Wednesday, 17 December 2014

A disappointing year

It’s been a disappointing year for those who care about the future of this area;

for those that care that Devon County Council is conspiring with a Swiss multinational cement conglomerate to seal the fate of Ottery St Mary and the surrounding area for generations to come;

for those that care that, despite a multitude of material planning constraints, the Aggregate Industries machine continues to move relentlessly towards the gates of its first target, Straitgate Farm.

Here are a few things we posted over the course of 2014:

AI is already marking out its quarry

Exeter Airport’s response on birdstrike fails to consider the complete picture
Hedgerows provide a natural flood defence
AI plans to grub up almost two miles of ancient hedgerows at Straitgate
Spot the difference - 49 acre lake vs. ephemeral pond?
Devon Minerals Plan delayed again
Devon sand and gravel production for 2013, down on 2012

AI's answer for the dormice - an 'escape route'

2015 is likely to be a year when more help will be needed; AI is likely to be submitting its planning application, and DCC is likely to be consulting on, and formally submitting, its long-delayed Minerals Plan. Please spread the word to all those who may be able to assist in any way they can.

It is at least pleasing that readership of this blog and Twitter continues to grow. To all who read this, friend or foe, we wish you a Happy Christmas and Peaceful New Year.

Monday, 8 December 2014

Latest musings from Aggregate Industries’ trade body

MPA wonders why we need Minerals Plans at all

The Mineral Products Association continues to complain of inertia in the planning system, and claims that "unless the situation changes, at some point in the near future the options for maintaining a steady and adequate supply of aggregates could become seriously limited". Mineral planning applications apparently remain low, and the MPA thinks that "the lack of completed mineral development frameworks has had a significant contributory effect". And yet, the MPA also tells us that "the greater proportion of new permissions granted since 2006 were for sites that were not allocated in mineral plans" and "around 90% of all mineral applications are successful". The MPA says:
That speaks volumes about the health of the plan-led system and is worrying as it weakens an already difficult situation, since those who engage with the plan-led system are paying twice for gathering data and putting sites into the system, only to see other sites getting permission at lower cost. Either we have a plan led system, or we don’t - some are beginning to wonder why we need plans at all.

Next time you buy a 25kg bag of cement from B&Q (currently £5.90, 5 or more for £4.15 each), spare a thought, the MPA would say, for the cost pressures the industry is under - particularly carbon-related costs. The MPA claims the UK cement industry is being unfairly treated, but this is the same industry that for every 25kg bag puts around 25kg of CO2 into the atmosphere, the same industry that is responsible for somewhere between 5-10% of all man-made CO2 emissions. The UK cement industry has pledged to reduce its CO2, yet its emissions in 2013 were up on 2012; the words climate change appeared nowhere in the MPA's press release.

The MPA has yet again called on the Government to reduce the regulatory burdens its members face. It estimates that "environmental and planning-based regulatory costs are set to increase from £324 million in 2013 to £641 million pa in 2020". Is this overly burdensome, as the MPA argues, for a sector turning over £9 billion annually, or just an indication of the scale of the industry’s environmental impact?

The MPA has called on the Government to freeze the Aggregates Levy for 2015/16 and "following the conclusion of current legal processes, that there is a review process to assess the role and appropriate level for the Levy going forward". It also calls for "the introduction of an Aggregates Levy Community Fund to be considered at a lower cost than the previous Aggregates Levy Sustainability Fund, with more of a community and biodiversity focus".

Monday, 1 December 2014

More Straitgate history comes to light

We know that Straitgate has been farmed for thousands of years - in Neolithic, Iron Age and Roman times. Now more history has come to light, in the form of a number of legal documents from the 16th and 17th century; one contains an extensive list of covenants relating to Straitgate Farm - known around the time as StreateyateStreatyeate or Streatyeat.

The documents, dating from before the English Civil War, add yet more 'historical colour' to what is at stake, and what stands to be lost. They paint a picture of a Devon farm almost 400 years ago, of the farmland that Aggregate Industries - with the help its Swiss paymasters and your county council - is now plotting to destroy for good.

We hope to post transcripts in due course.

