Minerals Local Plan Background Document Worcestershire County Council: October 2012 Consultation Document Salt and Brine in Worcestershire Verity Pitts, Marianne Joynes, Nicholas Dean October 2012 Executive Summary This document is a consultation document. We would like your comments on this document. Please consider the following questions in formulating your response: Do you have any other information about salt or brine resources or issues in Worcestershire, including whether any future extraction might be commercially viable? Are there any policies, plans or strategies that might affect how the Minerals Local Plan plans for salt and brine in Worcestershire? If so, how do you think the Minerals Local Plan could contribute to or conflict with these policies, plans or strategies? All comments should be sent to [email protected] or addressed to: Freepost SWC-1253, Minerals and Waste Planning Policy, Business Environment and Community Directorate, Worcestershire County Council, County Hall, Worcester, WR5 2NP. For further details or to request copies of this document please contact Marianne Joynes (01905) 766800. Salt and brine are found in Worcestershire in the Droitwich and Stoke Prior area. Historically they have been worked since the Iron Age, but the most recent working closed in the 1970s following concerns about subsidence. Based on the best information the Council is aware of, the salt and brine resources in Worcestershire are not considered likely to be workable or commercially attractive. Any proposed new salt or brine workings would need to satisfactorily address the implications for ground stability and subsidence in advance, The Council does not currently have any information to suggest whether these issues could be overcome. Contents Executive Summary.......................................................................................... 2 1. Introduction to Brine as a mineral .................................................................. 4 Why it is needed and what is it used in ............................................................. 5 2. Where is Brine found? ................................................................................... 6 3. The History of Workings in Worcestershire ................................................... 7 Droitwich........................................................................................................... 8 Stoke Prior ........................................................................................................ 9 4. Planning Context ......................................................................................... 10 National Planning Context .............................................................................. 10 Regional Spatial Strategy ............................................................................... 11 Local Policy Planning ..................................................................................... 12 5. Regulating Bodies ....................................................................................... 13 6. Planning Issues for Salt and Brine .............................................................. 15 Hydrology ....................................................................................................... 15 Geological Conservation................................................................................. 15 Emissions ....................................................................................................... 16 Visual Impacts ................................................................................................ 16 Transport ........................................................................................................ 16 Climate Change .............................................................................................. 17 1. Purpose of this document 1.1. This document is a consultation document. 1.2. We would like your comments on this document. Please consider the following questions in formulating your response: Do you have any other information about salt or brine resources or issues in Worcestershire including whether any future extraction might be commercially viable? Are there any policies, plans or strategies that might affect how the Minerals Local Plan plans for salt and brine in Worcestershire? If so, how do you think the Minerals Local Plan could contribute to or conflict with these policies, plans or strategies? 1.3. All comments should be sent to [email protected] or addressed to: Freepost SWC-1253, Minerals and Waste Planning Policy, Business Environment and Community Directorate, Worcestershire County Council, County Hall, Worcester, WR5 2NP. 1.4. For further details or to request copies of this document please contact Marianne Joynes (01905) 766800 or [email protected] . 2. Introduction to salt and brine 2.1. Salt is extracted in two forms from the earth. As a solid called rock salt (or halite), and also as a liquid known as brine. Brine is created where ground water percolates through and dissolves the rock salt and it is much denser than salty sea water. There is approximately 2.5 lbs. of salt per gallon in brine; this is ten times stronger than sea water. 2.2. Rock salt is extracted by the 'pillar-and-stall' method. This is a traditional mining method in which salt pillars are used to support the ceiling of shallow underground cavities and tunnels where the excavation takes place1. This has very little effect on the surface, except in the cases where the cavities or tunnels collapse and subsidence occurs. 