Environment Agency and Natural England respond again to Straitgate

DCC has received new responses from the Environment Agency and Natural England, this time in connection to the Sustainability Appraisal Report, referred to earlier, 18 July and 26 June.

Both statutory consultees commented on timing, the Environment Agency saying "We advise that this Sustainability Appraisal (SA) should have accompanied the formal consultation in March 2012 which set out your Authority’s preferred sites for future quarrying in East and Mid Devon." The Environment Agency were also of the opinion that "It is apparent from the SA that some of the excluded sites may [be] preferable in environmental terms" confirming the view that DCC focused rather more on "deliverability" - all the preferred sites are owned by Aggregate Industries - and much less on the "constraints". 

Natural England stated that "there are many contradictions and inconsistencies in the report which appears to have been written, not only after preferred options were selected, but also justifying those preferences - sometimes with inaccurate statements. For example, CAA advice for aircraft safety which conflicts with a proposal is usually considered a high not minor risk; travelling unnecessarily 9km though an SAC to process material further away from its final destination is not considered to be a neutral impact." With regard to Straitgate (S7), and the impact on Ancient Woodland and wetland habitats in Cadhay Bog, "If the Airport Authorities require no or maintained ponds as per their guidance on bird strike, we advise that mitigation would be either extremely difficult or not be possible, particularly given other ground water constraints and therefore consider this to be an immitigable impact of high significant negative impact." On the subject of processing at Blackhill, "Natural England has serious concerns regarding potential continued processing at Blackhill Quarry due to its sensitive location within the SAC. Although we have some concern regarding later restoration we are particularly concerned about the importation of waste material (including wet silts and water used to clean waste) with a higher nitrate content than that appropriate for restoration in a heathland area which requires negligible or preferably no nutrients. As Straitgate is intensively dairy-farmed, it would be impossible to prevent nitrates from entering lagoons at Blackhill if material were brought to Blackhill as dug. We advise that off-site processing at Blackhill is therefore an unacceptable high negative impact not highlighted in the SA report which should be noted."

DCC wanted an "evidence base" before delivering its Mineral Plan. Yet again the Council has been told that Straitgate is an unsuitable site.

Where are AI's priorities?

What impression does a company give when it can't pay its drivers on time, yet can afford membership of the Conservative Party's Leader's Group?

Apparently things have been so bad for Aggregate Industries with “unprecedented difficult operating conditions” that for the last two years in a row it has had to delay payments to drivers, putting some businesses at risk. The Road Haulage Association made representations to Government, and subcontractors were warned about accepting further work.

Yet the company did not delay payment for some things: "In 2011, Aggregate Industries paid the annual subscription of £50,000 for membership of the Conservative Paty [sic] Leader's Group", (Source: AI, GRI Index, Society S06), on top of £100,000 donated to the Conservative Party since 2008. The Conservative Party web site says: "The Leader’s Group is the premier supporter Group of the Conservative Party. Members are invited to join David Cameron and other senior figures from the Conservative Party at dinners, post-PMQ lunches, drinks receptions, election result events and important campaign launches." In case the company's views are not heard here, "In 2011, Aggregate Industries joined the Industy [sic] Parliamentary Trust to engage in a fellowship programme with Andrew Bingham MP. The programme is not a lobbying platform, but is designed to promote the work of both our industry and government and has seen Mr Bingham visit several of Aggregate Industries' UK operations and has seen Aggregate Industries employees spend time at Westminster" (Source: AI, GRI Index, Society S05).

The concern must be that companies who buy access to politicians expect a quid pro quo. Regardless of how the National Planning Policy Framework (NPPF) arrived at its current form, it has become known by many as a "developers' charter", being welcomed by construction firms and trade bodies alike - the Mineral Products Association (MPA, of which AI is a member) for one saying "the [NPPF], which the MPA welcomes, now has to prove it can help to deliver sustainable development quickly".

If Aggregate Industries, with its Swiss-based parent company Holcim capitalised at £11bn and with enough cash to dine at the top table of UK politics, wants to be considered a decent neighbour in our communities whilst exploiting our local countryside for profit, the very least it should do is be open with people, treat them decently.... and pay its bills on time.

Another MP visits Ottery

Following the recent visit by Environment Secretary Caroline Spelman MP, who came to see the flood damage in Ottery St Mary and the newly built flood defence scheme at Thorne Farm Way, Hugo Swire MP also visited Ottery last week to see the affected areas. He too was briefed by the Environment Agency, and felt it important "that we double our efforts" to prevent a repeat.

What does 'sustainable' mean?

Scheme of sustainable development:
at the confluence of three constituent parts.
Source: Wikipedia

The phrase "meeting the needs of the present without compromising the ability of future generations to meet their own needs" appeared as long ago as 1987, and now 'sustainable' development is the overriding theme running through the National Planning Policy Framework - "Sustainable means ensuring that better lives for ourselves don’t mean worse lives for future generations", "Sustainable development is about change for the better, and not only in our built environment" and "Development that is sustainable should go ahead, without delay – a presumption in favour of sustainable development that is the basis for every plan, and every decision." 