Friday, 21 November 2014

‘Straitgate’s not enough’ - AI wants more of our local area

Minerals planning in Devon has taken a new, bizarre and disturbing twist. No decisions have yet been made, but, according to DCC, ‘Straitgate may not be enough on its own’ - other areas around Ottery St Mary, West Hill and beyond may have to be earmarked as well.

And no, the sites at Penslade near Uffculme are not being ruled out either. In actual fact, if both Straitgate and Penslade are designated as Preferred Sites, that would cover any shortfall of sand and gravel for the Minerals Plan period to 2031 many times over, even if reserves at Houndaller near Hillhead are ignored. There should be no need to identify any further sites. So what’s going on?

First of all, Aggregate Industries obviously has little interest in Penslade - unless permission is refused for Straitgate. Secondly, Straitgate has a smaller available resource of sand and gravel than either AI or DCC had hoped - arguably not enough by itself to cover the expected shortfall in the Plan. AI clearly wants to be at Straitgate, but also wants to stay in the area once the Farm is exhausted. To facilitate this, DCC is considering making further provision in the Minerals Plan for this area. What DCC is now talking about, in addition to making Straitgate a Preferred Site, is identifying a more extensive 'Area of Search', in other words identifying the next areas for AI to quarry. BGS defines an 'Area of Search' as:
...broader areas where knowledge of mineral resources may be less certain than in Preferred Areas, but within which planning permissions could be granted to meet any shortfall in supply if suitable applications are made.
What area might it cover? It’s not known yet, but the best indication is this map, where the yellow indicates the extent of the Budleigh Salterton Pebble Beds, the sand and gravel that AI wants.

So much for DCC's idea 'that supply should be maintained from the northern and southern areas’. Nevertheless, most of this is no more than we have said before, that once AI gets a foothold in Straitgate it will move on to other farmland around Ottery St Mary, West Hill and beyond - quarrying here for generations to come; it already owns the mineral rights. What has changed is it now looks like DCC is working in tandem with AI to make it happen - opening the door for this Swiss multinational to wreck large parts of the Otter Valley. Huge areas are at risk; sites S1-S10 that had previously been excluded will now be looked at again. This is no longer just about Straitgate.

Wednesday, 19 November 2014

Devon Minerals Plan further delayed

Two passages to note from the report:
Further progress on developing proposals for sand and gravel supply has been limited by the delay in receiving further information from the potential mineral operator necessary to establish whether the constraints identified through the consultation are capable of being avoided or adequately mitigated. However, the operator has now undertaken extensive investigatory work and has indicated that the outcomes will be reported to the Council shortly to inform preparation of the Minerals Plan. [2.4]
It is anticipated that the pre-submission Minerals Plan will be reported to the Committee and Cabinet in June 2015 for approval for public consultation in advance of its subsequent submission to the Secretary of State. [3.1]

Straitgate planning application "in due course", confirms Aggregate Industries

A request was made in September to Aggregate Industries for copies of the archaeology trench plans. It was indicated that such plans would be forthcoming once certain amendments had been made; copies were freely shown to us on site visits.

As the archaeological investigations draw to a close, AI is now unwilling to share such plans; plans that show the position and nature of the farm’s geophysical anomalies, and indicate the revised extent of AI's proposed extraction area. Local people interested in the history of their surrounding area will instead have to wait for AI’s planning application and its environmental statement.

For those in any doubt it would get to this stage, AI has now confirmed that its application will be submitted "in due course".

And yet there is still no resolution of the outstanding issues with statutory agencies, and Devon still has no new Minerals Plan. It is a warning to local people, however, to be ready.

Monday, 17 November 2014

How much Roman archaeology has AI already destroyed at Straitgate Farm?

AI extracted 400 tonnes of sand and gravel from eight pits for testing.

All eight pits were dug in the field now showing extensive signs of settlement from the Roman period.

AI did engage someone to look for archaeology when the pits were first opened. He gave each each pit a cursory glance after the top soil was removed, before giving the excavator the nod to continue. He failed to find anything - in a landscape that’s now proving to be rich in history going back thousands of years...