2.3. For brine extraction, a modern brine pump involves a double pipe inserted into the ground which uses hydraulic power to induce the brine to flow upwards2. The extraction of brine through a pump therefore has very little impact, in the first instance, on its immediate surroundings. 1 Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG. Pg 8 2 http://www.igg.org.uk/gansg/12-linind/salt.htm 2.4. The processing methods differ on the surface depending on the end result or product desired and facilities can cater for a variety of uses. The processing methods include vacuum pan refining or open pan refining. 2.5. The vacuum pan refining method uses multiple evaporators all acting under vacuum in order to extract the salt. The crystallised salt is then removed as a slurry, dewatered in a centrifuge and rotary dried in a kiln 3. Open pan refining is not as energy efficient as the vacuum refiner and uses large pans to evaporate the water. In this method the salt forms as flakes not cubic crystals like in vacuum pan refiners4. Why it is needed and what is it used in? 2.6. In the UK rock salt is used to a large extent for de-icing roads, and to a lesser extent in agriculture as an additive or fertiliser 5. 2.7. Brine is produced on a much larger scale than rock salt and is therefore used more widely. Four main products are extracted from brine by the inorganic chemical industry: these are chlorine, caustic soda, soda ash, and hydrogen (electrolysis by-product)6. 2.8. Chlorine is used in water and sewage treatment, in household and industrial bleaches and for making plastics and polymers7. Chlorine is also used in crude oil refining and for making pesticides8. Caustic soda is used in paper-making and manufacturing soap and detergents9. Soda ash is used in manufacturing detergents and glass and hydrogen is used as a fuel for power generation10. 2.9. Brine can also be evaporated to produce white salt, which can then be used in water softening, chemical feedstock, food-processing and tanning11. 2.10. Salt (and its component brine) are necessary economic resources for the UK. Processing plants have been able to derive many uses from this basic compound (sodium chloride, NaCl). Deposits of salt and brine make up 1/5 of the total value of industrial minerals in the UK, representing a value of £530million (in 2010)12. According to the British Geological Survey, in 2010 the UK produced 6,666 thousand tonnes of rock salt/brine13. In the same year however, we imported roughly 17% of the amount we had produced indigenously and exported just over 6% of that same total14. This level of imports is partly due to the variety of uses we have derived from the 3 http://www.saltinstitute.org/Production-industry/Production-technologies/Evaporated-salt-refinedsalt/Vacuum-pan-refining 4 http://www.saltinstitute.org/Production-industry/Production-technologies/Evaporated-salt-refinedsalt/Vacuum-pan-refining 5 Mineral Planning Factsheet, Salt. BGS, 2006 6 Mineral Planning Factsheet, Salt. BGS, 2006 7 Mineral Planning Factsheet, Salt. BGS, 2006 8 http://www.saltinstitute.org/Uses-benefits/Salt-in-industry/Salt-in-chlorine-chemistry 9 Mineral Planning Factsheet, Salt. BGS, 2006 10 Mineral Planning Factsheet, Salt. BGS, 2006 11 Mineral Planning Factsheet, Salt. BGS, 2006 12 http://www.bgs.ac.uk/downloads/start.cfm?id=2485, page 10 13 http://www.bgs.ac.uk/mineralsuk/statistics/downloads/MineralsProducedInTheUnitedKingdom.pdf 14 http://www.bgs.ac.uk/downloads/start.cfm?id=2485, page 71 compound and that in certain circumstances our usage rates do not reflect our production rates, so importation is necessary. 2.11. Importing rock salt can also be necessary if local authorities' stockpiles for treating roads become depleted, 'in times of maximum demand it is sometimes easier and quicker to import salt from elsewhere into a convenient port'15. Stockpiling very large amounts of salt for long periods of time is not economically viable as salt becomes less effective once exposed to the atmosphere16. 3. Where are salt and brine found? 3.1. Figure 1 outlines where the main areas of salt and brine deposits and workings are distributed in England. Looking at the UK as a whole there is also an area of eastern Northern Ireland where salt and brine deposits have been exploited. There are no areas in Wales that salt deposits have been found. 3.2. As of February 2012 there are 14 salt workings in total around the UK. In England there are 8, most of them are situated in the county of Cheshire 17. 18 Figure 1: The distribution of salt karst and salt mining areas in the UK . 3.3. 15 The majority of areas near the county of Worcestershire have salt deposits from the Triassic period, including Cheshire and Stafford. Permian (290248 million yo) period deposits can be found on the north eastern side of England. As you can see from Figure 1, Teeside saltfield at Middlesbrough is where the salt is extracted. http://www.bgs.ac.uk/research/highlights/2010/rockSalt2010.html, Andrew Bloodworth http://www.bgs.ac.uk/research/highlights/2010/rockSalt2010.html, Andrew Bloodworth 17 http://www.bgs.ac.uk/downloads/start.cfm?id=2485, page 17 18 Cooper, A H (2002) Halite karst geohazards (natural and manmade) in the UK Environmental Geology, 42, 505-512. 