Minerals

LEEDS LOCAL PLAN (2024 to 2042)

Minerals Supporting Paper

Regulation 18 Consultation

June 2025

VISION

Minerals are important to the local and national economy and underpin the fabric of our everyday lives. In Leeds minerals produce building stone, clay is used for making bricks, aggregate is used in  concrete and other construction products. Aggregate Minerals (principally sand and gravel and crushed rock), like all other minerals, make an essential contribution to the nation’s prosperity and to the quality of life. They underpin the construction sector and provide the critical raw material for built development, other construction, manufacturing, and the maintenance of infrastructure.

We want to ensure that Leeds has a steady and adequate supply of the minerals that are needed, whilst ensuring that best use is made of them to secure their long-term conservation.

We aim to manage current mineral reserves and safeguard future resources where practical. We also want to encourage recycling of minerals where possible to reduce demand on primary resource extraction. Policies aim to:

• Define a Mineral Safeguarding Area for sand and gravel to prevent sterilisation of this important resource that would stop it being available in the future.
• Encourage the prior extraction of minerals, where practical and environmentally feasible, if it is necessary for non-mineral development to take place.
• Safeguard existing extraction sites to ensure the supply of minerals of local and national importance.
• Identify where future mineral supply should come from, including marine aggregate sources, to ensure a steady and aggregate supply and maintain landbanks of at least 7 years for sand and gravel and at least 10 years for crushed rock.
• Maximise the use of secondary and recycled aggregate to reduce pressure on primary resources.
• Ensure mineral activities can operate effectively without conflicts with other uses.
• Support the sustainable transport of minerals.

At the local level, the Best City Ambition sets the overall vision for the future of Leeds, focussed on improving outcomes across the 3 Pillars of health and wellbeing, inclusive growth and zero carbon. Minerals planning has an important role to play as part of this, as follows:

1. Health and wellbeing; ensuring minerals use is appropriately managed to support good health and wellbeing for all parts of the city. The shortage of construction products pushes up the cost of house building and in turn affects the ability of people to afford decent homes.

2. Inclusive growth; ensuring there is sufficient supply of minerals that are needed for construction, supporting the job opportunities within the minerals sector and recognising the importance of a skilled workforce.

3. Zero carbon; supporting the transition to a low carbon economy and ensuring the efficient use of minerals and supporting the sustainable movement of minerals and their products. Movement of minerals by water or rail has significantly lower carbon emissions than by HGV.             

EXISTING POLICIES

Core Strategy 2014 

Policy EN7 sets out which minerals require a mineral safeguarding area (MSA) in Leeds, based on proven deposits of minerals of local and national importance ie. sand and gravel and coal.  It also sets targets for aggregate apportionment and commits to identifying opportunities to ensure that aggregates can be transported by non-road based freight into the city and maximise opportunities for marine-won aggregate to contribute towards supply.

Natural Resources and Waste Local Plan (NRWLP)2013 (2015 Minerals Transport)

Policy MINERALS 1

Sets targets for the supply of aggregates

Sand and gravel = 146,000 tonnes per annum

Crushed rock = 440,000 tonnes per annum

These targets are set for Leeds based on population growth but since they were adopted the Local Aggregate Assessment has been prepared collectively with the other West Yorkshire Authorities, which is a more realistic way to plan for an aggregate supply.   

Policy MINERAL 2 and MINERALS 3

The NRWLP sets out policies for the safeguarding of minerals of local and national importance and the definition of mineral safeguarding areas for sand and gravel and for coal on the Policies Map. The relevant policies are MINERALS 2 for sand and gravel and MINERALS 3 for coal.

Policy MINERALS 4 safeguards existing mineral extraction sites.

Policy MINERALS 5 sets out how the target for sand gravel in Policy MINERALS 1 will be met. Through an allocation at Midgley Farm, Otley and area of search at Methley.

Policy MINERALS 6 states that it is unlikely that proposals for the extraction of sand and gravel within the area to the east of Pool in the Wharfe Valley will be supported.

Policy MINERALS 7 identifies Preferred Areas for stone and clay extraction. Areas of stone are also likely to contribute towards the supply of crushed rock.

Policy MINERALS 8 applies when there is a need to re-open a dormant quarry to provide local stone for the repair of historic buildings.

Policy MINERALS 9 provides criteria which will be used for determining mineral applications.

Policy MINERALS 10 states that restoration of mineral extraction sites which bring improvements to environmental quality and biodiversity will be supported.

Policy MINERALS 11 applies to aftercare and maintenance.

Policy MINERALS 12 safeguards existing mineral processing sites.

Policy MINERALS 13 safeguards existing canal wharves and rail sidings that are important for the sustainable movement of minerals and other freight and allocates a new canal wharf site and a new rail siding site for mineral processing.

Policy MINERALS 14 provides criteria for the consideration of alternative uses on sites protected by MINERALS 13.

UDP Policy GP5 refers to stability and public safety.

PLAN OBJECTIVES

The Natural Resources and Waste Local Plan contains objectives for this topic which are still relevant and fit for purpose. The objectives which relate to the Minerals topic are as follows:

AN EFFICIENT USE OF NATURAL RESOURCES

• The prudent use of natural resources is at the heart of the way things are done in Leeds.

• Ensure sufficient contribution to supply for local and regional minerals demand is provided, but look to use secondary / re-cycled materials first.

• Avoid sterilising future mineral resources.

• Efficient use of previously developed land, especially contaminated land.

A ZERO WASTE HIGH RECYCLING SOCIETY

• Support activities to reduce the level of waste produced.

• Maximise the reuse of waste.

• Maximise recycling and composting waste where possible.

A LOW CARBON ECONOMY

• Promote sustainable movement of freight including minerals.

• Make better use of the water and rail transportation networks

• Support the co-location of natural resource activities to minimise transportation impacts.

A HIGH LEVEL OF ENVIRONMENTAL PROTECTION

• Ensure the protection of the quality of watercourses and other sources of water.

• Ensure flood risk is managed, taking into account the effects of climate change.

• Protect and enhance the environment including the District’s heritage.

These objectives will be summarised and consolidated in the new Leeds Local Plan. 

SCOPING CONSULTATION

A scoping consultation took place on the Leeds Local Plan from 10th February to 24th March 2023. The results can be broadly summarised as:

Overall support for Minerals & Waste issues to be in the scope of the Plan

- 86% respondents agree that the amount of waste produced should be reduced.

- 78% think that minerals should be moved around in the most sustainable way

Support for ensuring that we minimise the impact of both mineral extraction and waste management on the environment and the amenity of communities.

