Aggregate minerals are defined primarily as those used in the building and construction industries, and in the JMLP area these comprise sand and gravel, crushed chalk, and limestone.  These materials are often referred to as Primary Aggregates, drawing a distinction from by-product wastes and synthetic materials which can be used as aggregates, which are referred to as Secondary Aggregates.

In addition to crushed rock for aggregate use, a significant proportion of chalk extracted in the JMLP area is used for industrial filler and whiting purposes. Crushed rock worked for these purposes are considered in Chapter 5, Other Non-Aggregate Minerals.

This chapter explains how the forecast demand for aggregates production and landbanks has been calculated, and presents the policies which will secure production for the JMLP period to 2006.  It also makes reference to the need to review the Plan so that changes in circumstances which may occur during the lifetime of the JMLP can be considered and, if necessary, policies adjusted accordingly.  This is termed the First Review, and it has the potential to influence policies for the working of aggregate minerals since the level of permitted reserves required at any one time during the Plan's lifetime will depend on factors such as the rate of working which in turn will be related to the level of demand.

Sand and gravel deposits for aggregate use, mainly of glacial or fluvoglacial origin, are distributed sporadically across most of the JMLP area, although there are only a few areas where their exploitation is economically viable.  The Holderness plain in the east of the area formerly held the most valuable deposits, though much of these reserves have now been worked out.  Working continues near Gransmoor, and in the Brandesburton area, and deposits have been worked on a smaller scale at Keyingham.  These operations are set to continue for the foreseeable future.  Sand and gravel is also worked on the flanks of the Wolds at North Cave, and on a smaller scale in the Vale of York.  Marine aggregates are considered separately later in this chapter.

The majority of the traditional sources of sand and gravel are becoming exhausted and few significant replacement deposits are known.  These factors, together with the shortage of detailed geological knowledge mean that precise definition of future workings is difficult, and it is anticipated that the JMLP area will remain a net importer of aggregate sand and gravel.

Information on sand and gravel supply and demand for the region is collected and assessed by the Yorkshire and Humber Region Aggregates Working Party (YHRAWP), a technical working group made up of officers of the mineral planning authorities in the region, the ODPM, and trade associations.  Other representatives include the British Geological Survey. The information is presented as an annual Aggregates Monitoring Survey.  The most recent annual report was published in December 2002 and presents information for 2001.  It is referred to as the AM01 Survey.  In 2001 sales of land-won sand and gravel in the former Humberside area were 0.9 million tonnes, having averaged 0.9 million tonnes per annum (mtpa) over the previous 5 years.  The trend within the former Humberside County area has been one of moderate variation from year to year, with a low of 0.5 mt in 1994 and a high of 1.0 mt in 1997.

The great majority of the JMLP area's production of sand and gravel is consumed locally, with some exports to North Yorkshire.  The YHRAWP Regional Commentary shows that the JMLP area is a net importer of sand and gravel aggregates, with minerals being imported from North Yorkshire, South and West Yorkshire, and from Nottinghamshire and the Trent Valley in the East Midlands Region.  These include riverine sands and gravels from the Trent Valley imported to Hull by barge.  These imports equate to about 18% of the total sold in the former Humberside County area.  Figures are not currently available for the percentage which imported materials make up of sales in the ERYC and HCC areas.

Government advice for securing supply to meet forecast demand for aggregates on a national and regional basis is presented in MPG6: Guidelines for Aggregates Provision in England.  This advice is based upon past consumption and forecast demand over the 15 year period 1992 to 2006.  It also recommends that a landbank of permitted reserves for land won sand and gravel, sufficient for at least 7 years' supplies, should be maintained at all times.  MPG6 advises that local authorities should provide for a consistent level of production for sand and gravel over the Plan period.

MPG6 identifies the regional apportionment to Yorkshire and Humberside of demand for aggregates.  The sub-regional apportionment of aggregate production is calculated by the YHRAWP with the figures agreed by the member authorities for use in their appropriate plans.

The YHRAWP has assessed the requirements set out in MPG6, and has advised the Yorkshire and Humber Regional Planning Conference of its recommendations.  The Regional Planning Conference, on the basis of this advice, has commended a figure of 9 mt of sand and gravel for the whole of the former Humberside County area, for the 15 year period 1992-2006.  This equates to average production of 0.6 mtpa.   This is somewhat lower than actual figures for recent years, and reflects the predicted trend for using higher proportions of crushed rock for aggregates purposes. 