16 3.4. Salt deposits can be found in two areas in Worcestershire; Droitwich and Stoke Prior. Both these areas have Triassic period (248-205 million year old) salt deposits. During this period the Worcestershire and Herefordshire area was nearer the equator. Earth movements resulted in mountainous areas from which minerals were eroded over millions of years. This lead to mineral deposits left in clear strata on the plains, forming sandstones and mudstones. Dry-arid like conditions created wind-blown dust which settled on the plains and also led to evaporation of the mineral-rich water. This formed the layers of salt in the Severn Vale under central Worcestershire.19 3.5. Where salt dissolution has already naturally occurred in the earth where groundwater comes into contact with the upper surface of a salt bed, this is known as a 'wet rock head'. The 'dry rock head' is the upper surface of the salt bed in places where the salt has not dissolved as it has been sealed under another rock stratum. Droitwich and Stoke Prior are both known to have access to a both a dry and wet rock head. The depth of the salt karst20 can be found at 30-130m21, depending on where the rock heads are found. In Worcestershire, the salty stratum is approximately 90m thick, 40% of which is made up of siltstone and mudstone particles22. 3.6. The deposits in these areas have been large enough in the past to be economically viable for extraction, although there are no current workings in Worcestershire. The last brine works (at Stoke Prior) was closed down in 1972 following potential subsidence and conflicts with housing development plans23 24. 3.7. The naturally occurring surface brine stream around Stoke Prior had previously dried up following extensive extraction of the wet rock head by the salt works. However, now that this has ceased it has been shown in a recent British Geological Survey that the brine is again beginning to reach the surface in the area. This survey shows that Chloride concentrations such as 3100-3400mg/l can be found east of Droitwich25. 4. The History of Workings in Worcestershire 4.1. 19 Of the two main salt areas in Worcestershire, Stoke Prior and Droitwich, Droitwich has had the more illustrious and celebrated history. http://www.naturalengland.org.uk/ourwork/conservation/geodiversity/englands/counties/area_ID 44.aspx 20 Karst: 'A suite of landforms created by the action of water on limestone' http://www.bgs.ac.uk/mendips/caveskarst/karst_1.htm 21 http://nora.nerc.ac.uk/6218/2/Halite_karst_geohazards_Cooper_Env_Geol_vol42_505-512.pdf 22 Cooper A.H., Natural and induced halite karst geohazards in Great Britain, British Geological Survey, Nottingham, NG 12 5GG. In: Geotechnical and Environmental Applications of Karst Geology and Hydrology, Beck and Herring (eds), 2001, Swets & Zeitlinger, Lisse. Page 119 23 http://www.miac.org.uk/ici.htm 24 rd Salt Subsidence at Droitwich report of meeting at Institute of Geological Science, London, 3 February, 1969. Archive file of Worcestershire County Council, Corporate Information Management Unit, 107214 Salt, File 1. 25 http://nora.nerc.ac.uk/6218/2/Halite_karst_geohazards_Cooper_Env_Geol_vol42_505-512.pdf Droitwich 4.2. There is possible evidence of pre-Roman workings in the form of an Iron Age brine boiling spring hearth26 At the Upwich brine spring in Droitwich. During the Roman era Droitwich was known as Salinae, which indicates its early extraction and distribution of salt.27 4.3. During the Early Medieval Period various authorities granted excavation space and land to run the pits28. The River Salouuarpe (Salwarpe) which runs through Droitwich was also mentioned29, the name presumably referring to its saline surroundings. 4.4. In 1086 William the First commanded the preparation of the Domesday Book. The survey frequently mentions the salt houses and 'wichs' that both William I and King John, owned and let out in exchange for a yearly rental respectively30. 4.5. Between the 17th and 18th centuries, salt extraction at Droitwich was reaching about 21,840kg per day. The method of extraction that commenced and was used at this time was known as 'wild brining'31, which enabled a heightened exploitation32. The increase in extraction highlighted the need for better infrastructure. In 1755 a report was written that indicated it would be more cost effective to transport the salt by canal. A canal would enable the salt to reach Bristol and other markets via the River Severn, increasing trade and raising the revenues of Salwarpe River. Quoting the writer, 'A navigable river would be a Publick good' 33. 4.6. Wild brining continued to be used as a main method of extraction in this area and joined the traditional 'pillar and stall' method that was used for rock salt exploitation. In the Worcestershire area wild brining was the primary cause of subsidence in Droitwich town and further afield. In other areas such as the county of Cheshire the method known as 'bastard' brining caused serious subsidence and new large lakes to be formed 26 Hurst JD (1997) A multi-period salt production site at Droitwich, Excavations at Upwich. Council for British Archaeology, Research Report 107, 164pp. In: Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG. 27 http://www.droitwichspa.com/history.htm 28 Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG 29 Mills AD (1998) A dictionary of English Place Names. Oxford University Press, Oxford. 411pp In: Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG 30 Poole EG and Williams BJ (1981) ‘The Keuper Saliferous Beds of the Droitwich area’. Report of the Institute of Geological Sciences, No. 81/2. 