Local plan scoping consultation

Dear Sir/Madam,
RE: Representations on behalf of Tarmac Trading Limited to the new Cheshire East
Local Plan Scoping Consultation
This letter of representation has been prepared in response to the Cheshire East New
Local Plan Scoping Consultation, on behalf of Tarmac Trading Limited (‘Tarmac’).
Tarmac is keen to engage at this stage of plan making to highlight as early as possible
the importance of mineral resource, minerals development, and mineral safeguarding in
the new Local Plan.
Tarmac is one of the UK’s leading sustainable building materials companies with
innovative products, solutions, and services that not only deliver the infrastructure
needed to grow the UK economy but also enable a more sustainable built environment
for the country’s long-term future.
Within Cheshire East, Tarmac has several mineral interests, including:
• Eaton Hall Quarry
• Gawsworth (Readymix plant)
• Middlewich Asphalt
Since the commencement of the scoping consultation for the new Cheshire East Local
Plan, the Government has published the new National Planning Policy Framework
(NPPF) (2026). In the making of the new local plan, the Council should ensure it reflects
the key principles set out in the new NPPF plan-making policies.
Tarmac Comments to Cheshire East Scoping Document (2026)
As identified in paragraph 5.77 of the Cheshire East Scoping Document, national policy
requires plans to maintain a sufficient (and timely) supply of minerals of national and
local importance, of which aggregates and industrial minerals are identified. The AMPS
2025 details that the rate at which new reserves of sand, gravel and crushed rock are
being permitted or replenished is continuing to fall, and so Cheshire East should take a
proactive approach in planning for mineral supply in the new Local Plan, as a
maintained supply of aggregates is essential.
The national importance of mineral resources is recognised in Chapter 11 of the NPPF,
and facilitates the sustainable use of minerals, as they play an essential role in the
development of our built environment, through the delivery of housing, infrastructure,
buildings, and green energy.
Tarmac supports Cheshire East Council’s transition away from fossil fuels in
accordance with national policy and supports their focus on sustainable minerals, in an
aim to boost the aggregate sand and gravel provision which is currently below national
policy requirements.
To ensure that boosting the aggregate sand and gravel provision remains achievable, the
preparation of the local plan should be underpinned by relevant and up to date
evidence, with the council having regard to National Policy PM7: Initiating plan-making
for local plans and minerals and waste plans, which states that:
1. Prior to initiating the preparation of a local plan or minerals and waste plan,
planning authorities should, with reference to national guidance, design an
approach to preparing and adopting the plan within 30 months. This should
involve:
a. Setting realistic timings for key milestones and reflecting these in the
local plan or minerals and waste plan timetable, which thereafter must be
updated at prescribed points;
b. Identifying how the plan and associated documents will be signed off
expediently and efficiently at appropriate points in its development; c.
Using a project initiation document to develop and collate key information
about how the plan will be resourced, managed and consulted on
throughout its preparation; and
d. Planning regular engagement with key stakeholders who are likely to be
critical to the delivery of the plan.
2. When considering the scope of a local plan or minerals and waste plan,
planning authorities should use their four-year plan evaluation report (or other
relevant monitoring information, where necessary) to identify and consider what preexisting plan policies and content should be wholly replaced, amended or
carried forward without change, though all elements will be subject to
consultation and examination.
As such, in accordance with Policy PM7, the council should ensure that key milestones
within the local plan timetable are realistic, and with the use of a project initiation
document should develop and gather evidence on how the plan will be managed.
The council should also have regard to Policy PM8: Evidence for plan making which sets
out that:
‘All plans should be informed by a baseline understanding of the needs,
opportunities, constraints and wider context of the area to which they relate. The
preparation of plans should then be shaped and underpinned by information and
data that is: relevant to the matters being considered in the plan; proportionate,
so that it is focused and not unnecessarily extensive; and drawn from suitable and
reliable sources that are sufficiently up-to-date.’
The Planning Practice Guidance for Plan-Making (Paragraph 038, Reference ID 61-038
20190315) supports this, stating that policies must be justified, and any evidence should
inform what is in the plan and shape its development, rather than being collected
retrospectively. As the new Local Plan will include minerals policy and therefore replace
the current Cheshire Replacement Minerals Local Plan 1999, robust minerals-specific
evidence should be provided to justify future minerals policies and to shape the spatial
strategy. Without this, the Council risk the potential of boosting the provision of sand and
gravel in the area, which is necessary to achieve the mandatory seven year landbank.