The county apportionment presented by the YHRAWP is not broken down to show a split between the authorities East Riding of Yorkshire/Hull City and North Lincolnshire/North East Lincolnshire which have replaced Humberside County.  Therefore a sub-county area apportionment has been calculated for the JMLP which is based on available historic production data, the MPAs' knowledge of sand and gravel working in the JMLP, and an assessment of future available reserves.

On this basis an apportionment of 70% from the East Riding and 30% from North Lincolnshire has been derived, and agreed between these authorities.  Therefore the total required figure for the JMLP area for the period 1992-2006 is 70% of 9 mt which is 6.3 mt, a requirement of 0.42 mt per annum over that period.  In order to reach the figure for provision required over the JMLP period - 1996-2006,  it is necessary to consider what permitted reserves exist.  The calculation of sand and gravel provision requirement for the JMLP area is given below in Table 4.1.

It may be seen from these figures that additional permissions for sand and gravel extraction will need to be granted during the JMLP period, to meet the shortfall of 1.36 mt.

The MPAs will seek to maintain their contribution to Yorkshire and Humberside's production of aggregate sand and gravel throughout the Plan period, having regard to other Plan policies for the protection of the environment.

For the period 1996-2006, provision will be made for the supply of 3.78 mt of sand and gravel, unless exceptional circumstances prevail, this figure being 70% of the YHRAWP requirement for that period.  A landbank of permitted reserves will be maintained throughout and at the end of that period, providing for at least 7 years' production.

The existing landbank is made up of sites spread across the JMLP area, with different levels of reserves.  Based on the calculation set out in Table 4.1 it is recognised therefore that, even though there is at the moment a 7 year supply in the landbank, in order to ensure continuity of supply with geographical spread, to maintain a healthy market, and to provide a landbank of at least 7 years at 2006 planning consents for additional sand and gravel extraction of 1.36 mt will need to be granted before the end of the JMLP period.  It is proposed that these consents will be within the Preferred Areas defined in Inset Maps 1-2, (PDF files) and these are:

• Catwick and Brandesburton (Inset Map 1)
• North Cave (Inset Map 2)

In addition to the Preferred Areas it is considered that some flexibility is required in the event of unforeseen demand, particularly toward the end of the Plan period, and to assist in maintaining a geographic spread of supply within the JMLP area.  Policy AGG3 below provides this flexibility to permit extensions to existing operations within the Areas of Search to meet unforeseen demand, and to ensure a continuity of supply with geographic spread. 

The Sand and Gravel Areas of Search identified on the Proposals Map Insets are

• Brandesburton and Leven (Inset map 3)
• Gransmoor and Lissett (Inset map 4)
• North Cave (Inset map 5)

The background to the selection of sand and gravel Preferred Areas and Areas of Search are given in Appendix 1.

Chalk of the Upper Cretaceous is quarried at a number of locations in the JMLP area in the Yorkshire Wolds.  The use of chalk as an aggregate material is limited due to its softness and susceptibility to frost.  It is most extensively used for bulk fill in construction projects such as new roads. 

As stated earlier, planning for production of aggregate crushed rock in the JMLP area is complicated by the fact that the majority of crushed rock quarried is used for industrial purposes, and is not therefore subject to the forecast and landbank requirements set out in MPG6.  Policies for non-aggregate chalk production are contained in Chapter 5.

In the same way as for sand and gravel, data on the production and consumption of crushed rock for aggregate (and industrial) use is collected and analysed by the YHRAWP, and the sub-regional apportionment is commended in the same way by the Regional Planning Conference.

Sales of crushed rock for aggregate and non-aggregate sales climbed throughout the region in the period 1991 to 1994, a year when the former Humberside produced 1.55 mt for aggregate use and 1.64 mt for non-aggregate use.  Total sales have fallen since then, although this has largely been accounted for by a significant fall in sales for aggregate use, and figures for the former Humberside area in 2001 were 0.5 mt for aggregate use and 2.4 mt for non-aggregate use. 

The JMLP area, as for the former Humberside County area, is a net importer of crushed rock for aggregate use by a considerable margin, and does not export a significant proportion of its own production.  Sales within the former Humberside County area accounted for less than 4% of the Region's overall 12.7 million tonnes sales in 2001 (Source: AM01).