19 pp. In: Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG 31 Wild brine is formed where salt deposits are close enough to the surface for the rock salt to be dissolved by downward percolating groundwater, creating underground pools and streams of "wild brine". ("Report on the effect of Brine Pumping in and around Droitwich", archive file reference 11543/4/5/2) 32 Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG 33 Bishop of Worcester Estates Parliamentary Records, BA 2636, 88, 45300. The Hive, Worcestershire County Archives, Original Documents. almost daily34. 'Bastard' brining is when old rock salt mines were pumped with fresh water to produce more, valuable brine. This method was first used in Marston Mine in 1873 and was a 'haphazard affair, [and] poorly regulated'35. 4.7. In the 1850s, the railway began to undermine the use of canals for transporting produce from Droitwich to the River Severn. Of the two canals which serve Droitwich, the wider canal (the Barge Canal) was officially abandoned in 193936. As salt production and processing developed over the country, competition increased and kept prices low. The Droitwich salt works began to struggle due to its relatively small scale of production 37. Salt production discontinued in about 192038. Stoke Prior 4.8. Stoke Prior, the other main Worcestershire salt works, continued to exploit the resource after the Droitwich works had shut. 4.9. These works had received heavy investment since the 1830s when a large deposit of rock salt had been discovered, however extraction quickly changed to brine due to the characteristics of the deposit 39. The works incorporated salt and chemical works and a soapery40. The salt that the mine at Stoke Prior produced was celebrated by chemists. Notably, A. Beauchamp Northcote of the Royal College of Physicians, who examined multiple brine springs in the UK wrote of the salt; 'Those of Stoke Prior rank among the first in point of concentration, and are also very remarkable for their freedom from earthy impurities, and calculated to produce a very fine and pure variety of salt.'41 4.10. Stoke Prior salt works was rejuvenated by John Corbett, a local entrepreneur, after he bought it in 185342. Updating the processing plant increased salt production from 26,000 tonnes to 200,000 tonnes a year 43. 34 Earp JR and Taylor, BJ (1986) Geology of the country around Chester and Winsford. Memoir of the British Geological Survey, Sheet 109.119 pp., Waltham AC (1989) Ground subsidence. Blackie, Glasgow and London. 202p., and Watham AC, Simms MJ, Farrant AR and Goldie HS (1997) Karst and caves of Great Britain. Joint Nature Conservation Committee. Chapman and Hall, London. 358pp. In: Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG 35 Bresnik, J (2005) Unstable Ground: Salt Mines, Subsidence, and Population Shifts in Northwich, Cheshire County 1850 – 1911, History 256 36 http://www.droitwichspa.com/history.htm 37 Decline of Droitwich Salt Production, Guerney's Lane Information Board. Droitwich Spa Heritage Centre, WR9 8DS 38 http://www.droitwichspa.com/history.htm 39 http://www.igg.org.uk/gansg/12-linind/salt.htm 40 http://www.miac.org.uk/corbett.htm 41 http://www.rootsweb.ancestry.com/~ukcemete/worcestershire/parishess/stokeprior/stoke_prior.h tml 42 http://www.miac.org.uk/johncorbett.htm 43 http://www.worcesternews.co.uk/archive/2001/05/16/Worcestershire+Archive/7760389.Salt_King _with_the_Midas_touch/ 4.11. The successful Stoke Prior works changed hands a number of times before its closure in 197244. Housing development in the surrounding areas brought local subsidence issues to the fore and it was deemed too dangerous to continue extraction45. 5. Planning Context National Planning Context 5.1. At a national level it is acknowledged that minerals are necessary for the country in many different ways. Minerals aid the economic growth of the country and enable us to improve our quality of life46. 5.2. Minerals are important for the materials we need for the infrastructure, buildings, energy and goods of the country. Because minerals are of such importance, are finite and can only be worked where they are found, it is important to use them to their best and full potential 47. 5.3. We have access to only certain minerals depending on the physical characteristics of the land. To ensure we use them in the most forward-looking and sustainable way, we need to define Mineral Safeguarding Areas to ensure that potential future mineral extraction is not unnecessarily sterilised by non-mineral development..48 5.4. The definition of Safeguarding Areas does not imply that any resource defined will be used49. Where ap propriate Minerals Consultation Areas should be put in place for specific areas, to ensure that appropriate consultation arrangements are put in place between district and county planning authoritiesto prevent potential non-mineral land uses from compromising mineral sites without appropriate consideration50. 