On this basis Tarmac supports the need to establish a minerals-based strategy based on
an understanding of Cheshire East’s mineral resources, future demand, and
environmental and community constraints affecting extraction, as set out in paragraph
5.76.
National Policy M1: Planning for a sufficient supply of minerals requires Local Authorities
to provide a sufficient and timely supply of minerals of national and local importance,
which in relation to aggregate minerals means using the Local Aggregate Assessment and
advice of the Aggregate Working Parties to identify the provision needed in the plan area.
Policy M1 also states that the development plan should allocate sites and/or identify
preferred areas to maintain this provision. Paragraph 5.78 however identifies that several
minerals resources within Cheshire East have limited future potential, and 5.80 states
that the authority are currently struggling to meet national policy requirements for sand
and gravel and crushed rock. Taking this, and the regional trend of decline of reserves into
account, Tarmac supports the council’s approach to identifying minerals sites for the
new Local Plan through the call for sites, and stress the importance that the Local Plan
must be clear in its intention to provide a steady and adequate supply of mineral resources to maintain its required aggregate landbanks and to safeguard existing mineral
sites and infrastructure, in accordance with national policy and Cheshire East’s role as
an MPA.
The importance of mineral safeguarding has been carried through in the new NPPF under
Policy M2: Safeguarding mineral resources and infrastructure through plan-making,
which states that development plans should define mineral safeguarding areas and
mineral consultation areas to support the safeguarding of mineral resources, and identify
existing, planned, and potential sites which need to be safeguarded for: the bulk
transport, handling and processing of minerals; the manufacture of concrete and
concrete products; and the handling, processing and distribution of substitute, recycled
and secondary aggregate material. Tarmac supports that the local plan must identify
Mineral Safeguarding Areas in accordance with national policy, and in the context of
Cheshire East’s need to boost sand and gravel provision, and identify crushed rock
aggregate opportunities.
As established, currently Cheshire East’s aggregate minerals reserves are currently lower
than the national requirement, and therefore Tarmac stress the importance that the
safeguarding of minerals resources is not compromised during the allocation of housing
to meet the significant housing growth targets. Policy M2(b) of the NPPF 2026 is directly
relevant in this regard, as it requires policies and allocations in development plans to
ensure that minerals resources are not needlessly sterilised by non-mineral
development. This is necessary because minerals are a finite and location-specific
resource: they can only be worked where they occur, and once land is sterilised by
incompatible development, the opportunity to recover that resource may be
permanently lost.
As set out in Policy P4: Impact of development on existing activities, proposed
development is required to identify the potential impacts on existing operations and
where necessary, demonstrate that suitable mitigation can be provided. This is also
known as the Agent of Change principle. Additionally, it recognises the importance of
taking into account both the current and permitted levels of operation of existing
activities. Therefore, careful consideration should be given to the proximity of existing
permitted sites and their uses when considering the appropriateness and delivery of new
allocations as mineral working and mineral infrastructure can be incompatible with
sensitive land uses such as housing.
Mineral resources, products, and infrastructure underpin the ability to deliver housing
developments. Without the adequate safeguarding of mineral resources and mineral
infrastructure, the plan would be unable to meet housing growth and development
objectives over the plan period. Consideration should therefore be given to the wording
of local plan policies to ensure they are justified and effective, and do not impose
unnecessary blanket restrictions or constraints on existing minerals development.
Conclusion
In consideration of the above, Tarmac considers it important that the emerging local plan: - - - - -
Provides sufficient and timely supply of mineral resources;
Maintains required aggregate landbanks;
Defines and reviews mineral safeguarding areas and mineral consultation areas;
Safeguards mineral infrastructure including concrete, asphalt, and aggregate
facilities; and
Ensures that future allocations do not unnecessarily sterilise mineral resources or
prejudice existing operations
As indicated above, the Plan must be clear in its intention to provide of a steady and
adequate supply of mineral resource, to maintain its required aggregate landbanks and
to safeguard existing mineral sites/infrastructure.
We trust that these comments made are helpful to you in progressing the preparation of
the emerging draft Plan. Should you wish to discuss any of the matters raised in more
detail, please do not hesitate to contact me.