MPG6 provides guidance on the supply and demand of aggregate crushed rock, and although not recommending a minimum figure for a landbank, it does suggest that resources to meet demand for longer than the 7 year sand and gravel landbank may be appropriate.  It is reasonable therefore to take 10 years as a landbank figure.  The sub-regional apportionment for aggregate crushed rock for the former Humberside County area is 11 mt for the period 1992-2006, which equates to an annual production figure of 0.73 mt.  This is based on the average individual County share of the regional total for the period 1989-1992.

In the same way as for sand and gravel minerals, the YHRAWP county apportionment for crushed rock is not broken down to show a split between the authorities which have replaced Humberside County.  Therefore a sub-county area apportionment of crushed rock for aggregate use has been calculated for the JMLP.  This is based on available historic production data, the MPAs' knowledge of crushed rock production for aggregate use in the JMLP, and an assessment of future available reserves.  On this basis a 50/50 split between East Riding and North Lincolnshire has been derived, and agreed between these authorities.  This split applies to both production and landbanks within the two authorities.

Taking the 50% share of the sub-regional apportionment figure, the requirements for the JMLP area are 5.5 mt for the period 1992-2006, an average annual production figure of 0.366 mt.

The figure is higher than production of aggregate crushed rock (i.e. not including non-aggregate use) in 1995 and 1996, (0.27 mt and 0.3 mt respectively) which may reflect the predicted increased use of crushed rock use for aggregates rather than sand and gravel, which is set out in MPG6.

Notwithstanding this, the MPAs are committed to maintaining their role in the apportionment of aggregate crushed rock in the region, and to maintaining a 10 year landbank of permitted reserves of this material.

The required landbank for the JMLP area for aggregate crushed rock is calculated by dividing the existing permitted reserves within the JMLP area by the JMLP area apportionment for the period 1992-2006, and then including a 10 year landbank at the end of the Plan period.  At 31.12.97 there were permitted reserves of all chalk/limestone within the JMLP area estimated at 21.5 mt.  Although this is a conservative figure, which excludes one operator's figures (where information is not available) and dormant sites, importantly it includes crushed rock which will be used for non-aggregate use.

As noted, the position in the JMLP area is complicated by the fact that crushed rock produced in the area is sold for both aggregate and non-aggregate use.  The proportional split for these uses depends on the quality of the mineral extracted, which is not always known beforehand, together with the strength of the market for each use.  Based on sales of crushed rock for aggregate and non-aggregate use for the years 1994, 1995 and 1996, the proportion of crushed rock sold for aggregate use was on average 30%, ranging from a high of 49% in 1994 to a low of 18% in 1995.  The 1994 figure was exceptionally high due to key construction contracts, and as a result a figure of around 25% for aggregate could be considered realistic if this proportional breakdown in end uses could be projected into the future.

It is not possible, however, to take this approach due to the influence of existing consented reserves on the likely future pattern of breakdown between crushed rock for aggregate and non-aggregate uses.  The two largest areas of consented reserves are at Queensgate, Beverley (operated by Imerys), and Melton (Omya UK Ltd).  These sites account for over 17 mt of consented reserves, approximately 80% of the overall consented crushed rock reserves within the JMLP area.  Historically, almost all of the production from these quarries has been used for non-aggregate use.  In addition, since the companies owning them have their own whiting works, and the material itself is of a generally high quality, it is unrealistic to assume that a significant proportion of these reserves will be available for aggregate purposes.

The more realistic approach, therefore, and the one which this Plan has adopted, is to identify a landbank figure for aggregate crushed rock which excludes those sources of crushed rock which are unlikely to contribute significant quantities for aggregate use within the Plan period.  Thus, those consented reserves at quarries which have not in the past provided significant quantities of aggregate materials and/or are owned by whiting works operators; together with dormant sites, have been excluded from calculations.  The JMLP has assumed a 50/50 split in production at Bracken Quarry, Lund and at Burnby Quarry, based on historic production figures for crushed rock for aggregate and non-aggregate uses. 

Using this approach, the figure for consented reserves at 31.12.97 is approximately 3.0 mt.  Applying this to the JMLP area requirement of 0.366 mtpa derived from MPG6 indicates a landbank as at  February 1997 of about 8 years, and if based on current output, a landbank of about 12 years.  This calculation may be summarised as shown below in Table 4.2.