5.5. The expectation is that where possible, mineral extraction should happen prior to non-mineral development. In practice this should only happen where mineral extraction is 'practicable and environmentally feasible' 51 and would not unacceptably compromise the proposed non mineral development. Although the National Planning Policy Framework does not make any distinction between different industrial minerals, the adopted Hereford and Worcester Mineral Local Plan states that extraction requirements are more relevant to surface resources, such as sand and gravel52. However these issues should be considered in developing the new Minerals Local Plan. 44 Cooper A. H., Halite karst geohazards (natural and man-made) in the United Kingdom, British Geological Survey, Nottingham, NG12 5GG 45 rd Salt Subsidence at Droitwich report of meeting at Institute of Geological Science, London, 3 February, 1969. Archive file of Worcestershire County Council, Corporate Information Management Unit, 107214 Salt, File 1. 46 National Planning Policy Framework, Chapter 13, policy 142 47 National Planning Policy Framework, Chapter 13, policy 142 48 rd National Planning Policy Framework, Chapter 13, policy 143, 3 point 49 rd National Planning Policy Framework, Chapter 13, policy 143, 3 point 50 http://www.westsussex.gov.uk/yourcouncil/ppri/mwdf/msareport2007.pdf 51 th National Planning Policy Framework, Chapter 13, policy 143, 5 point 52 Adopted Hereford and Worcester Mineral Local Plan, Chapter 5, 5.1 5.6. The NPPF states that planning policies should ensure that 'permitted operations do not have unacceptable adverse impacts on the natural and historic environment or human health'. One of the impacts mentioned in the policy is mining subsidence. It is also a matter of law that development should not undermine adjoining land. Subsidence is a specific impact from brine extraction which has, historically, caused extensive problems in Droitwich Spa, Worcestershire. 53. 5.7. The NPPF ensures that noise limits are appropriate whilst understanding that short term noise pollution that exceeds standard limits may be an unavoidable side-effect to the mineral extraction process54. The cumulative effects of noise and other impacts from a number of individual sites or a number of sites locally should be considered and taken into account 55. 5.8. The extraction of brine is completed with very little obvious surface workings; however the actual processing of brine requires a number of facilities at the site of the extraction pump. This means that reclamation needs to be considered after the site has been exhausted. In previous examples brine sites have been reclaimed as other large processing facilities56. Regional Spatial Strategy 5.9. It is observed that there is a fine balance between caring for the environment and exploiting minerals. The policies in the West Midlands Regional Spatial Strategy regarding the 'Quality of the Environment' have been put in place specifically for this need57. 5.10. Policy QE6 states that land should be conserved, enhanced and restored in all policies, proposals and plans for the region. Where mineral extraction is occurring, the degraded landscapes that are a result of this will be identified for restoration58. 5.11. The aim of Regional policies is 'to encourage the prudent use of available mineral resources and to maintain an appropriate on-going supply'59. 5.12. Regarding the provision of nationally and regionally important minerals, policy M1 states that account should be taken of 'the need to secure the best balance of community, social, environmental and economic interests consistent with the principles of sustainable development'. This policy also states that in making appropriate provision for minerals, conservation of non-energy minerals for the future and also the contribution minerals from outside the region will make will need to be taken into account60. 5.13. Policy M1 also states that development plans should identify areas that would and would not be appropriate for mineral extraction, should protect resources from non-mineral development and also protect infrastructure 53 th National Planning Policy Framework, Chapter 13, policy 143, 6 point th National Planning Policy Framework, Chapter 13, policy 134, 7 point 55 th National Planning Policy Framework, Chapter 13, policy 143, 6 point 56 http://www.miac.org.uk/ici.htm 57 Regional Spatial Strategy for the West Midlands, Part 3, Paragraph 8.56 58 Regional Spatial Strategy for the West Midlands, Policy QE6, pg 77 59 Regional Spatial Strategy for the West Midlands (WMRSS), Part 3, Paragraph 8.58 60 Regional Spatial Strategy for the West Midlands (WMRSS), Policy M1, A 54 for transportation of minerals. Plans will also need to include the circumstances in which mineral extraction will be permitted and also where it will not be suitable61. 5.14. The Policy Recommendations for Minerals for the Phase 3 revision of the West Midlands Regional Spatial Strategy states that, 'The population of the West Midlands is forecast to increase significantly. This increase will create additional demand for minerals and competition for land. The location of many mineral resources coincides with environmental and nature conservation designations such as Areas of Outstanding Natural Beauty and Special Areas of Conservation. The cumulative impact of this could be to restrict future development options for mineral development and supply'.62 5.15. There brine deposits in Worcestershire are not in Areas of Outstanding Natural Beauty, however the competition for land in the county will increase. This will compound the existing and potential negative impacts that salt extraction has on its surroundings. Local Policy Planning 5.16. It is recognised at the local level that 'locally-won minerals reduce construction costs and increase the generation of wealth in terms of employment and spending power'63. However, because environmental damage can be significant from the mineral extraction process 'policies are required to balance the need for mineral extraction with the social, agricultural, environmental and other considerations arising from the extraction process'64. 