In September 2025, Housing Secretary Steve Reed issued a call to arms to developers and housebuilders.
Alongside the continuing requirement for land to be turned over, albeit temporarily, to solar arrays and associated battery storage facilities, there are plans to build 1.5m homes this parliament, and developments to build industrial and commercial property.
With this, there is an increasing potential for the development of land to render the extraction of underlying mineral resources impossible, effectively sterilising these resources from working in the future or to affect the operation of essential mineral infrastructure, while also ensuring an increased demand for these resources.
As illustrated by the case studies in this article, where the development and minerals sectors work together it is possible to achieve built development that does not unnecessarily sterilise finite mineral resources or prevent essential mineral infrastructure, such as wharves and railheads, from operating.
Policies aim to ensure important minerals are not sterilised by development
Mineral safeguarding was formally introduced in 2006 in Minerals Policy Statement 1: planning and minerals (MPS1).
MPS1 required mineral safeguarding areas – land with the potential to contain reserves of minerals – and mineral consultation areas – land surrounding an existing mineral extraction or a mineral infrastructure site – based on the British Geological Survey's (BGS) mapping, to be defined in development plans.
In a mineral consultation area, the mineral planning authority is required to be consulted on any planning applications made for non-mineral development. Development plans will also define waste consultation areas around existing waste management infrastructure requiring the waste planning authority to be consulted.
The definition of safeguarding areas was to ensure, in theory, that developers would be aware of any potentially valuable minerals below their development sites. They could then devise schemes that would prevent the sterilisation of these resources by either avoiding mineral-bearing land or extracting the minerals before development.
This approach has been carried forward into the various iterations of the National Planning Policy Framework (NPPF), which requires local planning authorities (LPAs) to adopt policies that ensure minerals of local and national importance are not sterilised by non-mineral development.
Where non-mineral development that may impact mineral resources or safeguarded mineral infrastructure is proposed, planning policies often require the submission of a mineral resource assessment.
These documents should be prepared by a chartered mineral surveyor, or other suitably qualified and competent person, following BGS' Mineral safeguarding in England: good practice advice, as well as the Mineral Products Association and Planning Officers' Society's Minerals safeguarding practice guidance.
The following case studies are examples of projects where:
- mineral has been extracted before development
- built development and mineral operations can coexist, and
- the tension that can arise from the competing needs of developers and mineral operators.
Successful prior extraction: Ratcliffe-on-Soar case study
Plans are progressing for the redevelopment of the former coal-fired power station at Ratcliffe-on-Soar in Nottinghamshire, which closed in September 2024.
In July 2022, Uniper, the owners of the site, published a draft land development order with the intention to create a smart, green, resilient industrial park focused on energy and manufacturing. The aim was to provide the technology and industry to move towards a net-zero-carbon future.
In Nottinghamshire, there are currently two tiers of planning authority: the county council, which makes decisions relating to mineral and waste applications, and the borough council, which decides other forms of development.
Policy maps attached to both the Nottinghamshire Minerals Local Plan and Rushcliffe Borough Council's local plan identified that large parts of the site contained safeguarded sand and gravel, and gypsum.
This designation triggered the associated development plan policies – the minerals local plan SP7 and the borough local plan policy 42 – that require prior extraction of the underlying resource.
Initially, Uniper concluded that 'given the existing infrastructure constraints, prior extraction of gypsum would not be practical'. However, British Gypsum proposed a creative scheme that would secure the excavation of 1m tonnes of high-grade gypsum over four years.
The scheme would provide a restoration landform capable of both accommodating the proposed solar array and a similar-sized development platform for a large industrial unit, as well as securing increased biodiversity net gain.
In 2023, a land development order that includes the prior extraction of the gypsum was adopted.
How to live in harmony: Greenwich Wharf case study
Greenwich Wharf is one of the largest mineral aggregate terminals in Europe, comprising two aggregate wharves, a railhead, an industrial plant for mixing concrete and asphalt, and some waste recycling, including crushing.