Quarrying sand and gravel from the Budleigh Salterton Pebble Beds, a finite resource, by definition can never be described as 'sustainable'. 

'Sustainable' can mean using recycled and secondary aggregates, or using farmland for the generation of food, or using groundwater for drinking water supplies, or using our scenic and historic assets to promote tourism for the support of local businesses.

'Sustainable' does not mean dumping ball clay sand and gravels as waste whilst quarrying for primary aggregates, or polluting local villages by hauling as-dug material to Woodbury Common for processing, or hauling silt or other material back to Straitgate for restoration, or damaging ancient woodland and wetland habitats, or losing groundwater supplies for up to 100 people and 380 acres of grazing land, or increasing flood risk to downstream communities.

Straitgate Farm performs a number of very useful functions, including being a productive dairy farm, holding groundwater for drinking supplies, and moderating water run-off to limit flooding. Quarrying would permanently degrade all these functions for future generations, and therefore would not only be unnecessary, unjustifiable, and unmitigatable, but completely unsustainable.

Aggregate Industries would have us believe they are committed to sustainability, and their web site with all that grass is very 'green'. The statement "As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport" has been rolled out a number of times - however not in relation to their normal activities, but to the erection of wind turbines in Cornwall, Lancashire and County Durham.

No major revisions

We were pleased to hear from the Minerals Officer this week that, unlike in some previous years, Devon's sand and gravel reserves showed no major revisions by mineral operators last year, and were confirmed at 9.16 million tonnes (Mt) at 31 December 2011, down from 9.62Mt the previous year and reflecting the production figure of 0.44Mt for 2011. Indications are that 2012 will be lower still, with industry figures showing that nationally, for the first half of 2012, sales of sand and gravel are down 13% on the same period last year. The Mineral Products Association has also forecast "further declines in construction and mineral products markets in 2013". It is now difficult for DCC to continue to make the case, as it did in the February 2011 Mineral Core Strategy, that (4.3.12) "The anticipated economic recovery may see this decline [the decline that started in 1988] level off or, in the medium term, be replaced by increasing demand for aggregates."

The landbank in years, under DCC's current policy MP20, is therefore now 16.7 years, up from 15.5 years, on the basis of a reduced 5 year average of 0.55Mt. With level production, and no reserve revisions by mineral operators, the landbank in 2013 will be (8.26/0.46) 18.0 years, i.e. to the end of the new Minerals Plan in 2031.

Aggregate market investigated by Competition Commission

Is now the time for DCC to be promoting a site belonging to Aggregate Industries when they and others are the subject of a Competition Commission investigation, the result of which will not be known until 2014?

In January 2012 the Office of Fair Trading referred the aggregates, cement and ready-mix concrete [rmx] markets to the Competition Commission (CC) having "concerns regarding structural features of these markets and reasonable grounds for suspecting that these are preventing, restricting or distorting competition." The confidential parts of AI's response have been removed, and whilst acknowledging that what they say to the CC in answer to their concerns might not correspond exactly with what they would say to DCC to justify the need for a brand new sand and gravel site at Straitgate Farm, from what remains there are some interesting snippets.

Firstly AI bemoan their economic situation: "2.22 This is an industry suffering from a substantial fall in demand, increasing costs and significant pressure from customers. These are not the market conditions that favour suppliers seeking to profit to the detriment of consumers."

A couple of relevant themes come out: On the subject of demand:

"1.3 A fundamental change in building techniques and preferences meant that as the UK economy improved during the 1990’s the demand for aggregates did not return to pre-recession levels. More recently a sharp downturn in demand since 2007 has resulted in an unprecedented contraction in house building and infrastructure  expenditure." "2.1 A significant contribution to the lack of recovery in the 1990s was a  change in the design of buildings. Steel, glass and timber, for example, are increasingly used as a replacement for rmx.  Improvements in the design of buildings and houses, as well as better concrete specification, have also significantly reduced the demand for aggregates and concrete." "2.6 Forecasts for the future provide little encouragement for a recovery until at least 2015: (a) the Government’s austerity measures mean that any increase in public spending on infrastructure projects in the near future is highly unlikely."  