Monday, 10 November 2014


Somerset’s Minerals Plan is at a much more advanced stage than Devon’s - after DCC’s prolonged wait for Aggregate Industries to prove the viability of Straitgate Farm. Somerset’s Plan was examined in September, and a list of modifications is now out for consultation from 5 November to 17 December.

Somerset has limited resources of sand and gravel, but is a significant producer of crushed rock. This meets some of its demand for sand and gravel, but otherwise Somerset is supplied by quarries in Dorset, Devon and elsewhere. Of the 378k tonnes of sand and gravel that Somerset 'imported' in 2009, 65% came from Dorset (mainly AI’s Chard Junction Quarry on the Dorset/Somerset border) and, if the numbers are to be believed, less than 10% came from Devon (mainly from Hanson’s Town Farm Quarry at Burlescombe, on the Devon/Somerset border, which produces around 170k tonnes pa) [SCC LAA 2013]. In 2009, Devon 'imported' 93k tonnes of sand and gravel from elsewhere; 'much is likely to have originated' from AI's Chard Junction Quarry [DCC LAA 6.4], which produces around 160k tonnes pa.

SCC LAA 2013
What worries Somerset, and plainly the Planning Inspector, is what happens when these quarries finish:
Somerset County Council is mindful that reserves at the Town Farm site in Devon are expected to run until the early 2020s and that the planning permission at Chard Junction expires in 2023 [SCC Statement Sep'14 5.3]
There is a potential resource of around 400k tonnes near Hanson's plant at Whiteball, near Wellington:
Extraction at Whiteball may be proposed on the Somerset side of the border during the next 10 years, moving from extraction on the Devon side of the border. Whilst this is unlikely to change Somerset’s approach towards sand and gravel policy, it will alter the import/export figures, leading to Somerset exporting to local markets in Devon. [SCC LAA 3.10]
But following public examination, SCC has been prompted to add a new paragraph, 6.78:
Somerset County Council encourages proposals to come forward for sand and gravel extraction that are in accordance with relevant policies in the Development Plan and contribute to sub-regional supply. Informed by updates to the Somerset Local Aggregate Assessment, the need for new sources of sand and gravel is anticipated to become more pressing in the early 2020s, notwithstanding there may be benefits of proposals coming forward more quickly. [SCC Statement Sep’14]
If Somerset is now looking for sand and gravel supplies from within its own borders, does this reduce how much Devon needs to allocate in its new Plan? Probably not. SCC said:
It would be premature for the Plan to allocate sites for sand & gravel at this stage, noting the lack of interest from industry in sites for sand and gravel extraction in Somerset (except for interest in the continuation of Whiteball operations) and the lack of information on available resources other than those around the Whiteball operations. [SCC Statement Sep'14 6.9]
And DCC has already recognised the issue. In its latest LAA:
...during the later part of the period to 2031 covered by the LAA, some of the sand and gravel supply previously delivered from Devon will be met from Somerset through continued working at Whiteball. [3.25] However, this supply from Somerset will be offset by the likely cessation of supply of sand and gravel from Dorset, as Chard Junction Quarry, located close to the boundary with Devon and supplying materials into the east of the county, is anticipated to cease working in 2022/23. [3.26]
From a strategic point of view, this likely cessation of supply of sand and gravel from Dorset into the east of the county is probably another reason why Straitgate is so important to AI.


The site comprised the existing quarry together with an area of 34 hectares identified as preferred sites in the minerals local plan…. The council concluded that the need for the mineral had been proven through the site’s allocation in the mineral local plan.
The risk to a protected aquifer in Hertfordshire was sufficient reason for an inspector to dismiss an appeal involving the extraction of sand and gravel from land in the green belt.
Extractive companies contribute in a number of ways, said committee chair Adrian Bailey. But reports of poor practice around the world are a concern and give extractive industries a bad name. To improve the performance and accountability of mining firms, a tough social responsibility index needs to be developed in the UK, which features all extractive companies listing here.
4. Group of experts calls for national minerals strategy to meet the UK’s needs up to 2050
Continued access to minerals in the UK should not be at the expense of adverse impacts on the environment. So far the UK has generally been able to secure adequate and steady supplies within a highly protective environmental framework, and with care this should still be possible.
The community has really rallied together to fight these plans. I think the proposal is an absolute abomination and will totally ruin Shelford Valley. It is completely outrageous.
Delays to the end of work at [AI's] Uttoxeter Quarry has been an on-going issue for residents and the latest plan could see it delayed until the 2020s.

