessions, and to clarify various matters, correct errors and amend the grammar. Whilst some of these suggested changes do not go to the heart of the soundness of the Strategy, they will assist in understanding the operation and application of the policies, and help in the interpretation of various definitions. I endorse these suggested changes.

10.5 I have considered all the other points made in the representations, even though they might not relate directly to the tests of soundness, but I find no justification for any further changes to this DPD.

Recommendation 17 I endorse the remaining minor changes to the content of the policies, text and appendices suggested by the MWPA, in the interests of clarity, consistency, grammar and accuracy, including new and amended definitions in the Glossary (Change Nos. A-P in Annex B to my report).

Overall conclusions

11.1 I therefore conclude that, with the recommended amendments set out in the Annexes to this report, the Hampshire Minerals & Waste Core Strategy satisfies the requirements of s20(5)(a) of the 2004 Act and the associated Regulations, is sound in the context of s20 (5)(b) of the 2004 Act, and meets the tests of soundness in PPS12 (¶ 4.24).

Stephen J Pratt

STEPHEN J PRATT Inspector