- 67% of respondents had no opinion on whether aggregate came from the seabed or land-based quarries, but of those that did have an opinion, more preferred land-based extraction because it was largely considered that dredging the seabed is more environmentally harmful (although this is not in fact the case indicating that we need to provide more information on this issue) and there was a view that once quarrying is complete the site could be remediated and used for community uses, such as green space (again more factual info needs to be provided on this).

Support for transportation of minerals via waterways or rail rather than road network.

Comments from industry include requesting sites to be close to the market to reduce transport requirements, and support for the introduction of buffer zones to minimise negative impacts.

Some respondents, such as the Canal and River Trust have asked for further detailed discussions with us which we will be having in the next stage of plan preparation. We would also welcome detailed discussions with mineral operators, the Mineral Products Association and with rail freight companies and Network Rail.

KEY EVIDENCE / JUSTIFICATION 

The British Geological Survey Technical Report WA/92/1, Leeds: A Geological Background for Planning and Development, identifies alluvial deposits of sand and gravel within the district. These have been used as the basis for the mapping of the Mineral Safeguarding  Area for sand and gravel which excludes areas already worked, tributary areas which are very unlikely to contain significant amounts of sand and gravel, areas already worked primarily for surface coal and areas where the resource is overlain by a substantial depth of made ground, for example by deposited waste materials. Evidence suggests that the sand and gravel is not of a sufficient quality for it to be suitable for concrete making and therefore aggregate still has to be imported from elsewhere.

Leeds City Council works with the other West Yorkshire mineral planning authorities to prepare an annual Local Aggregate Assessment. The West Yorkshire Local Aggregate Assessment (WYLAA) forecasts future demand, based on a rolling average of 10 years’ sales data and other relevant local information, and an assessment of all supply options (including marine dredged, secondary and recycled sources). lt also looks at average sales over the last 3 years to identify the general trend of demand, as part of consideration of whether it might be appropriate to increase supply.

The WYLAA provides an analysis of all aggregate supply options, mineral plan allocations and capacity data e.g. marine licences for marine aggregate extraction, recycled aggregates and the potential throughputs from wharves. It uses this information to give an assessment of the balance between demand and supply, and the economic and environmental opportunities and constraints that might influence the situation. It indicates if there is a shortage or a surplus of supply compared with the landbanks required in the National Planning Policy Framework.

The targets for sand and gravel and for crushed rock set in the Natural Resources and Waste Local Plan under Policy Minerals 1 were informed by the Government’s National and Regional Guidelines for Aggregates Provision in England 2005-2020. They were based on the sub-regional apportionment in the now revoked Yorkshire and Humber Regional Spatial Strategy 2008 and extrapolated out to 2026 based on forecasted population growth. As this approach is now significantly out of date it is not a robust way to plan for future supply and the WYLAA provides a more reliable basis for planning for an adequate supply.

The WYLAA  2023 west-yorkshire-local-aggregate-assessment-2022-data.pdf (westyorks-ca.gov.uk) contains the following key messages and relevant considerations when assessing proposals and allocations for development relating to the supply of aggregates:

i. Additional aggregate supplies will be required for housing and infrastructure -Housing delivery has significantly improved in West Yorkshire in recent years; however, there remains a gap between the number of houses being built and the objectively assessed need for new housing. However, in the coming years recessionary effects may impact on housing delivery. A range of infrastructure projects are in the pipeline including ; Mass Transit for West Yorkshire, Northern Powerhouse Rail and upgrades of the Trans Pennine rail route and associated Rail Interchange upgrades. Infrastructure needed to achieve net zero (e.g. wind turbines) will place further demands on aggregate minerals. Additional aggregate supplies will be required to ensure the housing delivery gap is filled and the construction aggregate demands of the infrastructure projects are met.

ii. The aggregate resource in West Yorkshire is limited – The geology of West Yorkshire means that indigenous supplies of high quality land won aggregate, for use in concrete and road building, are difficult, if not impossible to obtain.

iii. West Yorkshire currently makes a small contribution to supply of construction aggregates – West Yorkshire is a major aggregate consumer but makes a low contribution to the overall supply of construction aggregates within the Yorkshire and Humber Region, particularly in relation to sand and gravel and high specification crushed rock.

iv. The resilience of the sand and gravel landbank is questionable – Reserves and production of sand and gravel within West Yorkshire are still at a very low level. The apparent significant improvement in the landbank is due to the low level of sales and permissions granted in 2022, however the deliverability of one of the new permissions is uncertain which means the landbank may not be very resilient and should not be taken as an indication that there is no need for additional reserves. The industry has noted that there is an ongoing national depletion in permitted reserves and this is of significant concern.

v. Crushed rock landbank is healthy but includes mainly lower specification material - Crushed rock reserves remain relatively high within West Yorkshire; however, a substantial proportion of the currently permitted reserves are Carboniferous Sandstone which is unsuitable for higher specification uses, such as for the manufacture of concrete or as roadstone.

vi. West Yorkshire is very reliant on neighbouring Mineral Planning Authorities - To meet most of its aggregate needs, particularly for uses which demand higher specifications, West Yorkshire is reliant on aggregate imports, primarily from quarries in the Yorkshire Dales National Park, Derbyshire and Durham. These areas currently have healthy landbanks though this may change in the long term.

vii. For road surfacing West Yorkshire remains strongly reliant on aggregate imported from the Yorkshire Dales National Park - To meet its needs for aggregate suitable for use as skid resistant road surfacing, West Yorkshire remains strongly reliant upon supplies of high specification (high Polished Stone Value) sandstone aggregates from quarries in the Yorkshire Dales National Park.

viii. Sustainable opportunities to increase aggregate supply in West Yorkshire- Given West Yorkshire’s reliance on adjoining authorities for higher specification aggregates, any sustainable opportunities to increase the supply of the generally lower specification aggregates produced within West Yorkshire should be considered upon their merits, particularly where such proposals would facilitate the indigenous production of building materials such as artificial stone products.

ix. Increase Recycled Aggregates - Providing new and enhanced facilities for the production of recycled aggregates will assist in West Yorkshire’s contribution to aggregate production & help to compensate for its reliance on primary aggregates quarried from neighbouring authorities.

x. Building Sand from Sandstone Quarries - Production of sand from crushed rock at sandstone quarries in West Yorkshire, including building stone quarries, is a valuable additional/ alternate source of sand supply, particularly building sand.

xi. Safeguarding Existing, and Developing New, Rail Sidings and Wharves - Existing rail and wharf infrastructure should be safeguarded. In light of the single wharf importing aggregate by barge ceasing operation in 2022, potential new locations for aggregate wharves and rail depots for the importation of marine aggregate should be investigated with greater urgency and their suitability for importation of crushed rock from the Yorkshire Dales should also be considered. Current industry interest in utilising waterways to transport minerals within West Yorkshire should continue to be supported. Removing HGVs from the road network to these transport modes would help improve air quality.

xii. Overarching message: Planning for continuity in the supply of the aggregates consumed in West Yorkshire is far more dependent upon effectively cooperating with neighbouring authorities and safeguarding minerals sustainable transportation infrastructure (i.e. rail sidings and wharves) than managing aggregate supplies within West Yorkshire itself.