It may be seen from these figures that additional permissions for aggregate crushed rock will need to be granted during the JMLP period, to meet the shortfall of 3.7 mt.  The MPAs will seek to maintain their contribution to Yorkshire and Humberside's production of aggregate crushed rock throughout the Plan period, having regard to other Plan policies for the protection of the environment.  The position regarding permitted reserves, and the need, if any, to grant additional consents to maintain the landbank will be considered again at the First Review.

For the period 1996-2006, provision will be made for the supply of 3.3 million tonnes of crushed rock, unless exceptional circumstances prevail, this figure being 50% of the YHRAWP requirement for the former Humberside County area for that period.

The JMLP recognises that as with sand and gravel, the aggregate crushed rock landbank is made up of a number of sites spread across the JMLP area, in this case north/south within the Yorkshire Wolds.  Based on the calculations set out in Table 4.2 it is recognised that, even though there is at the moment in excess of a 10 year supply in the landbank, in order to ensure continuity of supply with geographical spread, to maintain a healthy market and to provide a landbank of at least 10 years at 2006, planning consents for additional production of 3.7 mt will need to be granted before the end of the JMLP period.

The JMLP also recognises that existing sites have different levels of reserves which may vary in the type and quality of the mineralinvolved.  It further recognises that in order to ensure continuity of supply and to maintain a healthy market, particularly in terms of the geographical distribution of supply, some sites may need to extend their working to an extent which leads to a landbank larger than is strictly required within the JMLP area when considered as a whole. 

Unlike the position for sand and gravel within the JMLP area, there is insufficient robust information on the occurrence of viable reserves of crushed rock for aggregate, and for this reason there are no Preferred Areas identified for this material.  Instead the JMLP identifies a number of Areas of Search.  These are related to existing quarries and have been identified on the basis that sensitive extensions to these quarries would have fewer significant environmental impacts than the opening of a new quarry.  The Areas of Search are as follows:

• Greenwick Quarry, Huggate (Inset Map 6)
• Swinescaif, South Cave (Inset Map 7)

For these Areas of Search, notes accompany the Inset Maps which explain the principal environmental constraints present at each site, to which any successful planning proposals would need to respond.  The criteria used to identify Areas of Search are explained in Appendix 1.  Policy AGG5 below provides the necessary flexibility to permit extensions to existing operations during the JMLP period, to meet need, and to ensure a continuity of supply with geographic spread.

Borrow Pits are short-term mineral workings which may yield sand and gravel or crushed rock for aggregate use in a specific engineering or construction project, and only in that project.  They are normally located near or adjacent to the project in question, and are used to provide a project-specific supply of mineral, often producing large volumes in a short period of time, and with the objective of reducing environmental impact from transport to and from the development site.  Other environmental benefits can be utilisation of a resource which might otherwise be sterilised, discouraging the use of better grade materials from other sites, and protecting the environment from possible increased environmental impacts at existing sites.  Within the JMLP area, some of these benefits may be less significant as there is a large quantity of low grade crushed rock aggregate produced locally.

The operational life of borrow pits is much shorter than for conventional mineral working, and will normally be governed by the construction period for the engineering project.  Borrow pits are also usually much smaller than other mineral workings.  Restoration normally involves backfilling with unusable material or surplus materials from the construction site.  However, borrow pits can also provide potential for creating new nature conservation afteruses.  The contribution which borrow pits may make to the overall supply of mineral resources over the Plan period is not taken into account when calculating landbank requirements.

Planning permission is required for borrow pits except where they may be very small and located entirely within the boundary of highway construction sites.  In considering proposals for borrow pits the MPAs will need to be satisfied that the borrow pit represents the most suitable source of material to satisfy the specific demand involved, and that both working and restoration can be achieved without unacceptable environmental impacts.  The Authorities will consult with DEFRA on proposals which affect agricultural land, and restoration/aftercare proposals will be expected to be as high a standard as for normal mineral workings.

It is Government policy to encourage the use of secondary aggregates and recycled materials in order to reduce the need for primary mineral extraction, and to reduce the need for landfill.  MPG6 has set the following targets for the use of recycled and secondary aggregate materials in England:

• 40 million tonnes per annum by 2001
• 55 million tonnes per annum by 2006

MPG6 suggests that up to 65 million tonnes of aggregates may be provided from secondary and recycled sources in the Yorkshire and Humberside Region for the 15 year period to 2006.