8. Crickley Hill Iron Age battle site preserved
Iron Age battle site containing the remains of a hill fort has been given legal protection by English Heritage
The team of archaeologists, who unearthed the remains of a 2,000 year old Iron Age and Roman settlement and two medieval and post-medieval stone-constructed buildings in December 2012, will be presenting their findings to local residents and interested groups.

Tuesday, 4 November 2014

Straitgate just keeps giving…

Archaeological excavations are beginning to draw to a close at Straitgate, but the Farm has revealed yet another side to its past - as we learnt at a meeting on site today.

Two of the fields have already shown extensive evidence of Iron Age settlement, as already reported. Now, another field is showing widespread evidence of settlement during the Roman period. Numerous samples of pottery have been found, including black-burnished ware and mortaria dating back to around 300AD; baked earth and in-situ pottery possibly shows signs of a Roman corn dryer.

Perhaps the most dramatic discovery has been evidence of substantial earthworks - once a bank and ditch, enclosing possibly a settlement, maybe more... A 20-30m long feature was originally picked up on the geophysical survey; the ditch alone may extend to over 2m in depth. The bank has eroded over time and the ditch has filled with multiple layers of sediment. Pottery from the Roman period was found in the top layers of sediment, with underlying layers obviously pre-dating this. Further investigations are needed and additional trenches will now be opened in an effort to discover its full extent.

A report will be written by the contractors in due course; AI will include this with any future planning application. Whatever form this takes, it is now recognised that there have been settlements of one sort or another at Straitgate over thousands of years. The extent of the area where AI would now need to perform a full archaeological survey, should planning permission be granted, has grown yet again.

Trench running into AI's newly planted trees exposing finds from the Roman period
Baked earth and in-situ pottery possibly shows signs of a Roman corn dryer
Evidence of bank and ditch earthworks

Friday, 31 October 2014

Is this what it takes?

Something quite extraordinary happened this week. Lafarge Tarmac walked into the centre of a media storm, after it submitted Hopwas Woods near Tamworth, 50 hectares of ancient woodland, as a preferred site for sand and gravel quarrying for Staffordshires’s Minerals Local Plan. Local people were furious. A massive response erupted both in traditional and on social media; thousands signed online petitions. Let’s trace just how fast things happened:

Lafarge Tarmac have made an initial representation for Hopwas Wood to be included as a preferred site for future mineral extraction.
The scheme for Hopwas Hayes Wood was not included in the original Minerals Local Plan, which was consulted on earlier this year. But additional site options were then submitted by developers following the first draft and consultation with the public began last Friday.
The Woodland Trust has today been informed of the largest threat to a single ancient woodland site in England that the charity has seen in its 42-year history... Lafarge Tarmac is attempting to reap huge profits from the destruction of ancient woodland – an irreplaceable habitat – and we will object to this proposal in the strongest terms.
Ancient woods like Hopwas are nationally important and to destroy them would wipe out hundreds, if not thousands of years’ worth of ecology, history and beauty that can never be replaced.
What we're concerned about is that people are putting profits before the long term importance of the environment for society. 
Following dialogue with stakeholders and partners we have asked Staffordshire County Council to withdraw the Hopwas Woods proposal from the Minerals Local Plan. We pride ourselves on working in harmony with local communities and want to do so at Hopwas.
This is fantastic news for the people of Tamworth and Lichfield that Lafarge Tarmac have seen sense under the weight of public opposition to the plans. We have never seen a reaction like we have had to this story over an industrial plan. Congratulations to everyone who took part in campaigning to save the woods!
You have to ask yourself, what possessed Lafarge Tarmac to put forward such a site? And why they didn’t foresee the negative public response and the possibility of a barrage of damaging publicity? 

Saying that, in the space of a week, Lafarge Tarmac has seen sense. Aggregate Industries, on the other hand, has not. Are we in Ottery St Mary not shouting loud enough? Or is Lafarge Tarmac better at listening to local concerns than AI? If anyone needs reminding why Straitgate Farm should not be a preferred site in Devon’s Minerals Local Plan - see the post below. 