Sand and Gravel

The WYLAA 2023 (based on 2022 data) states that the sand and gravel landbank is currently at 24 years and 4 months. Although this is significantly above the minimum landbank of 7 years required by paragraph 213(f) of the National Planning Policy Framework it should be borne in mind that it is a rolling 7 year landbank and the Local Plan needs to provide for the whole plan period and beyond. Furthermore the improvement in the landbank is due mainly to planning permission having been granted in 2022 for the new sand and gravel quarry in Wakefield with a 1.6 million tonne estimated reserve to be worked at a rate of 150,000 tonnes per year (around 10.7 years). Another, much smaller site was granted permission in Bradford and together these additional reserves helped result in a landbank exceeding the minimum 7 year requirement for the first time in seven years, however the resilience of this landbank is highly dependent on the newly permitted site in Wakefield which is not yet fully operational.

Whilst the landbank is in surplus at present, the extraction of sand and gravel within West Yorkshire remained at a very low level in 2023 - with most of the sand and gravel being sourced from quarries located in other mineral planning authority areas. Once operational, the newly permitted sites will result in an increase in sales in West Yorkshire but these will still be at relatively low levels and it cannot be assumed that they will meet the need within Leeds. In any case it is unlikely that the Wakefield quarry would last for the plan period meaning that there is still a need for Leeds to improve resilience by identifying opportunities for local supply and to facilitate the movement of marine sand and gravel into West Yorkshire.

Crushed Rock

The WYLAA states that the current landbank for crushed rock is at 35 years and 3 months. This is significantly above the 10-year minimum level required by the NPPF.

According to the Aggregate Minerals Survey for England and Wales 2019 the majority of the construction aggregate produced in England and Wales was used for either concrete manufacture (31% in 2019) or road construction (25% in 2019). The mineral resources which are worked within West Yorkshire are generally thought to be incapable of producing significant quantities of the higher specification aggregates required for use in either road construction or concrete manufacture. Consequently, West Yorkshire will remain reliant upon the crushed rock aggregates produced in neighbouring authorities to meet most of its construction aggregate needs. Two principal sources for the crushed rock aggregates consumed within West Yorkshire are the Yorkshire Dales National Park and Derbyshire. Quarries from these two areas collectively provided for over two thirds of the crushed rock aggregates consumed within West Yorkshire in 2019 according to the data tables provided by the British Geological Survey (BGS) in association with the 2019 National Aggregate Minerals Survey 2019 (AMS2019). A significant quantity of crushed rock comes from Howley Park Quarry in Leeds as a bi-product of the extraction of sandstone. This quarry is the largest producer of crushed rock in West Yorkshire.

It is recommended that Leeds seeks to identify sources of aggregate that are not within a national park or could be moved from the National Parks to the district by sustainable forms of transport (ie rail or canal). This should be agreed with the other West Yorkshire Mineral Planning Authorities (MPAs) since we have a joint Local Aggregate Assessment with them and some areas are better able to supply aggregate than others. A statement of common ground between the West Yorkshire MPAs should be written to set out how we will meet the apportionment and agree the differences in the contribution that each MPA can make. Hull and East Riding of Yorkshire should also be signatories to confirm that they are happy for marine aggregate to be landed in the Humber Estuary and will safeguard the relevant wharves. The Statement of Common Ground should be taken to the Yorkshire and Humber Aggregate Working Party to seek ‘additional signatory’ from the minerals industry.

Secondary and Recycled Aggregate

Secondary aggregate is produced in Leeds as a by-product of the extraction of dimension stone. Quarries where this occurs are safeguarded under Policy Minerals 4. Additionally it is possible to manufacture aggregate for example OCO Technology in Cross Green use carbonated thermal wastes to make an aggregate that can be used in construction. This type of activity would fall as an industrial use and such sites are not currently safeguarded for mineral or waste use in the Local Plan.

Biffa Waste have planning permission to manufacture recycled aggregate at Whitehall Yard. This is a rail connected site that brings in 60,000 tonnes per annum of street cleansing residues with 48,000 of it coming in by rail. This reduces the number of road based trips needed as one lorry can move up to 20 tonnes of material but a train can move up to 1200 tonnes of material. When installed the facility would produce recycled products which comprise 45% sand, 25% aggregates, 10% silt/clay and 20% lightweights/organics. In total, 70% is a usable building product highlighting the value in recovery of waste. The small % of remaining residues will be  moved by train to landfill at Roxby in Lincolnshire.

Classification of construction aggregates by their origin or source:

Marine Aggregate

Marine aggregate from the North Sea is consistently good quality and of a higher quality than most of the indigenous sand and gravel in West Yorkshire. It has also been shown that it reduces the quantity of water and cement needed to make concrete of the same performance.

The Crown Estate (as landowner) provides annual data about the areas that are licensed for marine aggregate dredging and the tonnages removed and where they are landed. The degree to which demand is met by imports of marine aggregate into West Yorkshire is not recorded in the WLYAA due to the limited response to the survey, however the Crown Estate shows that there is significant resource available within the licensed areas.

The 2025 statistics from the Crown Estate provide 2024 data at the sub-regional level on marine production and imports, provided by The Crown Estate Licences. In 2024 1,194,000 tonnes of marine aggregates were delivered to the Humber region, with a further 0.65m tonnes delivered through secondary use from licences. The majority of this was to River Tees wharves (631,000 tonnes), River Tyne wharves (284,000 tonnes), River Humber wharves (232,000 tonnes) and Blythe (47,000 tonnes). Source: https://www.datocms-assets.com/136653/1746700986-mineral-summary-statistics-2025.pdf

There were 3.32 million tonnes of primary aggregate extracted from the permitted 6.87 million tonnes, with 69% of this being delivered to mainland Europe, 26% within the Humber & North East, and 4% to Thames Estuary. The graph below shows the permitted and extracted tonnage. There is estimated to be 13 years of supply of primary aggregate production permitted in the region, which could increase by 5.8 million tonnes annually if the Crown Estate approves all five current applications for new licences. 

Production licences are only released after the Crown Estate has completed rigorous Habitat Regulations Assessment and therefore we can be assured that there are no significant environmental effects arising from the dredging of marine aggregates in licensed areas. The Marine Aggregate Study 2022 commissioned by the West Yorkshire Combined Authority identified significant potential for more marine aggregate to contribute to supply in West Yorkshire.

