In early 2017 the Minerals Products Association together with the CBI Minerals Group prepared a proposed UK minerals strategy. Details of the consultation can be found on the Mineral Products Assocation website.
The submission produced by the Geological Society can be found below:
Submitted 31 March 2017
1. The Geological Society (GSL) is the UK’s learned and professional body for geoscience, with about 12,000 Fellows (members) worldwide. The Fellowship encompasses those working in industry, academia, regulatory agencies and government with a broad range of perspectives on policy-relevant science, and the Society is a leading communicator of this science to government bodies, those in education, and other non-technical audiences.
2. We welcome the publication of the draft Proposed UK Minerals Strategy which provides a useful approach for meeting the UK’s mineral needs and is very timely in the context of the uncertainty around trade that lies ahead as a result of the country’s decision to leave the European Union. We are pleased to see the discussion of sustainable access to resources as it pertains to meeting the UK Industrial Strategy and the National Infrastructure Delivery Plan as well as the comprehensive description of the value of minerals and raw materials to society and the economy. The focus in the document in communication across the devolved nations to develop secure access to minerals is particularly welcome given the differences in devolved regulation on matters associated with access to minerals. However, the document does not refer to the position with regards to minerals in Northern Ireland, where production of construction minerals and salt contribute significantly to the economy. The authors should refer to the Planning Strategy for Rural Norther Ireland, Regional Planning Policies: Minerals (https://www.planningni.gov.uk/index/policy/rural_strategy/psrni_regional_policies/psrni_minerals.htm) for more information. You may wish to include the findings of this report in Appendix A of the strategy.
3. We are also pleased to see that the proposed strategy includes consideration of geoconservation and environmental interests to ensure that landscapes are appropriately conserved. The aim to develop more former mineral working sites through consultation with stakeholders and with consideration of the local biodiversity, natural capital and geodiversity is welcomed. Open dialogue with those working in environmental protection around designations such as AONBs and National Parks is essential to developing sustainable plans for mineral extraction. The stated aim on page 4 to ‘improve public understanding of the need for miners and of mineral working and processing through open discussion about their concerns’ is also good to see.
4. Effective policy making around issues such as resource sustainability and environmental protection requires extensive working across policy areas, disciplines and government departments. The established view of those in the policy sector and among environmental organisations working in this area is that a holistic approach to policymaking is needed to effectively manage the extraction of raw materials and resources held in the Earth together with impact on the environment in a sustainable way. There are a number of sections in the draft document which recognise the importance of sustainable management of resources and minerals and a healthy environment to deliver quality of life and economic growth. However, some of the ways that the impact of planning regulations and environmental protections are presented in the strategy could lead to misperceptions regarding the role of these areas of policy in delivering sustainable economic growth for all. There are a number of instances in the document where environmental considerations are omitted or where environmental regulations are described as being problematic. References in the document include environmental protections described as being a ‘constraint’, or the description of a ‘licence to operate’ as ‘unnecessarily slow, complex and expensive’ or the inclusion in Appendix C in the Planning and Environmental Regulation section of the wording ‘the need for planning decisions to have primacy over environmental permitting’. Presenting concerns in this way could be counterproductive and discredit those areas of environmental permitting that work well alongside mineral extraction. To avoid any misperceptions on behalf of the reader it would be useful to specifically identify problematic permitting issues rather than discuss environmental protections in a general way. Changes to planning and environmental regulations cannot come at the expense of effective environmental management and planning: indeed both must be considered together if the government is to deliver an effective minerals strategy.
5. The same argument can also be made for the intersection between planning and permitting for minerals extraction and climate change policy. Secure access to resources and decarbonisation policies need to exist side by side in a holistic approach to environment and resource management. Both improved resource security and decarbonisation of the economy are essential as we move to live more sustainably and equitably. The link to a low-carbon and circular economy is made on page 4 in the document is welcome but the document would benefit from this being added at the appropriate points on Page 3.
6. In addition to these suggestions, we would recommend the following amendments:
- Page 1 - On the bullet point list on the first page, amend ‘Mitigate impacts of extraction, processing and transportation’ to include ‘and work with those responsible for environmental permits to ensure alignment of understanding’.
- Page 1 - On the bullet point about ‘Cut and improve ‘red tape’ particularly in relation to planning and permitting’, it would be useful to include a few words that describe this being done ‘in line with current environmental protection’ or ‘while also considering environmental protections’ or something to that effect. You may also want to rethink the use of the phrase ‘red tape’, a term which could be perceived as a pejorative by some readers as this could send out the wrong message. This point should also be amended where it appears in the bullet points on page 4.
- Page 1 - The document contains a useful collation of information regarding the use of minerals and raw materials in industry in the ‘Overview’ section as well as a useful set of numbers and statistics about UK mineral extraction and use. Secure access to minerals is also imperative for the renewable energy industry as many renewable energy technologies such as wind and solar power require minerals to manufacture. Renewable energy technology is a growing area in the UK economy and it would be worth mentioning this link in the Overview section.
- Page 1 – In paragraph 2 the text includes the following passage ‘reserves are not being replenished fast enough’. This may be confusing to some readers as it suggests that mineral resources are renewable as implied by the use of the word ‘replenished’. This definition is reinforced later in the paragraph where the wording includes ‘Timely replacement is needed’. This section could be referring to the renewal or awarding of permits but this is a little unclear with the current wording so this may need to be reviewed.
- Page 3 – In the section on access to minerals, paragraph 2 refers to a ‘licence to operate’ relating to ‘securing planning permission and environmental permits’. This term is increasingly being used in both the mining and policy sector as short hand to refer to the ‘social licence to operate’ where as the majority of the text in this section refers to issues around securing planning and permits for mineral extraction and production. It is possible therefore that there may be confusion on behalf of the reader as to what is meant by this phrase in this context.
7. We note that the role of University Geoscience Departments in delivering the strategy is only mentioned briefly in the statement under the section in Appendix C on Education, Skills and Employment and Public Understanding. University training will have a role to play in many of the points raised in the action plan. In particular, University Geoscience Departments will be involved in delivering the key technical skills the sector will require to meet the aims laid out in the proposed strategy, specifically geotechnical and geological skill sets. As raised in Appendix C, a successful UK Minerals strategy relies on an adequate resource of skills and technical ability in the workforce as well as experienced planners and Health and Safety experts. We would recommend underlining this need more clearly so that it ties into the science and skills ‘pillars’ in the Industrial Strategy Green paper.
8. The importance of research is covered in the document but the link to universities is not explicitly mentioned. The strategy details the need for research into technological and operational procedures as well as sustainability and product research. This could be extended to research into finding and proving resources, improving recovery, innovative processing techniques and extraction in novel settings. Research and innovation will also be key to minimising the environmental footprint of mineral extraction which can build towards improved public acceptance and community support for resource extraction in the UK. University Geoscience Departments are key to carrying out and delivering research findings as well as maximising the links between industry and research which is imperative for bringing research findings into commercial settings.
9. On the broader area of ongoing and future mineral needs of the UK, the Society is involved in a major initiative being organised by the International Union of Geological Sciences (IUGS) entitled ‘Resourcing Future Generations’ (http://www.geolsoc.org.uk/RFG) which is aimed at ‘securing the mineral, energy and water resources required by future generations’. You might consider drawing attention to this initiative in the strategy as another way of linking the long-term minerals strategy to UK policy initiatives on economic growth, international development and environment and climate change policy. 2018 is also the Geological Society’s themed Year of Resources and there may be opportunities to collaborate on meetings and activities around mineral and resource security to raise awareness of the current status in the UK among fellow geoscientists and policymakers as well as plans going forward.