Minutes of the 'seven suits meeting' have now been produced. Aggregate Industries, in wanting the meeting to be confidential, was asked to produce the minutes itself to ensure they did not contain "issues that the Company wished to remain confidential". As it turned out, despite the number of AI delegates, the author was not actually present at the meeting, and the model outlined in 3.4 and 3.5 was not actually the one described at the meeting - according to subsequent conversations we’ve had with the EA and DCC.
Regarding the matter of the 1m standoff above the maximum recorded water table, AI says it was the "the presentation of information [in its planning application] that had been misinterpreted" by statutory consultees: the Environment Agency, Natural England, and the Mineral Planning Authority.
But to put it down to misinterpretation by others is disingenuous in the extreme. If AI had wanted people to understand that it was proposing to leave zero metres of sand and gravel above the maximum recorded water table, it only had to use clear unambiguous language to that effect from the start, or in further communications, or in its Regulation 22 response - see post below. Furthermore, nowhere did AI’s planning application make reference to a summer and winter working regime; nowhere was there an indication of extraction phasing that might accommodate this. There was, however, clear unambiguous language from Amec, AI’s consultants, in its hydrogeology report. Here’s one example from several:
The removal of the unsaturated zone down to a level of 1 m above that defined by the maximum winter water level will mean that any change in the recharge/runoff split…
One can only surmise, therefore, that Amec’s conclusions on the impact of AI’s proposal were on that basis. If the standoff proposed above the maximum winter water table is now 0m, Amec should be asked whether it stands by those previous conclusions or whether the impacts need to be reassessed.
However, the simple fact of the matter is that AI did not want to make it clear that it intended to leave 0m of sand and gravel unquarried above the maximum water table, or that post-restoration it intended there to be just 1m of soil above the maximum water table - 30cm of topsoils and 70cm of subsoils - to protect water drinkers from nitrates or other contaminants that might be produced from any future farming or alternative land-use. When Hanson proposed to quarry Town Farm at Burlescombe - same geology, fewer private water supplies - it did make it perfectly clear that "Post restoration (including the placement of soils) the resulting ground surface will be at least 2m above the water table" 1.4.8 because "the unsaturated zone above the water table affords protection of the aquifer from surface pollution, allowing adsorption, attenuation and degradation of contaminants prior to reaching the water table" C3.1.
An expert's advice on the importance of leaving 1m of sand and gravel unquarried above the maximum water table is also perfectly clear and needs repeating:
Future land uses, after site closure, will be limited by the available unsaturated zone thickness. 3.8
Post-restoration, due to the decreased depth to groundwater and more limited ability of the ground to attenuate contaminants, it is appropriate to impose restrictions on land use. Although nitrate and bacteria, as might result from intensive agriculture, are not contaminants of concern for the quarry and cleanfill operation, these may pose a risk to groundwater quality for downgradient users if the post-rehabilitation land use causes discharges of these contaminants (including diffuse discharges). 6.1(g)
Through quarrying the exposure pathway for any contaminants has been modified. This means that there may be rapid access to the groundwater system for any contaminants, including pathogens. 6.2
When soil is first reinstated, its ability to attenuate contaminants will be lower than for a well-established soil. In a well-developed soil, the top soil grades into the underlying gravels, allowing for further attenuation of nutrients and pathogens. The soil condition would improve with time, but depends on soil management practices. 6.5
Compound all this with the fact that AI doesn’t know with any degree of certainty where the maximum water table actually is across the whole site - even if there were a piezometer in the centre of the site giving the height of groundwater during any quarrying operation - and AI’s whole scheme is patently reckless. If 1m is typically left unquarried above the maximum water table at other sites with sensitive groundwater receptors, it beggars belief that for Straitgate Farm - where the issue of water is so important, be it for flooding, wetland habitats in ancient woodland, airport safeguarding or drinking supplies for large numbers of people and livestock - anything less should even be a consideration.