Moving aggregate into Leeds by lorry brings problems of pollution from the lorries as well as adding to congestion on the roads, increased risk of road accidents and the need for road repairs. However Leeds is fortunate to have both rail and canal infrastructure both of which are suitable for the movement of aggregate in a more sustainable way. Marine aggregate from the Humber area of the North Sea is landed at the Albert Dock in Hull and can be moved by barge along the Aire and Calder Navigation. This has been an objective of the Natural Resources and Waste Local Plan (NRWLP) since 2015 when policies were adopted in that Plan to safeguard the canal wharf infrastructure to ensure that the potential for unloading barges is retained in Leeds.

The WYLAA 2023 recognises that marine aggregates are likely to become an increasingly important component of minerals supply in West Yorkshire. The Marine Aggregate Study 2022 identifies a site in Stourton, Leeds as having the best potential for receiving marine aggregate moved by barge.

The Department for Transport (DfT) reports that moving freight by water reduces the amount of nitrogen oxides put into the atmosphere by about 35% (Sea and Water, Department for Transport (DfT), March 2006). Given that lorries often have to return empty the actual saving on air pollution is much greater. If marine aggregate is brought by HGV from Hull to Leeds it would necessitate a 90 mile round trip.

The Tyndall Centre for Climate Change (Manchester University) estimates that carbon dioxide emissions from barge transport are 25% lower than those from road transport.

Movement of marine aggregate from Hull to Leeds by barge took place from 2015 till January 2023. The operator, AC Marine, was moving over 1,000 tonnes of sand and gravel by barge each week to a wharf at Knostrop Depot, replacing the need for 35 HGVs coming in and out of Leeds. Demand for marine sand became so high that the land available at Knostrop Depot was not sufficient to meet the need resulting in the operator having to return to road based movements so as to avoid the need for fragmented operations at different sites. This highlights the urgent need for the availability of a wharf in Leeds of sufficient size to accept incoming marine aggregate.  Caspar Shipping have purchased a 600 tonne barge, the MMS Offroader, and have commenced barge movements of cement from Lisbon to the wharf at Haigh Park Road, Stourton and there is potential for marine aggregate to also be off-loaded there.

The Natural Resources and Waste Local Plan safeguards three wharves in Leeds and allocates a further site for the construction of a new wharf. Landowners, including the Canal and River Trust, frequently have aspirations for higher value uses on their land, eg residential, however the proximity of wharves to a watercourse frequently means they are in high flood risk areas making them inappropriate for residential use. Additionally, the many benefits of having places where barges can load or unload for movement by water means that it is sensible for the Council to ensure that the limited wharves that we have in the district remain available to retain the opportunity for low carbon transport movements by barge to take place. 

The Canal and River Trust are currently seeking funding for the construction of the inland port at Stourton which will accept marine won aggregate. There is sufficient land at the site for an aggregate washing facility and a mineral processing plant to be co-located on the site.

The National and Regional Guidelines for Aggregates Provision in England 2005 – 2020 estimated that the Local Aggregate Provision for Yorkshire and the Humber should include 5 million tonnes of marine aggregate.

EMERGING POLICY APPROACH

Should Leeds continue to set targets for aggregates in Core Strategy Policy EN7 and NRWLP Minerals 1, given that it is a task for West Yorkshire to set a sub-regional apportionment? Policy MINERALS 1 is an attempt at local aggregate apportionment but this is done annually now in the WYLAA. Nether-the-less Leeds needs to contribute as much as is possible, given that the district has limited resource and what there is tends to be in high value landscape areas, however we do contribute a very large amount in crushed rock.

Current targets set for the supply of aggregates in the NRWLP (Sand and gravel = 146,000 tonnes per annum and Crushed rock = 440,000 tonnes per annum) are based on population growth, so if Leeds wishes to continue to set its own targets these figures would need to be updated to reflect population growth forecasted for the plan period, however a more realistic approach is to prepare a Statement of Common Ground between the WY authorities to set out how the LAA will be met and contributions from each Mineral Planning Authority.

The allocation at Midgely Farm has not come forward and at the Yorkshire and Humber Aggregate Working Party (YHAWP) meetings, mineral operators have stated that they consider it to be too difficult to secure a consent for it given the local environment. However, the mineral rights are now vested with the Church Commissioners who do not attend the YHAWP. It is unknown as to whether they have any wish to bring the site forward. Given the lack of certainty there is doubt as to whether Midgley Farm should continue to be an allocation for sand and gravel extraction.

An area at Harewood has been proposed through the call for sites process. This will need to be evaluated as to whether it could be supported as an allocation (see Alternative Options section below). The site is in an area of the Wharfe Valley which has high landscape value.

An area of search for sand and gravel extraction exists at Methley. The area is very close to residential areas and is in the functional floodplain meaning that workings may have to be pumped out. The Council does not have sufficient data about the quality of the material or whether it could be economically viable to work.

The West Yorkshire Local Aggregate Assessment highlights that providing new and enhanced facilities for the production of recycled aggregates will assist in West Yorkshire’s contribution to aggregate production & help to compensate for its reliance on primary aggregates quarried from neighbouring authorities. Leeds has an opportunity to address this through the allocation of specific sites for aggregate recycling. These will need to be in locations which are accessible and appropriately sited.

If a target is to continue to be set in policy MINERALS 1 it should reflect local circumstances and constraints and also include an estimate for the proportion that could be met from marine aggregate and secondary and recycled aggregate. The NPPF states that MPAs should maintain a landbank however, there is clear evidence that this will be a struggle in Leeds due to a mixture of geology and landscape designations and therefore it can be justified that secondary and recycled aggregate and marine sources of aggregate can contribute a proportion of the supply instead. This would also reflect the position nationally. MINERALS 1 could be reworded to state that we will work with the other West Yorkshire authorities to maintain a 7 year landbank for as long as resources allow.

Given the carbon emissions associated with the burning of coal, policy should make clear that Leeds does not support the extraction of coal for energy use. (Note that the Supreme Court ruled in June 2024 that Surrey County Council acted unlawfully when it granted permission for oil drilling at Horse Hill, near Horley because of the climate impacts of the inevitable burning of the oil). Therefore the Coal MSA is not needed. The sand and gravel MSA should be retained as it remains an important mineral locally and nationally (according to the definition in the NPPF). There is not enough information to know if the deposits of sandstone and limestone are viable, therefore as they are not proven deposits they do not need to be covered by an MSA. Reserves of clay are sufficient to support the needs well beyond the Plan period, such that a MSA for clay is not required.

ALTERNATIVE OPTIONS

Mineral Safeguarding Areas for Sand and Gravel and for Coal

Leeds declared a climate emergency in March 2019 and made a commitment for the city to be carbon neutral by 2030. Core Strategy Policy EN7 protects important mineral resources in Leeds from sterilisation. These include sand and gravel and coal. An option is to consider if we still need to protect the coal resource from sterilisation as the city wants to see a future that is not based on fossil fuels.

