Posted on October 28, 2026
By Jon Moran
It is not every day that a planning application for a new housing estate reveals enough sand and gravel beneath the proposed development to keep a substantial quarry busy for years.
Yet that is precisely what has emerged from Bloor Homes’ application to build up to 1,200 homes on land at Foxhall Road, between Kesgrave and Martlesham Heath.
Buried among the extensive supporting documents submitted to East Suffolk Council is a Mineral Resource Assessment which estimates that approximately 1.4 million tonnes of potentially saleable sand and gravel lie beneath the land.
That is an enormous quantity of material. And once roads, foundations, drainage systems and houses have been constructed above it, much of that resource could effectively be lost to future generations.
The assessment, prepared by specialist environmental consultants RSK Geosciences on behalf of Bloor Homes Eastern Limited, concludes that extracting the minerals before construction would not be commercially viable.
But the reasons for that conclusion tell an interesting story about the land itself, its history and the consequences of building an entirely new neighbourhood upon it.
What exactly is beneath Foxhall Road?
The deposits are principally sand and gravel associated with the Kesgrave Catchment Subgroup, together with other geological formations characteristic of this part of Suffolk.
The Kesgrave deposits are ancient river sediments, containing gravel characterised by quartz and volcanic rock fragments, alongside sand and other materials. They are part of a geological history stretching back hundreds of thousands of years, when the river systems of eastern England looked very different from those we know today.
The wider geological sequence also includes deposits associated with the Lowestoft Formation and the underlying Red Crag, the latter containing shelly sands and rounded flint pebbles.
These are not precious metals or rare minerals. They are something arguably more useful to the construction industry: aggregates.
Sand and gravel are essential ingredients in concrete, building materials, roads and infrastructure. They are also finite resources. Once a deposit has been built over, extracting it later may become effectively impossible.
RSK’s investigation involved boreholes drilled through the mineral-bearing ground, allowing its consultants to establish the depth, composition and extent of the deposits.
Their calculations initially identified approximately 1.65 million tonnes of potentially extractable sand and gravel. After accounting for fine material and ground that could not realistically be worked, the estimated saleable resource was reduced to around 1.4 million tonnes.
The report acknowledges that further losses would arise from the space needed for quarry roads, equipment and other infrastructure.
There have already been gravel pits here
Perhaps less surprisingly, this is not the first time the mineral deposits around Foxhall Road have attracted attention.
Historic maps examined by RSK show gravel workings in the surrounding area dating back more than a century.
The assessment records previous gravel extraction within the southern part of the site, with workings extending eastwards towards land subsequently used for landfill.
It also identifies 24 recorded surface workings in close proximity to the development.
Some older gravel pits were subsequently filled, including one which the assessment records as having received refuse during the 1980s.
In other words, the mineral deposits are not merely theoretical. This landscape has a long association with quarrying, extraction and the subsequent restoration or reuse of worked land.
Why doesn’t Bloor Homes simply extract the minerals first?
The central argument in RSK’s report is that the potential financial return from extracting the sand and gravel would be outweighed by the costs and practical difficulties of doing so.
The consultants identify several obstacles.
First, the proposed development is close to existing residential properties. RSK has therefore applied an assumed 100-metre separation distance between quarry excavations and neighbouring homes, reducing the area available for extraction.
Second, a working quarry would require substantial infrastructure, including processing machinery, stockpiles, access roads, washing equipment and potentially settlement lagoons.
These operations would generate noise, dust and vehicle movements, with consequences for surrounding communities.
Third, extracting such a quantity of material would leave a substantial excavation which would then need to be restored to an appropriate level and engineered to carry a new housing development.
That process would be expensive.
RSK estimates that setting up a relatively small sand and gravel quarry could cost between £250,000 and £4 million in plant and equipment.
Its assessment argues that the investment needed to extract the deposit, followed by reinstatement to a standard suitable for construction, would outweigh the potential returns.
The report also refers to an existing supply of sand and gravel from established and planned mineral sites in Suffolk, arguing that there is no overriding supply requirement to work this particular deposit.
These are the conclusions of the developer’s appointed consultants, rather than an independent determination by the county council.
The extraordinary problem of moving it all
Perhaps the most striking figures appear in the section examining the transport implications of quarrying the site.
RSK calculates that exporting approximately one million tonnes of processed minerals could generate around 50,000 heavy goods vehicle loads, assuming an average lorry load of 20 tonnes.
Those figures illustrate the enormous logistical challenge of operating a quarry alongside established residential communities.
Restoring the land afterwards could require similarly substantial quantities of imported material.
The consultants suggest that the combined extraction and restoration operation could potentially generate more than a million HGV movements, although that is a broad hypothetical estimate rather than a forecast of construction traffic for the proposed housing development.
It is nevertheless a revealing indication of the scale of the engineering work that full-scale quarrying might involve.
There is another complication. The geological formations beneath Foxhall Road include important groundwater-bearing layers, including the Red Crag, classified as a Principal Aquifer.
RSK considers that large-scale quarrying, washing operations and associated water management could pose unacceptable risks to the local water environment.
The assessment also raises concerns that removing the natural sand and gravel, then replacing it with imported material, could interfere with the infiltration drainage strategy envisaged for the new development.
In simple terms, the ground’s ability to absorb rainwater is one of the characteristics upon which the drainage proposals may depend.
But thousands of tonnes will still be excavated
The developer’s own calculations introduce a further interesting dimension.