Ottery St Mary's ancient woodland at Cadhay Bog at risk from Aggregate Industries' plans

Multiple impacts

NPPF: "When determining planning applications, local planning authorities should: ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety, and take into account the cumulative effect of multiple impacts from individual sites…" [144]

Multiple impacts? Like these, for Aggregate Industries' plans for Straitgate Farm?

impact on drinking water supplies to 100 people and Environment Agency’s SPZ
impact on water supplies to 3 farms and surrounding agricultural land
impact on stream flows to wetland habitats in ancient woodland
impact on birdstrike risk to Exeter Airport from ponding
impact on archaeological remains of an Iron Age settlement 
impact on dormice - a European Protected Species - and their habitat
impact from the loss of c.80 acres of the 'best and most versatile' agricultural land
impact from the loss of almost 2 miles of ancient hedgerows with high biodiversity value
impact on veteran oaks
impact on the view from East Devon AONB
impact on surface water run-off and flooding to communities downstream
impact on grade I listed Cadhay’s mediaeval fish ponds
impact on grade II listed Straitgate Farmhouse and its setting
impact on public roads from hauling as-dug material to process off-site
impact on the health and well-being of local people from hgvs, noise and dust 
impact on tourism and commercial interests of Ottery St Mary
impact on restoration plans for Woodbury Common should processing continue at Blackhill

Straitgate Farm - the "best and most versatile agricultural land"

All the land threatened at Straitgate Farm, around 80 acres, is graded under the Agricultural Land Classification as 3a, and is therefore considered the "best and most versatile agricultural land".

In 1968, the Ministry of Agriculture Fisheries and Food strongly objected to plans advanced at that time to quarry Straitgate:
The Minister is anxious to safeguard such valuable agricultural land so far as possible and I am directed to advise that in his opinion there is the strongest possible objection to the proposed development on agricultural grounds.
The application also gives every indication of being "the thin end of the wedge", and if approval were to be granted others adjoining or nearby would almost certainly be precipitated, with the greatly increased loss of further good agricultural land.
How this important natural resource is used is vital to sustainable development. This includes taking the right decisions about protecting it from inappropriate development. 
Planning authorities... should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality. 
Consultations with Natural England are required on all applications for mineral working or waste disposal if the proposed afteruse is for agriculture or where the loss of best and most versatile agricultural land agricultural land will be 20 ha or more.
Standing in one of the fields at Straitgate looking over the farm buildings towards Sidmouth Gap and East Devon AONB

Tuesday, 28 October 2014

“Historic Environment Good Practice Advice in Planning” - the MPA is not happy

The Mineral Products Association - the trade body representing quarry companies - is not happy with English Heritage. The MPA claims English Heritage’s draft Good Practice Advice (GPA) - a series of documents intended to help local authorities, applicants and other interested parties implement the historic environment policy of the National Planning Policy Framework (NPPF) - is "not in tune with the presumption in favour of sustainable development formalised by the NPPF". Its director of planning said:
It seems that English Heritage expects the planning system to protect heritage assets above all other interests and that is not how the planning system is supposed to be operating.
It is bothered that the previous advice "Mineral Extraction and Archaeology: A Practice Guide" - a document produced in 2008 by the Minerals and Historic Environment Forum (MHEF) - has been sidelined, "given only one brief mention in the draft GPA":
In complete contrast to the MHEF, the group that drafted the GPA was comprised almost entirely of heritage professionals. Unless English Heritage involves a broader range of interested parties in the production of the GPA, with a view to winning their joint endorsement to the final document, it seems unlikely that the planning system will afford much weight to what it says. That is also likely to result in a document that reflects a better balance of interests…
In other words, the MPA wants planning advice that better reflects the interests of its quarrying members, and that less reflects the interests of the UK's historic environment. The MPA champions the NPPF’s "presumption in favour of sustainable development", but that's the same document that says local planning authorities "should recognise that heritage assets are an irreplaceable resource [to be conserved] in a manner appropriate to their significance".