An option is to delete Policy MINERALS 3 and the Coal MSA. The emphasis now is on remediation and therefore Minerals 3 could be replaced with a policy focussed on safe development in the former coalfield areas.

Sand and gravel remains an important mineral resource for the district and should continue to be protected from sterilisation. The policy includes targets for aggregate provision in Leeds for the plan period and these targets could be updated to reflect the fact that the annual Local Aggregate Assessment is prepared jointly with the other West Yorkshire Authorities. Consideration should be given to including targets for secondary and recycled aggregate and for marine aggregate as these are increasingly becoming more important sources of supply in Leeds.

Sand and Gravel Extraction

Given that the allocation at Midgely Farm has not come forward since it was allocated in the Leeds Unitary Development Plan in 2006, should this continue to be an allocation? Is there a need for Leeds to make new allocations either at Methley or elsewhere in the Wharfe Valley or both? Is it more realistic for Leeds to plan to move away from a land-won supply?

We would welcome views from industry on whether other sites could be viably worked. If a new allocation is to be made we will need sufficient data to support that. Criteria for viability include the thickness of the resource in relation to surface area, the quality of the resource and whether it would be suitable for concrete making, the total recoverable tonnage,  the cost of extracting the resource/the extent of any impediments such as the cost of accessing the potential site and the stand off from roads, rivers, gas pipelines, pylons, canals, the land owner’s cut and the cost of bringing it to market.

Crushed Rock

A significant quantity of crushed rock comes from Howley Park Quarry in Leeds as a bi-product from sandstone and clay extraction. This quarry is the largest producer of aggregate in West Yorkshire.  West Yorkshire also imports crushed rock aggregates produced in neighbouring authorities to meet much of its construction aggregate needs. Two principal sources for the crushed rock aggregates consumed within West Yorkshire are the Yorkshire Dales National Park and Derbyshire. Quarries from these two areas collectively provided for over two thirds of the crushed rock aggregates consumed within West Yorkshire in 2019 according to the data tables provided by the British Geological Survey (BGS) in association with the 2019 National Aggregate Minerals Survey 2019 (AMS2019). Brick clay is a mineral resource of local and national importance and the quarry at Howley Park provides a significant role in ensuring that West Yorkshire meets the NPPF landbank requirement for crushed rock. Reserves of clay at Howley Park are sufficient to support need well beyond the plan period and the opportunity to make bricks adds greater value.

The Natural Resources and Waste Local Plan safeguards Howley Park quarry and brickworks and also an extension to it. The quarry and brickworks are safeguarded as site 5 under policy MINERALS 4. The extension is a ‘preferred area’ for stone and clay extraction under Policy Minerals 7.

Mineral Processing

Sites which are suitable for concrete batching, the manufacture of coated materials, asphalt, and other concrete based products play a necessary part in the economy and development of the City. Whilst they do not necessarily require large areas of land, they often have an adverse impact on the surrounding environmental quality and the high buildings and hoppers for production and blending are unsightly. National policy encourages the safeguarding of existing, planned and potential sites including any with rail or wharf infrastructure and suggests that, where appropriate, new sites to meet future needs should be identified in Local Plans. Adopted Policy MINERALS 12 safeguards existing mineral processing facilities in Leeds.

Given the increase in construction arising from LLP2040 it is likely that there will also be a need for at least one additional appropriately sited mineral processing facility within Leeds.

Previous options considered in the preparation of the existing Plan included safeguarding existing sites or providing a criteria based policy for assessing suitability of sites. The options that are appropriate to consider now are

Option 1 – Continue to safeguard existing sites and allocate a new site for mineral processing and related activities under MINERALS 12

Option 2 – Continue to safeguard existing sites but do not allocate a new site for mineral processing and related activities.

Option 3 – Seek opportunities for railheads or wharves on the inland waterways network to provide shared facilities for minerals, waste and other materials? 

Buffer Zones 

Leeds is a unitary authority so it doesn’t have an arrangement for consultation on minerals planning applications with a County authority, however there is still a need to ensure applications for development will not be located in areas which may lead to conflicts with existing operational mineral sites (the agent of change principle). We currently have an internal, informal process whereby there are buffer zones for mineral processing activities and quarries that trigger the need for the Council’s Minerals Team to give their expert opinion on whether proposed users (eg residents) could be affected by existing activities. These buffer zones need to be formally created so they can be seen on the Policies Map and so that all developers, residents and other agencies are aware of them. An associated policy is needed to explain the purpose of the buffer zones i.e to avoid conflict with residential permissions and to protect the resource so it is not operationally difficult to extract in the future. This could be either as a new policy or an addition to existing policies.

We would welcome views on this approach to buffer zones and how big buffer zones should be for different types of activities.

Aggregate Recycling

The WYLAA highlights that providing new and enhanced facilities for the production of recycled aggregates will assist in West Yorkshire’s contribution to aggregate production & help to compensate for its reliance on primary aggregates quarried from neighbouring authorities. Leeds has an opportunity to address this through the allocation of specific sites for aggregate recycling. These will need to be in locations which are accessible and appropriately sited. The adopted Natural Resources and Waste Local Plan considered a number of options in this regard and allocated a site at Cinder Oven Bridge for construction, demolition and excavation waste. This site was affected by the safeguarding requirements of HS2 but still remains available. It may therefore be appropriate to consider whether that site could also be a suitable location for aggregate recycling or whether an additional/ alternative site is needed. Sustainability appraisal of previous options during the preparation of the Natural Resources and Waste Local Plan rejected options around the use of former mineral workings with suitable hardstanding areas and a general approach to encourage aggregate recycling alongside a criteria policy for assessing the location of facilities. Leeds does not have its own recycled aggregate washing facility with the nearest one being at Skipton, therefore the preferred approach is for the Local Plan to allocate a site for this activity to take place.

Coal

The NPPF makes a presumption against opencast coal mining (para. 223), therefore Leeds does not allocate land for surface coal extraction, however, to prevent sterilisation of the resource within the urban area, the prior removal of coal from development sites is encouraged when a site is being redeveloped.

The validation criteria requires that developers have to submit a coal recovery report for applications in the coal resource area which, until January 2021, was checked by the Coal Authority (who have now been re-named as the Mining Remediation Authority). However in January 2021 the Coal Authority changed their stance on this and wrote to Leeds stating that they would:

• No longer seek for prior-extraction to be considered when considering planning applications for sites where surface coal resource is present.

• No longer request that development plans include policies to safeguard the surface coal resource nor to promote its extraction or the extraction of associated unconventional hydrocarbons.