Although RSK recommends against commercial quarrying before development, it anticipates that approximately 270,000 tonnes of material could be excavated incidentally during construction.
That might include material removed for roads, drainage infrastructure, foundations and landscaping.
The report recommends maximising the reuse of excavated minerals within the development itself, with surplus material potentially used elsewhere for sustainable soil management.
This is a rather different proposition from operating a commercial quarry, and the distinction matters.
Nevertheless, 270,000 tonnes is a substantial quantity of excavated material, equivalent in weight to approximately 13,500 fully loaded 20-tonne lorries.
That does not mean 13,500 lorries will leave the development site. Reusing material within the development would greatly reduce external transport requirements.
But it raises obvious questions about construction phasing, where excavated material will be stored, how much can genuinely be reused and what happens to anything left over.
It also raises questions about noise, dust and heavy construction vehicles during the early stages of development.
Precisely how these operations will be managed should be an important part of the detailed construction arrangements.
Other places have done things differently
The relationship between housing development and valuable minerals beneath the ground is not unique to Suffolk.
At Sandhills, near Leighton Buzzard in Bedfordshire, silica sand was extracted in phases before housing development. The land was subsequently shaped to accommodate the estate, demonstrating that mineral extraction and residential construction can sometimes be successfully combined.
In Essex, at Bullslodge Quarry near Chelmsford, permission was granted in 2012 for the early extraction of sand and gravel ahead of a proposed mixed-use development.
And near Exeter, the extraction of sand ahead of commercial development has provided another example of mineral resources being recovered before the ground is covered by buildings.
These examples are cited in published mineral safeguarding guidance as illustrations of how prior extraction can work where the economics, geology and surrounding circumstances permit it.
They do not establish that a similar approach would be practical at Foxhall Road.
What they demonstrate is that building over mineral deposits is not always the only option.
What does Suffolk’s planning policy say?
Suffolk County Council has a responsibility to safeguard important mineral resources, even where the land in question is being promoted for another form of development.
Policy MP10 of the Suffolk Minerals and Waste Local Plan, adopted in 2020, provides a framework for protecting mineral resources from development which could prevent their future extraction.
Where qualifying development falls within a Minerals Consultation Area, the county council must be consulted and the practicalities of extracting minerals beforehand considered.
National planning policy similarly recognises that minerals are finite and can only be extracted where nature deposited them.
That principle is particularly relevant at Foxhall Road.
The site lies within a Minerals Consultation Area and the developer has therefore commissioned the detailed assessment now accompanying its planning application.
But establishing that extraction would be commercially unattractive is not necessarily the end of the planning discussion.
The county council will need to consider the evidence, the potential loss of the minerals and whether the proposed arrangements for reusing excavated material are satisfactory.
There is a distinction between demonstrating that mineral extraction would be difficult and demonstrating that permanently building over the resource is justified.
And where is the local councillor?
All of this makes the apparent absence of any detailed public explanation from the area’s district councillor, Mark Packard, all the more surprising. Councillor Packard is not simply a ward councillor – he is also East Suffolk Council’s Cabinet Member for Planning, at the very authority responsible for determining the application.
His public comments, so far as we have been able to establish, have concentrated on informing residents that the application is now open for consultation, rather than explaining the considerable complexities buried within its supporting documents.
Yet what does meaningful public consultation amount to when residents must navigate hundreds of pages of technical evidence, specialist assessments and planning arguments simply to understand what is being proposed?
Ipswich.co.uk has asked Councillor Packard directly whether he supports or opposes the application overall. This is not an attempt to lay a political trap, nor to demand that he prejudge any formal planning decision. It is a reasonable question to put to an elected representative about a development of this magnitude.
After all, alongside the already approved 2,000-home Brightwell Lakes development at the former Adastral Park, Bloor Homes’ proposals could bring as many as 3,200 new homes to this part of Greater Ipswich. That is development on a scale which could permanently transform the area’s landscape, roads, services and communities.
There is no requirement for Councillor Packard to declare support or opposition before the evidence has been considered, and he must be mindful of the rules surrounding planning decisions. But surely residents are entitled to expect their elected representative – particularly one holding the planning portfolio – to explain the issues, identify the questions that need answering and, where appropriate, make his own position clear.
Simply announcing that the public may now comment is not quite the same thing as helping them understand what they are being asked to comment upon.
An interesting decision for the planners
Bloor Homes’ application, DC/26/2312/OUT, is currently being considered by East Suffolk Council.
The developer proposes up to 1,200 homes, a primary school and associated community facilities on land which has remained largely agricultural, notwithstanding its previous associations with the former Martlesham Heath airfield and nearby gravel workings.
The mineral assessment reveals another layer to the debate.
We now know that beneath the proposed new neighbourhood lies a substantial natural resource. We know its approximate size, its geological composition and the difficulties involved in recovering it.
We also know that construction is expected to disturb a significant proportion of the ground, whether or not commercial extraction takes place.
What remains to be established is whether the county council accepts the developer’s economic assessment, whether the proposed reuse of excavated material can be properly secured and what environmental controls will govern the substantial earthworks that construction may require.
It is one of those planning questions which rarely features in the promotional illustrations of new housing developments, but which may have consequences long after the builders have departed.
For the land at Foxhall Road, the debate is not simply about what might be built above the ground.
It is also about what Suffolk is prepared to leave, perhaps permanently, beneath it.