But what is in the draft GPA that has made the MPA so angry? Well, and bearing in mind we now have evidence of a settlement of Iron Age roundhouses at Straitgate, here are a few things that English Heritage, a statutory consultee in the planning process, says:

Note 1: The Historic Environment in Local Plans

On Local Plan site allocations - "The best way of ensuring that the selection of sites to be put forward for development supports the delivery of the conservation strategy within the Local Plan is to avoid the selection of sites that will harm the significance of heritage assets." [16]

Note 2: Decision‐Taking in the Historic Environment

On Archaeological and historic interest - "Archaeological interest, as defined in the NPPF, differs from historic interest… because it is the prospects for a future expert archaeological investigation to reveal more about our past that need protecting." [13]

On Assessing the proposals - "Heritage conservation is an objective of sustainable development, as are many other public benefits. The optimum sustainable scheme is therefore one that can clearly show that it avoids, minimises or mitigates conflict between heritage conservation and any other public benefits it may deliver. This may be achieved, for example, by reconsidering the means of providing the public service or benefit, the location or the design." [23] "For loss to be necessary there will be no other reasonable means of delivering similar benefits, e.g. a different design, other mitigation or, as a last resort, development of an appropriate alternative site." [24]

On Decision‐taking for assets with archaeological interest - "For sites with archaeological interest, whether designated or not, the benefits of conserving them are a material consideration when considering planning applications for development." [31]

On Recording and furthering understanding - "…records cannot deliver the sensory experience and understanding of context provided by the original heritage asset, so the ability to investigate and record a heritage asset is not a factor in deciding whether consent for its destruction should be given." [32]

On Public engagement - and remember all the initial hoo-ha and secrecy surrounding the archaeology at Straitgate in September? - "Where appropriate and possible, local planning authorities and the developer are advised to consider the benefits of making the investigative works open to and interpreted for the public and to include that as part of the written scheme of investigation. The results can contribute to a deeper sense of place, ownership and community identity. Promoting understanding will increase active protection for the historic environment. Opportunities for public engagement, proportionate to the significance of the investigation, could, for example, include enabling participation in investigation, providing viewing platforms and interpretation panels, jointly designed open days in partnership with the local community, public talks and online forums as well as coverage in local media." [45]

On Unexpected discoveries during work: "Where a new heritage asset is discovered or an existing known asset proves to be more significant than foreseen at the time of application, the local planning authority is advised to work with the developer to seek a proportionate solution that protects the significance of the new discovery, so far as is practical, within the existing scheme. Developers are advised to incorporate the potential for unexpected discoveries into their risk‐management strategies." [46]

So you can see why the MPA is concerned. It's not going to be in favour of anything - even something as important as the nation's historical and archaeological assets - that hinders the activities and profits of its multinational cement conglomerate backers. English Heritage's GPA is something for us all, including DCC, to bear in mind, as Aggregate Industries pushes on with its plans to bulldoze Straitgate Farm.

Nick Smith

Tuesday, 21 October 2014

Dust impact on observatory stops quarry extension

Dust and noise - two of the main impacts people think of in relation to quarrying. And while noise is a nuisance, dust can be a killer.

Small particles are a particular problem. They can travel large distances and can be damaging to human health even in low concentrations over prolonged periods of time. Terms PM10 and PM2.5 are used to describe particulate matter of 10μm and 2.5μm in size respectively (a human hair is about 50μm in diameter). A quarry can generate significant amounts of this harmful dust over its lifetime, particularly during dry conditions. We’ve written about this dust - Respirable Crystalline Silica - before. HSE advice is that "all RCS is hazardous", and that workers should be told that "very fine quarry dust can cause silicosis, which leads to disablement and early death". The US Health Department warns "Residents near quarries and sand and gravel operations potentially are exposed to respirable crystalline silica". One study concludes "there seems to be a risk also in groups exposed to lower levels [of respirable quartz]. There is no consensus how low an acceptable risk level ought to be".

Keeping these facts in mind, it’s interesting to note that plans for a sand and gravel quarry extension in Hertfordshire were recently refused on appeal - because of this PM2.5-PM10 dust. Perversely, and despite objectors' fears, not because the planning inspector was concerned about the impact of prolonged exposure to this airborne carcinogenic dust on people living as close as 75m away, but because he was concerned about the impact the dust might have on an observatory - 550m away.