5.17. Salt is listed in the adopted Hereford and Worcester Minerals Local Plan as a commercially exploitable mineral that can be found within Worcestershire. However it also states that presently, and in the foreseeable future, salt will not be commercially exploited65. However, the new Minerals Local Plan will supersede the adopted Hereford and Worcester Minerals Local Plan, and it will need to consider the commercial viability and sustainability of the mineral resources in Worcestershire. 5.18. The County Structure Plan sets out some of the current policies surrounding the extraction process and after care of minerals in the county. This saved minerals policies in the Structure Plan will be superseded by the new Minerals Local Plan. The policies mentioned below uncover some of the issues that will need to be considered in developing the new Minerals Local Plan. 5.19. Policy M.2 in the County Structure Plan ensures that mineral deposits are safeguarded as far as possible and non-mineral development which could sterilise resources will be resisted unless there is proof that no workable 61 Regional Spatial Strategy for the West Midlands (WMRSS), Policy M1, B WMRSS, Policy Recommendations for Minerals, pg 11 63 Adopted Minerals Local Plan, WCC, Paragraph 1.2 64 Adopted Minerals Local Plan, WCC, Paragraph 1.3 65 Adopted Minerals Local Plan, WCC, Paragraph 1.4 62 deposit exists, or that the environment would be unacceptably compromised by extraction66. 5.20. Policy M.3 in the County Structure Plan states that in order for minerals development to take place, 'agricultural land, local amenities, local character or features of landscape, historic and nature conservation importance will not be unacceptably affected' and that 'safe access can be provided'. Areas of outstanding Natural Beauty and Sites of Specific Scientific Interest will go through the most 'rigorous examination'67. 5.21. The County Structure Plan also covers the restoration and aftercare of the mineral extraction site. Policy M.4 ensures that operations are carried out in accordance with approved schemes and should enhance the landscape and ecological quality of the area. The policy also highlights the need for proper management and continuation of care after the statutory 5 year period68. 6. Regulating Bodies 6.1. The Environment Agency, Natural England and English Heritage are all regulatory bodies with various roles in protecting the natural and historic environment. The Minerals Local Plan will need to take into account any relevant policy or advice from these bodies, and they will be consulted on the development of the plan throughout the process. The role of the Environment Agency 6.2. The Environment Agency aims to make our land, air and water better quality and our use of those resources more sustainable. They are an Executive non-departmental Public Body responsible to the Secretary of State for Environment, Food and Rural Affairs.69. In their corporate plan 2011-2015 they will 'work with businesses so they take full responsibility for their environmental impact and report openly on it'70. 6.3. 'By 2030 there could be up to 30% more households in England', putting pressure on natural resources and existing environmental infrastructure71. The Environment Agency seeks 'to ensure land-use planning processes address environmental challenges, particularly at an early stage, by influencing strategic plans. [They] are a statutory consultee for environmental assessments and sustainability appraisals that are part of land use planning in England and Wales'72. 6.4. The Environmental Agency assesses and regulates some individual sites through the Environmental Permitting process. This process was introduced in 2010 to widen the scope of activities that are controlled by the Environmental Agency. Now activities involving groundwater, 66 Worcestershire County Structure Plan, 1996-2011, Chapter 9, Policy M.2 Worcestershire County Structure Plan, 1996-2011, Chapter 9, Policy M.3 68 Worcestershire County Structure Plan, 1996-2011, Chapter 9, Policy M.4 69 http://www.environment-agency.gov.uk/aboutus/112336.aspx 70 The Environment Agency, Corporate Plan 2011-2015, Paragraph 2.4, page 12 71 The Environment Agency, Corporate Plan 2011-2015, Paragraph 2.4, page 14 72 The Environment Agency, Corporate Plan 2011-2015, Paragraph 2.4, page 14 67 radioactive substances and mining waste require a permit to continue work, this is not an exhaustive list73. 6.5. In order to protect water resources, prevent over-abstraction or unacceptable impacts on water courses, the Environment Agency advises that an abstraction licence is likely to be required for impounding water or taking more than 20 cubic metres (4,000 gallons) of water per day from sources including rivers or streams, springs or underground sources. This is likely to apply to brine extraction, and the Minerals Local Plan will need to consider the Catchment Abstraction Management Strategies which cover Worcestershire. The role of Natural England 6.6. Natural England is an Executive non-departmental Public Body responsible to the Secretary of State for Environment, Food and Rural Affairs. Their role is 'to protect and improve England's natural environment and encourage people to enjoy and get involved in their surroundings'74. '[They] are also a statutory consultee on local plans and strategic environmental assessment'. 