It is operational 24 hours a day, handling some 4m tonnes of mineral a year. The site, its wharves, railhead and other operations, are all safeguarded in the local plan.
Greenwich Millennium Village is within 10 metres of the Greenwich Wharf's boundary fence, with blocks of flats immediately abutting the wharf.
Initially, planning for the Millennium Village, a mixed-use development, was refused at judicial review; the court held that the applicant did not fully consider the adjacent safeguarded mineral operations.
As a result, when a revised application was put forward, the applicant ensured that it included a detailed assessment of the existing mineral operations in terms of noise, dust, vibration and flood-lighting.
The assessment considered how the impact of the safeguarded mineral operations could be successfully mitigated through the development's design.
The design incorporated mechanical ventilation systems and flat layouts with kitchens, bathrooms and circulation space overlooking the mineral operations, with bedrooms facing in the opposite direction.
Mineral operations and residents of the village now coexist.
'The assessment considered how the impact of the safeguarded mineral operations could be successfully mitigated through the development's design'
When sectors clash: Northfleet Harbourside case study
An appeal decision for the Northfleet Harbourside development on the edge of the River Thames is awaited. This is a case where the minerals and development sectors are clashing over a proposed development.
The proposed development is a mixed-use development that would accommodate 3,500 residential units, an 8,000-seat football stadium, a hotel and retail and office space.
However, approximately a quarter of the application site comprises a safeguarded mineral wharf and associated mineral processing operations.
In this case, the wording of the safeguarding policy in the minerals local plan has been critical, as it allows for exceptions to the policy in certain scenarios.
The applicant has argued, citing these exceptions, that the need for the built development outweighs the need to maintain the minerals wharf.
The mineral operators, Kent County Council and the Port of London Authority, have argued that the wharf is essential infrastructure critical to the landing of marine-dredged aggregates that supply London and the South East.
A number of LPAs' safeguarding policies include similar exceptions; consequently, this appeal decision is eagerly awaited by both sectors.
What can we learn from these projects?
The development plan is key. Mineral safeguarding policies will be set out in minerals local plans. However, with the current two tiers of planning authorities, this mapping data is not always incorporated into the borough or district local plans and policy maps.
When considering a potential development site, it is important to check the entire development plan, including any minerals local plan.
In addition to defining mineral safeguarding areas, minerals local plans will also define mineral consultation areas, which wrap around existing mineral operations. The mineral planning authority will be consulted on planning applications proposing non-mineral development in these consultation areas.
Applicants need to demonstrate that their proposed development will not adversely affect the existing mineral or safeguarded waste operations – 'the agent of change principle' – mentioned in the NPPF.
This principle simply means that whoever introduces change must deal with it and its consequences. As with the Greenwich Wharf case study, the developers of the Millenium Village had to deal with the noise generated by the existing mineral activities.
Safeguarded minerals do not always require prior extraction. Historically, planning authorities have taken a broad-brush approach to the designation of mineral safeguarding areas, sometimes incorporating areas of existing built development.
Site-specific factors such as poor quality or shallow bands of mineral deposits, the proximity to residential developments and utilities, groundwater levels, environmental designations, to name but a few, can all affect the viability of a resource. These may remove any requirement for prior extraction of the minerals.
Increasingly, LPAs are trying to ensure that any mineral that is excavated as a result of opportunistic or incidental extraction is appropriately used within the development.
Examples of this includes its use in landform development or, where the mineral can meet British Standards, it may be used on site in concrete manufacture with the associated environmental and financial benefits.
The earlier safeguarded minerals or infrastructure is considered the better. If a development site is covered, even if only in part, by a mineral safeguarding or consultation designation, it is important to acknowledge it and seek professional minerals advice.
It may be necessary to commission a mineral resource assessment, which may require site investigation works. If considered at an early stage, investigative works can be carried out alongside the usual site investigations, with associated savings in time and costs.
On large development sites, there may be opportunities to work in partnership with mineral operators to promote creative designs, unlocking both mineral extraction and built development to the benefit of both sectors.
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