The quarry company had put forward a Dust and Air Quality Management Plan (DMP) which claimed to “proactively” manage the dust. Objectors, however, had little confidence in these measures, and nor did the University of Hertfordshire’s Bayfordbury Observatory, who were "...concerned about the potential for a significant loading in PM dust in the air for significant periods of time".

The Inspector was also unconvinced the DMP would work:
I am also concerned about its effectiveness in limiting harmful concentrations of PM2.5-PM10 dust, given their long suspension in the air and ensuing unpredictability and that monitoring and any preventative action would need to be the subject of constant surveillance... Responding to visible signs of dust emissions in dry, windy conditions would plainly not be effective as a preventative measure… For all that the DMP would provide for an enhanced level of control over dust emissions, given the risks and uncertainties that I have outlined above, I cannot be confident that it would prove to be fully effective... I conclude that the proposal would give rise to an unacceptable risk of harm to the operation of research equipment at the observatory, having regard to dust.
But when the planning inspector recognised the "long suspension in the air and ensuing unpredictability” of PM2.5-PM10 dust, and the harm such dust might cause an observatory 550m away, why did he not think that over prolonged periods it might be harmful to people too, living just 75m away? Were his hands tied by planning guidance? Did he put too much faith in consultants' reports? The observatory may have been particularly sensitive to dust, but so too are children, asthmatics, allergy sufferers and the elderly.

Whatever his reason, he refused the appeal anyway, and people nearby were spared prolonged and elevated dust emissions; others across the country continue to suffer. 

Since PM2.5-PM10 dust can travel long distances, planning authorities should be pushing quarry companies to act in a more precautionary manner, pushing for greater stand-offs from nearby communities, pushing for more rigorous dust mitigation. As DCC's Sustainability Appraisal warns, "due to a changing climate there is the potential for the impact of noise and dust on sensitive receptors to become more intense. Hotter summers will provide conditions that will produce additional dust, and people will spend more time outdoors and leave the windows of dwellings and workplaces open for longer". Planners' attitude to dust and the harm it can cause has to change.

PS. On the subject of consultants' reports, prepared for and paid for by quarry companies, and how much trust can be placed upon them, it may come as no surprise that the Dust Impact Assessment for the above quarry extension claimed "any impact associated with dust generation upon the observatory is considered to be low". The Planning Inspector, on the other hand, said "given the apparent importance attached to the observatory’s research activities, any harm arising from operations, notably in relation to PM10 dust, must, I conclude, have the potential to be severe". Low or severe? They can't both be right.

Thursday, 16 October 2014


Archaeological work at Straitgate Farm is ongoing. Further investigation in the areas showing evidence of Iron Age huts has however been on hold - the trenches are full of water. There appears to be a tail-off in archaeological evidence moving further away from the Iron Age settlement, but a few new prehistoric features are being uncovered that had not shown up in the geophysical survey. No evidence has so far been found of the prehistoric boundary running through the site, but this would have to be explored further should planning permission eventually be granted.

Consultants AMEC have just uploaded another round of groundwater measurements from the 11 boreholes around the site, and now have a full 12 months of data from all of the boreholes. AMEC will continue to monitor groundwater levels, and will be producing a report for AI in the new year. They have also sampled water from three boreholes and three springs to test water quality, and continue to take regular stream flow measurements.


Part of AI's undoing, according to The Secretary of State, was:
There is little evidence that thought has gone into alternative layouts and arrangements of structures to take account of the site’s environmental constraints or wider context. Indeed, there is little identification of these, or opportunities, unlike the analysis carried out for the Objectors... [12.36]
A warning that environmental constraints for any application must be properly addressed, even by AI.

In an article in Mineral Planning, on the effects of the NPPF, the director of planning for the Mineral Products Association admits:
Operators have been eking out reserves they already have. The last thing they have wanted is to go anywhere near a planning authority... [as a result] MPA survey figures suggest both producers and consumers have adapted by switching from sand and gravel to crushed rock.
On the subject of planning, he bemoans that:
Concern over vulnerability to legal challenge is leading to an ever more precautionary approach by regulators. This results in delay and unnecessary costs in providing superfluous information to support plan allocations and planning applications.
Superfluous information? Is that really the industry's thinking when responding to its impact on people, groundwater, ecology, history, endangered species, dust, noise, traffic, etc?

