"Option 4: "Support extraction of potash from under the National Park as well as outside of the National Park but only support siting of surface infrastructure outside the National Park."
Comment: Though it would be technically feasible to place a minehead at a considerable distance from where the extractable ore is winnable, there are 3 important reasons why this is impractical and therefore I believe Youk Potash would never proceed with such a scheme.
1/ Such a mine designed this way would immediately have the same issues that 'exhausted' mines do with long distances to workings, drastically impairing the economics of such a proposal.
2/ There would be very large and I suspect unacceptable to local communities, amounts of spoil created in cutting the long drifts/tunnels needed to reach the ore from the mine head.
3/ The long journey times for staff from face to surface would add significant risk to the wellbeing of operative in an emergency situation.
General comment: with the York Potash design particular effort has been made to minimise surface impact of the mine buildings and Mineral Transport System. I believe this is an acceptable level of moderation to protect this valuable landscape." -------------- GK.
I assume you got that reply after the consultation closed - too late for comments now.
NYCC had 4 proposed options on potash policy re the M&W Plan, only one would allow a long term and sustainable UK potash industry, AISI. My submission of last week below:
"Comment on the NYCC M&W Joint Plan
Option 1: "Support an indigenous supply of potash from one location only."
Comment: This misunderstands how the life of mines develop over time, they become 'exhausted', ie it becomes more and more difficult for a mine to remain economically viable when it has a single minehead access point and the extractable ore has to be won from greater and greater distances from the mine shaft bottom. In the case of Boulby there is proposed new investment but that may only extend it's life by 1 to 2 decades, from my understanding. With this option there would be a real future risk of a situation arising where there is no extraction of this vital and strategic mineral in this country and a set of policies in place where there is no means of allowing it from where it is viable to mine it.
Option 2: "Support the principle of multiple sources of potash supply from within the Plan area.
Comment: This would not only provide the possibility of "economic benefits" but many other social and environmental benefits could arise from careful application of funding to the area of the local wealth created from mineral extraction. It would also allow a much higher degree of certainty of continuity of supply of potash.
Option 3: "Support new locations for potash extraction outside of the North York Moors National Park only."
Comment: To protect the Park from any development this would be a sensible approach. However in the particular cases of Boulby and York Potash the geology of the resources does not support the economic mining of potash (either Sylvinite or polyhalite at other locations other that Boulby's existing site or in the near vicinity of York Potash's proposed site near Sneaton.
From sec 116 of the NPPF:
"the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and *any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated"
For the York Potash scheme there is no "scope for developing elsewhere outside the designated area" and the NPPF accepts that developments are allowable if "any detrimental effect on the environment, the landscape and recreational opportunities........could be moderated" in an acceptable way. From my understanding."
Here's a somewhat 'hedgy' reply from NYMNPA on the relevance of the Minerals and Waste Plan to the YP application:
Dear Mr xxxx,
Thank you for your enquiry.
The York Potash planning application will be considered against the policies in the Development Plan for the area. This is the North York Moors National Park Authority Local Development Framework - Core Strategy and Development Policies, November 2008 which can be accessed on the Authority’s website on the following link: Local Development Framework
There are two documents currently in preparation, the Whitby Business Park Area Action Plan and the Minerals and Waste Joint Plan which, once adopted by the Authority, will also become part of the Development Plan for the area. It is expected that the Whitby Business Park Area Action Plan will be adopted before the end of 2014 but the Minerals and Waste Joint Plan is still at ‘Issues and Options’ stage and is not likely to be adopted until 2015. The National Planning Policy Framework (NPPF) includes guidance that weight should be given to relevant policies in ‘emerging’ plans according to the stage of preparation, the extent to which there are unresolved objections to relevant policies and the degree of consistency with NPPF policies. At the point at which the York Potash planning application is likely to be considered, the Minerals and Waste Joint Plan is likely to be at ‘Preferred Options’ stage and it may be possible to attach limited weight to it, depending on the nature of any issues outstanding from the recent ‘Issues and Options’ consultation.
Other policy documents that will also be taken into account in considering the York Potash application include: • The National Planning Policy Framework and the associated on line Planning Practice Guidance • English National Parks and the Broads UK Government Vision and Circular 2010 • North York Moors National Park Management Plan, A Wider View
Jane Davies Senior Planning Officer (Potash Project)
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