The National Planning Policy Framework promotes a low carbon future and contains a presumption against the extraction of coal, except where extraction can be made “environmentally acceptable” or where it is clearly demonstrated that socio-economic benefits outweigh environmental costs (paragraph 223). However, in conflict with the presumption against coal as an energy resource, the NPPF also requires the protection of mineral resources, which include coal reserves. Minerals resources of local and national importance are defined in the NPPF as ‘minerals which are necessary to meet society’s needs’ and it lists surface coal as an example.

In June 2024 the Supreme Court ruled that downstream greenhouse gas emissions (GHG) must be assessed before a decision to grant planning permission for fossil fuel extraction (Finch on behalf of the Weald Action Group v Surrey County Council). The judgement concluded that it was inevitable that GHG emissions would result from the burning of the oil produced, that those emissions were clearly indirect effects of the development, and that the Council’s failure to assess and consider the impact of those emissions on the climate and global warming was unlawful. This means that on the grounds of the GHG that would be emitted, it is unlikely that Leeds City Council would grant planning permission for coal extraction as fossil fuel use will inevitably lead to an increase in global warming which will only serve to exacerbate the climate emergency.

Given these changes since the adoption of the existing policy MINERALS 3 it is appropriate to consider if the Local Plan should continue to identify a coal Minerals Safeguarding Area (MSA) and to review the wording of policy MINERALS 3. It may be appropriate for coal NOT to be considered as a mineral necessary to meet society’s needs.

The Mining Remediation Authority (aka Coal Authority) continue to support prior extraction where this would provide a cost-effective solution to remediating potentially unstable land affected by coal mining features. However, the principal purpose of this is to achieve safe and stable development, not to extract coal for its value as an energy resource.

The NRWLP identifies the extent of the coal resource on the Coal Resources Map. Applicants are required to submit a Coal Mining Risk Assessment with applications for development in the Coal Resource Area. The purpose of this is to ensure that where development is proposed in the former coal mining legacy area, that it will be free from risks of combustion and land instability. Where it is practical and environmentally feasible, the removal of any remaining surface coal as part of site preparation may be a way to eliminate those risks.

There is an option to consider re-wording MINERALS 3 so that it is based on coal removal for safety purposes as part of prior extraction. A Coal Mining Risk Assessment would still be required but there would be no requirement to submit a Coal Recovery Report.

The Mining Remediation Authority defines development areas based on their degree of risk. All land within the former coalfield area falls within either Development High Risk Area or Development Low Risk Area. The Development High Risk Area could be used as the boundary for the policy area.

Shale Gas (Fracking)

Why is it needed?

Introduction

Fracking is a technique for recovering gas and oil from shale rock. It involves drilling into the earth and directing a high-pressure mixture of water, sand and chemicals at a rock layer, to release the gas inside.

There is currently uncertainty about the viability of fracking in the UK, due to uncertainty around how much shale gas there is and how much could be accessed through fracking. In addition, there are concerns around health and safety, environmental and carbon impacts of fracking. Further information on this is set out below

Resource in Leeds

The 2013 Bowland Shale Study (Bowland Shale Gas Study - GOV.UK (www.gov.uk)) is widely cited and is the most recent information of its kind on the shale resource in Northern England. However, there has been some suggestion in more recent studies that this did not sufficiently incorporate the specific geology of the UK.  

The estimates of the energy that could be provided through fracking range from less than 10 years to 50 years of the UKs energy needs from gas. 

From London School of Economics in September 2022:

According to the British Geological Survey, initial estimates in 2013 suggested that the Bowland-Hodder area may have held between 23.3 and 64.6 trillion cubic metres (tcm), but a more recent analysis in 2019 suggested the figure is closer to 4.0 tcm.

Domestic demand [is] typically 70–80 billion cubic metres per year

The Upper Bowland Unit more closely resembles that found in the United States whereas there are some unknown factors involved with the Lower Bowland Unit. See Figure 1 for a map showing the extent of these prospective resources

The full extent of the resource will not be known unless exploratory drilling takes place and this has not happened and is unlikely to happen in the current climate.

What is it seeking to achieve?

The Local Plan approach to fracking is seeking to achieve the best, most sustainable outcome possible as relating to fracking. It seeks to support national emphasis on investment in renewable energy and enable Leeds, and therefore the UK, to meet its legal requirements under the Climate Change Act 2019.  

The approach seeks to protect landscapes and amenity within Leeds and avoid any health and safety risks to residents that may be caused by fracking. 

The approach acknowledges that, based on current understanding, there is unlikely to be a vast resource and that given the international nature of the gas market, any fracking that took place would not necessarily reduce energy bills in the UK.

Is it justified by the evidence? 

The Bowland study in 2013 (see link above) 

This has formed the basis for much of the policy and discussion on fracking as it is the only study of its kind that has taken place in the UK. It indicated that:

1. The upper unit is more prospective, primarily due to the better well control which demonstrates its closer resemblance to the prolific North American shale gas plays, in which the productive zones are hundreds of feet thick. The lower unit is largely undrilled, but where it has been penetrated it contains organic-rich shale intervals, whose lateral extent is unknown…There is considerable upside potential in the lower unit, but the resource estimation for this unit has a much higher uncertainty due to the paucity of well data so far and potentially less favourable lithologies.
2. The total range for estimated gas in place is 822 – 1329 – 2281 tcf (23.3 – 37.6 – 64.6 tcm) (P90 – P50 – P10) for the combined upper and lower parts of the Bowland-Hodder unit.
3. …However, only with further shale gas exploration drilling and testing over an extended period, and optimization of the extraction process, will it be possible to determine whether this identified shale gas prospectivity can be exploited commercially – and how significant a contribution it could make to the future UK energy mix…

• Following this report, the then Government announced that it was ‘going all out for shale’, which involved lower taxes and a simplified application regime. While fracking at lower scale has taken place before in the UK, the only site for High Volume Hydraulic Fracking was the high-profile Preese Hall site in Lancashire, drilled by Cuadrilla in 2011. This drilling was stopped after seismicity was recorded on the site. Fracking at this point became a controversial topic and a great deal of discussion on the safety of fracking has taken place, but less so on the economic viability. As mentioned above, the 2013 study remains the most detailed of its kind on the Bowland shale formation which partly falls within Leeds.
• Subsequent studies, however, have cast doubt on the 2013 study due to the methods used. industry has also barely taken advantage of fracking licences and, at times, a more supportive political environment. Subsequent studies include:

Subsequent studies

• Fraser et al, 2024, provide detailed data on the Bowland Shale formation and conclude that original estimates were over-optimistic: A review of the Carboniferous shale gas potential of northern England: a data-based analysis of why it won't work | Geological Society, London, Special Publications
  1. The recent shale gas revolution originated in the USA in the late 1990s with the exploration of the Carboniferous Barnett Shale in Texas. Success in a number of additional basins in North America, such as the Marcellus, Eagle Ford and Bakken basins, stimulated a search for similar opportunities elsewhere around the world. Among the shales and basins targeted by industry was the Carboniferous Bowland Shale (and equivalents) in northern England. The initial premise that the Barnett Shale represented an excellent analogue for the Bowland Shale led to over-optimistic reserve estimates that have since been shown to be largely incorrect. On the basis of visual inspection of wellbore cores, the Carboniferous Barnett and Bowland shales appear to be very similar. Unfortunately, it is there that the similarity ends. Research carried out for the UK Unconventional Hydrocarbons project has highlighted important differences adversely impacting prospectivity. These can be summarized as basin type/continuity and structural complexity. The total organic carbon, maturity, mineralogy and thickness of the Bowland Shale and equivalents are broadly similar to the successful US examples. Our conclusion is that the Bowland Shale in the UK does not represent a technically significant resource, and in hindsight did not merit the considerable industry and media attention that has been associated with it. One key learning is that fundamental research based on heritage data and modern analytical and modelling techniques should have preceded drilling and fracking operations in northern England…
  2. …As highlighted in the structural elements and palaeogeographic maps, the Bowland Shale and equivalents are preserved as a series of relatively narrow (25 km), finger-like bodies trending NW–SE in the East Midlands (Gainsborough Trough = 5000 km²) and NE–SW in Lancashire and Cheshire. This is in marked contrast to the continuous and regional nature of the organic-rich shale intervals in the Barnett (13 000 km²), Marcellus (250 000 km²) and Eagle Ford (20 000 km²) plays in the USA..
  3. …Roughly 12 years ago, industry and academia enthusiastically embarked on UK shale gas research with the premise that the organic-rich Bowland Shale and equivalents in northern England would provide UK shale gas resources that could fill an ever-widening gas supply gap from rapidly declining North Sea production. Initial in-place estimates published by the BGS (Andrews 2013) based on a possibly over-optimistic interpretation of the organic content of the deeper basin fill (Bowland, Hodder and equivalents) appeared to support the general optimism. However, our research involving geochemical, mineralogical and petrological analysis of over 100 core samples for this study and complimentary sampling for other studies, e.g. Hennissen et al. (2024), Sims et al. (2024), suggests a markedly different and more pessimistic resource outlook. To summarize, the key negative factors are the wrong type of basins (rift rather than foreland) and post-depositional structural complexity…
  4. …Several factors contributed to shale gas operations commencing before the fundamental research was in place. The major North Sea operators such as Shell and BP, with access to critical expertise and data, declined to take up exploration licences for UK shale gas. This left the field open to a dominance of underfunded and technically inexperienced exploration companies whose business objectives did not necessarily align with the public interest and who were slow to fund the necessary research in UK universities. It was not until 2014 that the government, through NERC and ESRC, actively funded research into UK shale gas resources. Before this, the void was largely filled by an underfunded geological survey that was slow to identify and respond to the issues and out of its depth when it was allocated the shale gas resource evaluation task…
• Emmings et al, 2024: An introduction to the Bowland Shale Formation, UK: processes and resources | Geological Society, London, Special Publications Provides a summary of recent studies of the Bowland Shale:

With the benefit of hindsight offered by the latest generation of research, the early regional shale gas assessments failed to attach sufficient weight to the compositional heterogeneity, structural complexity, compartmentalization and highly variable exhumation, erosion and palaeo-heat flow history of the Bowland Shale.

Studies on health and safety impacts

• More research on the health impacts of fracking has been able to take place in the United States, where fracking is now well-established:
• Study Links Fracking, Drinking Water Pollution, and Infant Health | URMC Newsroom
  1. The study is available at Drinking water, fracking, and infant health - ScienceDirect 

…fracking-related chemicals – including dangerous volatile organic compounds – are making their way into groundwater that feeds municipal water systems, and that the potential for contamination is greatest during the pre-production period when a new well is established.  With only 29 out of more than 1,100 shale gas contaminants regulated in drinking water, the results suggest that the true contamination level is higher. The study specifically finds that every new well drilled within one kilometer of a public drinking water source was associated with an 11-13 percent increase in the incidence of preterm births and low birth weight in infants exposed during gestation..

• Research by the US-based environmental charity Natural Resources Defense Council (NRDC: Air Pollution from Hydraulic Fracturing Threatens Public Health and Communities (PDF)) found that fracking can also cause air pollution near sites, including pollution by diesel, silica, and hydrogen sulphide (which is also explosive). All can cause serious respiratory illness, with particular impact on workers at frack sites.
• The previous government in 2019 implemented a moratorium on fracking due to concerns over seismicity

Local Position in Leeds

• Government offered licences for the exploration of the areas shown in  Figure 2, but the licenced area covered by PEDL275 was surrendered in 2020 by Hutton Energy Ltd. It has now lapsed and there are currently no interested operators
• If the Government were to offer more licensed rounds an operator could come forward, but this is unlikely as there was no interest in PEDL275 from any of the other fracking companies.
• The shale gas resource can be safeguarded either wholly or focusing on the areas that are most likely to provide accessible and viable shale gas (Upper Bowland)
• A policy could help manage the impacts and location of shale gas exploration and extraction

How will it help deliver the Council's corporate Strategy?

A fracking ban would prevent harm to health and wellbeing through potential fracking-related pollution. Fracking has not fully taken place for extraction in the UK, due to seismicity at Preston and the resulting moratorium. However, experience from the United States (where there is a greater resource and therefore fracking has been established) indicates that there could be a number of risks to health, wellbeing and safety for residents near a fracking site. Some of these studies have been set out above.  

A focus on renewable energy and moving away from support for fossil fuels will help Leeds to meet its carbon emissions targets and work towards its Zero Carbon goals. There is some indication that jobs in the fracking industry tend to serve a moving workforce that is largely male so are unlikely to have an impact on inclusive growth

How is it consistent with the NPPF?

NPPF (National Planning Policy Framework), December 2024:

223. Planning policies should: …

a) provide for the extraction of mineral resources of local and national importance, but not identify new sites or extensions to existing sites for peat extraction…

c) safeguard mineral resources by defining Mineral Safeguarding Areas and Mineral 

Consultation Areas; and adopt appropriate policies so that known locations of 

specific minerals resources of local and national importance are not sterilised by 

non-mineral development where this should be avoided (whilst not creating a 

presumption that the resources defined will be worked); 

228. Minerals planning authorities should: 

a) when planning for on-shore oil and gas development, clearly distinguish 

between, and plan positively for, the three phases of development (exploration, appraisal and production), whilst ensuring appropriate monitoring and site restoration is provided for… 

Glossary: Minerals resources of local and national importance: Minerals which are necessary to meet society’s needs, including aggregates, brickclay (especially Etruria Marl and fireclay), 

silica sand (including high grade silica sands), coal derived fly ash in single use deposits, 

cement raw materials, gypsum, salt, fluorspar, shallow and deep-mined coal, oil and gas 

(including conventional and unconventional hydrocarbons), tungsten, kaolin, ball clay, 

potash, polyhalite and local minerals of importance to heritage assets and local 

distinctiveness.