An article by Environmental Working Group claims that thousands in the US are exposed to potential health risks from silica sand mining:
Research has shown that these particles can degrade air quality as far as 750 meters away, leading to a variety of serious health problems, particularly in children and other vulnerable populations.
Dust, and its effects upon health, is a continuing concern around quarry sites in the UK; we have written a number of times in the past about Respirable Crystalline Silica.

4. Business and society: defining the 'social licence'

An article by John Morrison in The Guardian argues that:
Social licence can never be self-awarded, it requires that an activity enjoys sufficient trust and legitimacy, and has the consent of those affected. Business cannot determine how much prevention or mitigation it should engage in to meet environmental or social risk – stakeholders and rights-holders have to be involved for thresholds of due diligence to be legitimate (sometimes even if these are clearly determined in law).

A blog on the impacts of mining across the world, by a PhD candidate at the University of Bristol, tackles the subject of corporate social responsibility or CSR:
Often, CSR in the mining industry is little more than a public relations exercise, with no tangible reality to support its elaborate rhetoric.
6. Prehistoric boundary

For anybody interested in learning about Prehistoric Boundaries - like the one thought to run through Straitgate Farm - this English Heritage document explains more.

Friday, 10 October 2014

The cumulative effect

Let’s summarise what’s happened since 2012, when DCC decided that Straitgate was the best of 10 sites in East Devon to put forward as a Preferred Site for sand and gravel in its new Minerals Plan.

In 2011/12, DCC performed a "detailed appraisal" of each of the 10 sites to find those with "the least constraints and most likelihood of potential delivery". It found issues with all of them - but apparently Straitgate (S7) was the only site without a ‘showstopper’; of course, it was also the only site owned by Aggregate Industries. DCC's belated Sustainability Appraisal - a process which did not inform the rejection of the alternative sites as it should have - found even more constraints. In fact, Straitgate had more "significant negative impacts” than almost any other site; the Environment Agency remarked "It is apparent from the SA that some of the excluded sites may [be] preferable in environmental terms".

Since DCC’s original appraisals, Straitgate’s list of issues has only grown. We now know that:

Natural England, the Environment Agency and Exeter Airport all have unresolved concerns;

Cadhay Bog, with its ancient woodland and wetland habitats, is now recognised in all likelihood to have been wooded for up to 10,000 years, being a remnant of the 'wildwood' that colonised Britain after the last Ice Age. According to SLR, AI’s consultants, Cadhay Bog is “in very good condition” with "significant biodiversity interest” and "the ecological site most at risk from the proposals”;

Straitgate has a population of dormice - a European Protected Species; AI will need to convince Natural England that a quarry and the removal of almost 2 miles of ancient hedgerow dormouse habitat is "preserving public health or public safety or other imperative reasons of overriding public interest including those of a social or economic nature and beneficial consequences of primary importance for the environment”, has “no satisfactory alternative” and “will not be detrimental to the maintenance of the population of the species concerned at a favourable conservation status in their natural range”;

And now, the fields at Straitgate are also revealing signs of Iron Age settlement that will probably require a very full archaeological excavation before any quarry could ever take place.

Any of these new developments might have been considered ‘showstoppers' in their own right, but when you combine them all, and then add them to the ones we knew about before - 100 people and 3 farms relying on the site for drinking water, increased birdstrike risk to aircraft from ponding, visual impact on AONB, flooding, effect on Grade I & II listed buildings, off-site processing using public not internal haul roads - then the cumulative effect of any quarrying makes Straitgate look a non-starter. Sometimes you wonder whether DCC couldn't have picked a more constrained site if it had tried.

Of course, if DCC does go forward with Straitgate as its preferred choice, it will somehow have to persuade a public inspector of the soundness of relying on a site with potentially as little as 6 years, or less, of sand and gravel... and a list of issues as long as your arm.