Secondary aggregates are those materials suitable for aggregates use which are a by product of another mineral extraction process, or processes such as power generation, steel making etc.  They include materials such as colliery shale, pulverised fuel ash (PFA), Furnace Bottom Ash (FBA) and blast furnace slag.  Recycled materials are, as the name suggests, waste materials which can be reused as aggregate, and these come from two main sources: construction and demolition wastes, and road planings.

There are a number of problems with the viability of secondary and recycled materials and their ability to make a significant contribution towards aggregates sales and use.  The cost of transporting the material from the point of arising to the point of use is a key concern, which is more significant than for ordinary aggregates due to the low cost and low quality of the material creating little price elasticity.  In the JMLP area the situation is better than in some parts of the UK, due to the availability of arisings from the coal and power generation industries such as PFA from Drax power station which is near to the JMLP area, and where significant investment has been made in plant to provide ash of a quality which complies with British and European standards for use as a partial cement replacement in concrete.  To a lesser extent blast furnace slag from British Steel at Scunthorpe also has the potential to contribute to demand in the JMLP area, although its viability is somewhat reduced as a result of the need to import it across the Humber Bridge, with consequent toll costs.. 

The ability of these materials to meet high specification end-uses, such as in road construction, is a frequent concern, since technical Department of Transport specifications often preclude their use.  This issue is in the process of being tackled at a national level, and therefore their usage may become more common in the future.

It is often the case that secondary and recycled aggregates have difficulty in competing with cheap primary aggregates, and this is a particular concern in the JMLP area where most of the primary aggregate crushed rock supplies are low quality, and hence comparatively cheap.

Notwithstanding the above comments, the MPAs support the move to use a higher proportion of secondary and recycled aggregates, and support the targets set out in MPG6.

One problem which has restricted the use of these materials in some parts of the UK is opportunities for processing and sorting the materials involved.  Processing and sorting requires a site with good transport links, which can accommodate stock piles, sorting and despatch areas, and the plant which may be required such as crushers and screens.  Such sites should be located away from residential areas and other sensitive environments, and should be visually well screened.

Aggregate recycling facilities may often be well suited to existing mineral working sites, provided that those sites are well related to the markets which they serve.  In considering such proposals, however, it is important to consider the issue of the prolonging of activities at a site when mineral working may be complete, and the relationship of the proposal to the restoration plans for the site.  It is also of great importance that any such uses are confined to genuine aggregates recycling activities, and that no other materials reclamation or waste storage takes place.  In this respect the site licensing process will be used to reinforce planning conditions imposed.

Sand and gravel aggregates are dredged in a number of places off the East Yorkshire coast, and elsewhere off the north east coast of England.  In the 3 years to 1994 0.3 million tonnes per annum were sold from this source within the JMLP area, while for 1994, 1995 and 1996 the figures were 0.2, 0.1 and 0.3 respectively (Source: AM96).  In 2001 the figure was again 0.3 million tonnes (Source: AM01).

Part 3 of the Marine Aggregates Survey (East Coast), carried out for the Crown Commissioners by the British Geological Survey, has identified broad zones of gravel bearing sediments 80km east of the Humber and 30 km off Flamborough Head.  Although the surface distribution of sea bed sediments is well known at the reconnaissance stage, little is known about the thickness of the gravel bearing deposits and there is a lack of the geological information required for satisfactory resource appraisal.  Nevertheless, there is good reason to believe that the east coast deposit will prove commercially attractive, and will continue to play a part in the overall aggregates market in the JMLP area.

MPG6 envisages that landings of marine dredged aggregates for Yorkshire and Humberside will increase over the period 1992-2006 from the existing level to 0.5 million tonnes per annum.  The regional apportionment does not provide a figure for predicted landings on a county specific basis, but the great majority of landings will be in the JMLP area.

This predicted increase is independent of any direct influence by the MPAs, since conventional planning control does not extend beyond the low water mark.  Licences for the working of marine aggregates are considered by the Office of the Deputy Prime Minister (ODPM), under a new non statutory interim Government View procedure which was introduced in 1998.

