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.