6.7. Natural England seeks to ensure that every opportunity is taken through the planning processes to protect, and wherever possible enhance, the natural environment. It is also responsible for designated sites, such as National Parks and Sites of Special Scientific Interest and the new Minerals Local Plan will need to consider Natural England's advice on protecting and enhancing habitats and species both in considering mineral resources which should be worked and developing policies to protect and enhance biodiversity at minerals sites through site design, operation and restoration. 6.8. Natural England also works with RSPB in the Nature after Minerals Programme with the Mineral Products Association. They work with mineral planners and industry to help 'nature following minerals extraction' 75. The role of English Heritage 6.9. English Heritage is an executive Non-departmental Public Body sponsored by the Department for Culture, Media and Sport. In relation to mineral extraction English Heritage advises local authorities on managing changes to the most important parts of our heritage76. 'English Heritage has special access to government, holds legal and statutory powers and a statutory role in the planning system', using these powers they 'promote the value of England's heritage and its sustainable use'.77. 6.10. Some remains from historic mineral workings may be of interest to or protected by English Heritage. The new Minerals Local Plan will need to consider English Heritage's advice on protecting and enhancing historic assets both in considering which mineral resources should be worked and 73 http://www.environment-agency.gov.uk/business/topics/permitting/default.aspx http://www.naturalengland.org.uk/about_us/default.aspx 75 http://www.naturalengland.org.uk/ourwork/planningdevelopment/spatialplanning/default.aspx 76 http://www.english-heritage.org.uk/about/who-we-are/how-we-are-run/what-we-do/ 77 English Heritage Corporate Plan 2011-2015, page 12 74 developing policies to protect and enhance historic assets at or near minerals sites through site design, operation and restoration. 7. Planning Issues for Salt and Brine 7.1. The majority of activities associated with salt extraction are underground and remain unseen. However there are particular characteristics of salt extraction that have environmental implications. Hydrology 7.2. Policy QE9 from the Regional Spatial Strategy for the West Midlands (WMRSS) states that it will 'ensure abstraction from watercourses and aquifers does not exceed sustainable levels'. The WMRSS also states that 'development that poses an unacceptable risk to the quality of groundwater or surface water in this or other regions should therefore be avoided'78. 7.3. Brine extraction in Worcestershire has had an impact on groundwater in the past, however, the new ground water exemption policy from the Environment Agency includes saline abstractions from the Cheshire brine fields. These are specific exemptions that also allow certain types of dredging operations and certain abstractions within water meadow systems79. If the brine fields were to be re-exploited in Worcestershire abstraction would almost certainly be less than at the current Cheshire fields. However, care would be required assessing the specific local impact to the area's groundwater and aquifers. Geological and Nature Conservation 7.4. In the UK, the Geological Conservation Review (as part of the Department of Environment, Food and Rural Affairs) has been developed 'to provide a public record of the features of interest and importance at localities already notified or being considered for notification as 'Sites of Special Scientific Interest' (SSSIs). The sites selected – GCR sites – form the basis of statutory geological and geomorphological site conservation in Britain'80. 7.5. The sites that have been selected have the potential to be used for scientific, education, training, economic, leisure and aesthetic purposes 81. 7.6. Areas of Triassic and Permian rock in the UK are GCR sites and therefore protected. The rocks that were formed during these time periods are where our halite deposits are situated. There are no areas in Worcestershire that are GCR or SSSI sites that are also potential salt working areas. (The Worcestershire Triassic or Permian GCR sites comprise of Burcot, Beckford, Osebury Rock and Sling Common82). 7.7. SSSI designation means that the area is protected and conserved as it naturally develops in order that future generations may be able to enjoy it 78 Regional Spatial Strategy for the West Midlands, Jan 2008, pg 82 Managing Water Abstraction, June 2010, The Environment Agency, Bristol, BS32 4UD 80 http://jncc.defra.gov.uk/page-2947 81 http://jncc.defra.gov.uk/pdf/earthscienceSSSI.pdf 82 http://jncc.defra.gov.uk/default.aspx?page=4210&area=SO 79 as well83. The Worcestershire County Structure Plan in Policy M.3 states that proposals in Areas of Outstanding Natural Beauty or SSSIs will be 'subject to the most rigorous examination'84. 