National position:

A Moratorium was put in place on the 2^nd of November 2019. This was following seismicity detected on the Preston New Road site: Government ends support for fracking - GOV.UK (www.gov.uk). The Moratorium was briefly lifted on the 20^th of September 2022, and reinstated on the 26^th of October 2022. A timeline on the moratorium can be found below

The Labour Party won the July 2024 General Election on a manifesto that included a fracking ban. Later in December 2024, a new version of the NPPF consultation was published which does not change the wording relating to unconventional hydrocarbons set out above. In March 2025, a consultation opened on proposals for no new oil or gas licences (offshore or onshore): Building the North Sea’s Energy Future: consultation document . It should be noted that this does not affect existing licences. The consultation includes the following wording:

…Second, our approach to oil and gas production in the North Sea needs to support our climate obligations, including the UK’s carbon budgets set under the Climate Change Act 2008. We must speed up the transition away from fossil fuels and towards clean energy. The science is clear that the world needs to take urgent action and that current plans for global production of oil and gas are not compatible with limiting global warming to 1.5°C. That’s why the government has committed to issuing no new licences to explore new oil and gas fields…Ending new onshore licences will progress the government’s commitment to ban hydraulic fracturing for shale gas extraction (‘fracking’). Fracking is a specific type of onshore oil and gas extraction by unconventional means, involving pumping large volumes of fluid into shale rock at high pressures. Onshore licences, along with other consents and permissions, are a prerequisite for fracking to take place, and therefore the government’s proposal to end new onshore licencing would also encompass new licences for the purpose of fracking.

Moratorium:

• The current moratorium on fracking was introduced on 02/11/2019, following seismicity on Preston New Road site: Government ends support for fracking - GOV.UK (www.gov.uk)
• This was then briefly lifted on 20/09/2022 and reinstated on 26/10/2022
• Government decided not to make proposed changes to the planning system to reflect the moratorium
• Timeline on the moratorium, and attempted local fracking bans in London and Manchester, below:

Timeline of fracking bans/restrictions nationally, in Manchester and in London

Climate Change Act and Local targets

The Tyndall Centre for Climate Change states in May 2025 that, for Leeds to meet it’s local climate change targets, which contribute to National targets under the Paris Climate Change agreement, it should reach zero or near zero carbon by 2041, and:

Stay within a maximum cumulative carbon dioxide emissions budget of 24.7 million tonnes (MtCO2) for the period of 2020 to 2100. At 2017 CO2 emission levels, Leeds would use this entire budget within 7 years from 2020.

Although the Climate Budget would measure carbon emissions from the point of use, not supporting fossil fuel development would encourage renewable energy development which could contribute to Leeds’ work to meet its carbon targets.

How will it be implemented?

Options:

1. No Policy

Having no specific local policy would not guarantee fracking would take place, or encourage it, but would also not protect from fracking. NRWLP general policy MINERALS 9: APPLICATIONS FOR MINERAL DEVELOPMENT would be used to determine planning applications: 

MINERALS 9: APPLICATIONS FOR MINERAL DEVELOPMENT   

Applicants will need to demonstrate that adequate consideration has been given to the following matters:  

1. Evidence of a proven deposit of mineral. 

2. Avoidance of or the reinstatement of the best and most versatile agricultural land. 

3. Duration of the development. 

4. The layout of operational areas e.g. plant yards and processing facilities. 

5. Effect on visual amenity. 

6. Effect on the natural and historic environment. 

7. Retention, treatment and maintenance of boundary features as appropriate. 

8. Environmental and amenity aspects such as noise, dust, litter, odour, vermin and 

gas emissions. 

9. Protection of controlled waters. 

10. Drainage and use of sustainable drainage. 

11. Stripping and conservation of soils. 

12. The adequacy of the highway network and the safety of access and egress to the 

site and to other users of the highway including pedestrians. 

13. Routing and frequency of vehicle movements, together with hours of operation and timescales for delivery. 

14. Measures to prevent dirt being carried onto the public highway and private 

highways in public use beyond the site boundary. 

15. The use of alternatives to road transport where feasible. 

16. Hours of operation. 

17. Protection of public rights of way. 

18. Temporary and permanent landscape works including screening. 

19. Restoration and aftercare. 

20. Fairly and reasonably related community benefits where appropriate (to be delivered through s106 Planning Obligations). 

2. Mapping of resource and safeguarding for future exploration

Any mapping would be based on the Bowland Shale Study which is from 2013 and may not be an accurate estimation of accessible shale gas. Safeguarding would ensure compliance with the National Planning Policy Framework (see above), without necessarily supporting fracking. 

3. Ban on Fracking see Manchester and London above

As shown in the timeline of national developments, the feasibility of this option will depend on how government policy and priorities treat fracking.. This option is currently consistent with the national policy direction, given that Government is working towards a national ban on fracking. 

As Leeds is a large urban area surrounded by Green Belt, there is a similar set of issues to that stated by the Major of London in his letter to the Secretary of State. Following from this, the London Plan was adopted with the fracking ban intact. 

4. Support for fracking with policy to protect designations and amenity

This approach would not guarantee fracking would take place, but would nevertheless provide an opportunity should an operator want to explore/extract shale gas in Leeds. 

It would be more protective than no policy, and provide more detailed guidance for determining planning applications than currently exists in the Local Plan. It could be more tailor-made to provide more guidance for the determination of planning applications. 

Given that applications are unlikely to come forward in Leeds a bespoke policy may not be necessary. A supportive policy would also be out of step with the direction of travel in central government 

Equality, diversity, cohesion and integration

• Energy bills – It is thought that Fracking may have a positive impact on energy bills, which have affected everyone during the cost of living crisis and the impact of the Russia-Ukraine war on gas supply. There has been a greater impact on those with low incomes, particularly older and disabled people. However, as the energy market is global, it is not guaranteed that energy from fracking would be used in the UK, therefore it is not guaranteed that fracking would reduce energy bills 
• Jobs – There could be a possible negative impact on gender equality of opportunity for jobs in the fracking industry. There are potential health risks to workers at fracking sites set out above
• Potential for contamination of water and air that would have a greater impact on children, particularly their respiratory health