Government housing ambitions are undermined by the absence of “effective and timely” monitoring data relating to the basics of building, a Commons committee has heard.
The Mineral Products Association (MPA) told the Public Accounts Committee (PAC) that the absence of a consistent baseline position to refer to, the planning and management of mineral provision is having to draw on a range of alternative data sources, which can often be out of date, inconsistent or incomplete.
MPA is the trade association for the aggregates, asphalt, cement, concrete, dimension stone, lime, mortar and silica sand industries.
It’s response to the PAC inquiry ‘Planning and the broken housing market’ is outlined in newly published committee papers.
Essentially, MPA warns that delivery of a sustained increase of housing is not just an issue for the operation of the housing aspects of the land-use planning system, but will require a parallel focus on the effectiveness of the mineral planning system.
This to ensure that mineral products – as the most significant element of the housing supply chain – are readily available from UK sources to enable the sustainable and cost effective construction of future homes and associated infrastructure.
24housing first flagged the issue in 2017, with government accused of complacency over aggregates.
The previous year, the industry supplied £18bn worth of materials and services to the economy and was the largest supplier to the construction industry, which had annual output valued at £152bn.
Overall, industry production represents the largest materials flow in the UK economy and is also one of the largest manufacturing sectors.
While the MPA welcomes the revised National Planning Policy Framework (NPPF) recognising a sufficient supply of minerals is essential, it stresses that minerals provision should not be siloed as a concern only for mineral planning authorities.
It is, the MPA says, equally important that local planning authorities properly understand and appreciate that the delivery of housing commitments is dependent on a steady and adequate supply of raw construction materials.
Statements of common ground should, the MPA says, provide a mechanism by which authorities must jointly plan and provide for minerals, rather than assuming supply from elsewhere, and so provide more certainty over future supply.
Given the National Audit Office conclusion that the delivery of new-build housing will need to increase by 69% to meet Government’s ambitions – from a baseline position of 177,000 new homes being built on average – the MPA sees an equivalent increase in the demand for construction materials.
Drawing parallels with the buffers imposed on housing provision, there is currently no policy requirement under the NPPF to apply similar ‘buffers’ for aggregate provision in Minerals Local Plans – based on Local Aggregates Assessments – in order to account for the risk of under-supply and provide necessary flexibility to account for market fluctuations.
Levels of planned provision for minerals in Minerals Local Plans are based on Local Aggregates Assessments (LAAs), all but a very small number of which rely on past sales over 10 years as a means of forecasting future demand.
To the MPA, the inherent problem and risk in looking backwards to plan forwards is a self-fulfilling cycle of decline, with fewer minerals sites being allocated and permitted and sales decreasing, resulting in a medium to long-term risk of shortage of construction materials.
The MPA’s own series of Annual Mineral Planning Survey reports have shown a decline in the permitted reserves of land-won sand and gravel over the last decade, with a replenishment rate of just 54% since 2008.
Aggregate Working Parties (AWPS) are charged with ‘scrutinising’ LAAs, providing an overview of demand, reserves/landbanks and whether adequate provision is being made for minerals supply in each region.
The MPA says very few LAAs actually include the ‘forecast of demand’ required by NPPF – acknowledging this as difficult, especially at planning authority level and with limited resources and expertise.
Also acknowledged is the “politically expedient” reliance on the historic 10-year average, which is still falling in many areas and may also lead to under-provision in Minerals Local Plans – especially as recent sales, including 3-year average, are rising and higher than the 10-year average.
However, the MPA told the committee that what happens in reality around the country is a “somewhat variable and inconsistent” approach with some authorities relying on 10 years, some take into consideration the three years, and some rely on the regional apportionment figure.
Historically, central Government produced National and Sub-national Guidelines for aggregates provision in England.
These data, the last of which were published in 2009 covering the period 2005 to 2020, were intended to be used in the preparation and revision of minerals local development frameworks and regional spatial strategies.
The objective of the guidelines was to inform the provision of aggregates through the planning system in the English regions and for individual mineral planning authorities.
Mineral planning authorities and the MPA strongly believe that updated National Guidelines are essential to provide a strategic and forward-looking forecast of demand for aggregates for all markets, including housing and infrastructure.
In the absence of up-to-date National and Sub-national Guidelines, the MPA says AWPs have no benchmark against which to consider whether the collective provision in the LAAs (and plans) is making a ‘full contribution towards meeting both national and local aggregate needs’ as referred to in planning practice guidance.
This, says the MPA, is resulting in marked variations in the approaches adopted by LAA’s to forecast future mineral demand, resulting in significant inconsistencies between the Local Planning Authorities within AWPs but also across the AWPs themselves.
To the MPA, updated and up-to-date Guidelines would effectively represent a national statement of need for aggregates, as advocated in the UK Minerals Strategy.
The committee was told similar statements would be required for other minerals to provide a strong steer and message, and context for plan-making and decisions.
This, says the MPA, would also remove some of the local subjectivity out of arguments about the numbers to be delivered.
But in order to plan and manage the provision of minerals effectively, the MPA makes a case for monitoring of current activity as the withdrawal of Government support for the Annual Mineral Raised Inquiry – undertaken by the Office for National Statistics on behalf of MHCLG and BEIS – leaves a “significant gap” in the knowledge and understanding of minerals production.
And the Aggregates Monitoring Survey – which has traditionally been commissioned every four years by MHCLG to provide information on the national and regional sales, inter-regional flows, transportation, consumption and permitted reserves of primary aggregates in England – is, says the MPA, being delivered inconsistently.
The survey is used to inform government on the production, movement and consumption of aggregates in order to monitor and revise the aggregates guidelines, which support the National Planning Policy Framework, and to monitor and develop planning policies for the managed supply of aggregates in England.
Delivery of the last survey, for the year 2014, was delayed by two years, finally reporting in 2016, while the survey for 2018 is still to be commissioned.
The MPA told the committee: “At a time when Government has clear policy ambitions around housing and infrastructure delivery, the ability to plan and manage the delivery of mineral planning effectively is being undermined by the absence of effective and timely monitoring data.
“In the absence of a consistent baseline position to refer to, the planning and management of mineral provision is having to draw on a range of alternative data sources, which can often be out of date, inconsistent or incomplete.”