7.8. The Salwarpe Valley and Terraces, a zone running from Stoke prior to the Severn confluence have been identified as a distinctive biogeographic "Natural Area" in Worcestershire. The limit of the zone is taken as the extent of the river terrace deposits. The flood plain habitats in this area are unique in the county. There is a distinctive brackish element present throughout the valley system in association with the river, the canal and on the remnant wetland habitats on the flood plain - species such as Wild Celery and Dittander occur. Pimpinella major (Greater Burnet-saxifrage or Hollowstem Burnet Saxifrage) has its stronghold here. The salinity levels have dropped since the 1960s and several halophytes are now extinct. Nonetheless any potential effects on the nature conservation interest of these habitats would need careful consideration. Emissions – noise, dust and vibration 7.9. Mineral extraction can result in adverse effects on surroundings unless the operation is properly controlled and the site appropriately restored. These impacts could include noise, dust and vibrations. 7.10. Noise and dust emissions are more likely to occur from rock salt workings than from brine extraction. Rock salt mining may involve blasting which can cause some emissions, although this is likely to be below the level that would cause structural damage at the surface. Visual Impacts 7.11. One of the main impacts associated with salt mining or brine extraction is the visual impact of buildings and storage mounds and the effects of wind-blown salt. The surface impact of brine extraction is likely to be limited to control valves, kiosk housing and small scale exposed pipework at the well head, unless brine processing works are also developed. These would have a visual impact on the surface akin to other industrial uses. 7.12. Visual impacts are considered by policies in city, district and borough level planning policy and the WMRSS works within the context of the Region's 'countryside character', 'natural areas' and 'historic landscapes'. These definitions 'embrace the wide range of natural, cultural and historic elements of the landscape together with more aesthetic and qualitative aspects such as tranquillity'. Visual impacts will therefore be carefully considered. Transport 7.13. Nationally the Government has set out some over-arching targets for transport to ensure that transport contributes to an efficient economy and supports sustainable economic growth in appropriate locations and to 83 84 http://www.sssi.naturalengland.org.uk/Special/sssi/index.cfm Worcestershire County Structure Plan, 1996-2011, Policy M.3, page 115 promote the 'integration of all forms of transport and land-use planning, leading to a better, more efficient transport system'.85 7.14. Regionally, relating to mineral extraction, policy should improve safety and protect the environment. To do this the region should take 'measures to improve national road and rail networks to ensure that strategic links to external markets are maintained and the Region does not become a bottleneck undermining national economic growth'.86 Salt resources currently extracted in other areas of the country are exported to international markets as well as national markets87. 7.15. The distribution of rock salt by road can lead to heavy vehicle impacts and congestion particularly during spells of adverse weather. Brine from Worcestershire was historically transported by canal and rail, and if this resource was to be worked in future then sustainable transport methods should be explored. It may also be possible to utilise pipelines to extract brine and transport it directly to a processing plant. 7.16. Transport links will therefore be an important consideration in developing the Minerals Local Plan. Climate Change 7.17. The NPPF states that in a local context, 'local planning authorities should adopt proactive strategies to mitigate and adapt to climate change, taking full account of… water supply and demand considerations'88. 7.18. The WMRSS recognises the potential for industries in the region to apply new technology to help address the implications of global climate change 89 and encourages energy conservation90. Brine and salt extraction and processing are energy intensive as the majority of extraction is undertaken in a vacuum. The Minerals Local Plan will need to address climate change issues, including energy efficiency. Ground stability and subsidence 7.19. At the historic salt and brine workings in Worcestershire, subsidence was a side-effect that impacted upon the local area. There can be unpredictable zones of subsidence caused by brine pumping. However, the effects may not always be negative and subsidence might provide an opportunity to create wetland areas with recreational potential and habitats with unusual flora and fauna if appropriately managed. 7.20. Modern management and extraction techniques are also more likely to enable design and operation which minimises the risk of subsidence than historic workings. 85 WMRSS, Strategic Context for Transport, pg 103 WMRSS, Policy T1, page 106 87 http://www.bgs.ac.uk/downloads/start.cfm?id=2485, page 71 88 NPPF, Policy 94, page 22 89 WMRSS, Paragraph 7.6, page 45 90 WMRSS, Paragraph 8.47, page 84 86 8. Conclusion 8.1. Based on the best information the Council is aware of, the salt and brine resources in Worcestershire are not considered likely to be workable or commercially attractive. 8.2. There could also be serious implications associated with new salt or brine workings which would need to be satisfactorily addressed, particularly in relation to ground stability and subsidence. The Council does not currently have any information to suggest whether these issues could be overcome.
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