An application for a Government View must be made to the Office of the Deputy Prime Minister.  In reaching its decision the ODPM will consider all the information submitted with the application, including reports on the environmental effects of the proposed dredging, all comments received in response to consultation with interested parties and comments received following advertisement of the application.  Where an inquiry or hearing is held into an application, the recommendation of the Planning Inspector will also be taken into account.  A favourable Government view must be obtained before a production licence will be issued by the Crown Estate.

Whilst the procedures relate primarily to the roles of the applicant and Government Departments in determining a Government View, they are also intended to inform other parties, who may have an interest in expressing their own opinion on a particular application, of the stages at which they will be able to make their view known. 

The new Government View procedure has introduced a more formal process of assessment and consultation and now requires the applicant to submit a formal Environmental Impact Assessment and Coastal Impact Study to fully evaluate any proposed dredging operation.  A more systematic approach to project evaluation, consultation and implementation should reduce the impact of dredging on the East Yorkshire Coast.  The special characteristics of the coastline including FlamboroughHead and Bempton Cliffs, the off-shore archaeology and the fishing grounds will all be given increased importance in dredging project evaluation and implementation.

Marine aggregates are currently landed at purpose-built wharves at Hull.  Other Wharves which currently handle land won aggregates which are transported by water potentially could land marine aggregates.  The MPAs broadly support the increase in marine won aggregates envisaged in MPG6, as making a contribution to sand and gravel sales within the JMLP area and region, and therefore moderating the potential for environmental impacts arising from land won aggregates.

There are, however, a range of serious concerns about the environmental impacts which may arise from marine dredging.  There are two main impacts to be considered.  The first is the physical damage to marine life and habitats through disturbance of the sea bed and deposition of silt, and the second is the potential effect on coastal physical processes especially erosion, and the interruption of sediment flows. Both these factors are of concern to the MPA’s, and it is prudent when considering the potential contribution which marine won aggregates can make, to consider possible impacts on the Heritage Coast, the Flamborough Head and Bempton Cliffs Special Protection Area and the Humber, Flats, Marshes and Coast SPA and proposed Special Area of Conservation, fisheries, off-shore archaeology, and the significance of the coast as a tourist attraction.  The procedures involved in licensing marine aggregates dredging have recently been modified to give greater attention to the potential environmental effects of such activity, and the MPAs welcome this move.

An increased role for marine won aggregates could lead to a demand for new facilities, or the intensification or expansion of existing sites.  Existing facilities are located in Hull's eastern docks and in the lower river Hull corridor.  The latter area is a Geographical Priority Area in the City Regeneration Strategy, and as such it is important that any new development associated with minerals handling does not prejudice the broader objectives of HCC for regeneration of this area.  It is likely that Hull will remain the focus for new marine aggregate development.

The MPAs are members of the East Coast Offshore Minerals Forum, a body of elected representatives from coastal local authorities in the region, a principal role of which is to act as a focus for consideration of marine won aggregates in this area.  The Authorities will maintain their role in this respect, and where possible will seek to be involved in the marine aggregates licensing process.  They will continue to seek the highest standards of environmental safeguarding and operational good practice with a view to monitoring the role which marine aggregates can play, within a sustainable environmental context.

The JMLP area is a net importer of aggregates and will continue to be, primarily as a result of the limited reserves present within the area, and environmental constraints.

The implications of aggregates imports have been considered in relation to predictions of demand and supply for aggregates within the former Humberside County.  A further planning consideration, however, is the appropriate infrastructure needed to accommodate and distribute aggregates imported to the JMLP area, and the implications of future trends such as the introduction of coastal "super quarries" in Scotland and Scandinavia.

At present, some aggregates are landed at Hull, and there are wharves designed specifically to handle minerals.  These facilities are adequate to accommodate current levels of imported materials, and are anticipated to remain so.  The majority of imports to the JMLP area are by road, and by rail via the Tilcon Aggregates rail depot in Hull.

The MPAs will continue to monitor the adequacy of infrastructure within the JMLP area to receive and distribute imported aggregates.  Although not anticipated at present, there may be an increase in the future in the proportion of aggregates landed at ports, and the MPAs will give favourable consideration to the expansion of facilities, or the construction of new facilities where needed.  Where possible, the Authorities will expect to see such facilities linked to the rail or waterways networks serving the JMLP area, and will not encourage the use of road transport.