On the subject of secondary and recycled aggregates:

"3.10 The increase in the levy on primary aggregates, new recycling technology and changes in product specifications over the last 15 years have supported the growth in sales of recycled aggregates. Whereas primary aggregates suffered a fall in demand post 1989, recycled and secondary aggregates grew throughout the period from 1989 to 2007. Secondary and recycled aggregates have, according to the [Mineral Products Association], grown from constituting 9% of all UK aggregates in 1989 to accounting for 28% in 2010." "3.11 Secondary and recycled aggregates are a substitute for primary aggregates for a significant proportion of the use of aggregates in the UK. For example: (a) secondary and recycled aggregates are entirely substitutable with primary aggregates for general construction purposes and produce a highly similar product with comparable integrity;... (c) some secondary aggregates, china clay by products from Devon and Cornwall, are used as complete substitutes for primary aggregates across all applications;" But AI complain that "6.5 As noted above AI is strongly of the view that aggregates taxes and credits distort efficient production. AI agrees that the landfill tax and latterly the aggregates levy have been a barrier to the expansion of primary aggregates and results in the favouring of secondary and recycled aggregates over primary aggregates" and "6.7 The aggregates levy has given producers of secondary and recycled aggregates, primarily independents, a significant cost advantage....(a) The 2009 BDS report found the “Introduction of the aggregates levy has changed the economics and distorted the market. It is now possible to economically supply china clay sand into the south east, and slate wastes into the midlands. […] Untaxed aggregates have a cost advantage over taxed aggregates. This distorts the market”.

So when AI themselves accept that the economic outlook for aggregates is bleak, and that secondary and recycled continues to displace primary aggregate, it is not the time for DCC to go designating new greenfield sites when there are still over 9 million tonnes and 20 years of reserves in the County.

Letter to DCC

Letter to Dave Black, Head of Planning and Transportation at DCC.

Is there a conflict of interest in DCC with the same person overseeing the environmental auditing and preparation of the new Minerals Plan? Why were Preferred Sites selected before the recommendations of the Sustainability Appraisal were known - a process which incorporates the legal requirements of the EU's Strategic Environmental Assessment?

Why is DCC not allocating Straitgate Farm as a "Preferred Site" for food production?

With food production needing to increase by 70% over the next forty years to feed the world's growing population, but demand for sand and gravel in Devon falling for the last 20 years, why is DCC proposing to sacrifice for quarrying a perfectly good dairy farm currently producing about 1 million litres of milk each year? The loss of Straitgate as a working farm would almost certainly be permanent if quarrying took place. Restoration does not work, on the basis of other sites and according to local farmers, with soils not easily consolidating and becoming productive again. Does DCC not value farmland? Some might argue that rather than helping Aggregate Industries find their next site, the County's Planners should be safeguarding and allocating more agricultural land for the security of our food supply. Otherwise, future generations may regard any decisions by DCC to remove good agricultural land from the food chain as misguided and irresponsible. 

They had their priorities right in 1968, and the Ministry of Agriculture Fisheries and Food (MAFF) was one of the more vociferous objectors to the Straitgate development, saying "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." Then, little more than 20 years on from a World War, people were perhaps more conscious that security of food supply was of national importance, but with some now predicting a global food supply crisis the issue is receiving renewed attention, and a report by the Henry Jackson Society, a leading independent think-tank, entitled ’Shocks and Disruptions: the relationship between food security and national security’ tackles the issues. 

In 1968, Straitgate Farm was regarded, as it is today, as highly productive, and in the Inspector's report from the Public Inquiry, "363) ...well-situated and climatically favoured" with land that "362) In the recent survey of agricultural land 48% of the site is categorised as Class II and the balance as Class III." What concerned MAFF was that "365) 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." With Aggregate Industries owning the surrounding mineral rights for thousands of acres this continues to worry local people today.

It is telling that many developers and trade bodies, such as the Mineral Products Association, have welcomed the NPPF, but on the subject of agriculture: "28. Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development. To promote a strong rural economy, local and neighbourhood plans should...promote the development and diversification of agricultural and other land-based rural businesses;" and "112. Local 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 a higher quality."

In East Devon, high quality farmland seems to be disappearing to development at an alarming rate, and the warning from MAFF at the Public Inquiry in 1968 "363) ...that its retention is more than ever necessary to maintain production in a rapidly expanding urban society from a fast contracting acreage" will still resonate with many today. CPRE for example have recently warned: "We think that strong protection for best quality agricultural land should be an absolutely critical part of sustainable development, given that such land is a finite resource and the pressure on food and farming from wider global pressures of climate change and population growth."

Flooding

Ottery St Mary

Ottery St Mary has a history of flooding: in recent years, August 1997, September 1997, September 1998, October 2005, November 2005, October 2008, and now 7 July 2012. Aggregate Industries need to be aware just how much it can rain here, and how much water they would have to manage if they quarried Straitgate Farm.

Flood water in Cadhay Bog

The Environment Agency on the other hand is very much aware of how much it can rain here, and on Sunday Richard Cresswell, the Environment Agency director for the South West, briefed Caroline Spelman, the Environment Secretary, on the measures being taken to protect Ottery. When Mrs Spelman stood in front of the newly completed flood relief channel at Thorne Farm estate, however, and proudly recounted to the press how this government-funded measure had saved 60 properties from flooding (by coping with all the water coming down from Straitgate through Cadhay Bog), did she know what Aggregate Industries and Devon County Council were planning further upstream that could endanger this scheme and the properties it protects?

Still flooding from Cadhay Wood
several hours later

Residents around Cadhay do not yet have the benefit of any flood defences, and, well after the rains had stopped, water from Cadhay Wood was still flooding out over the road opposite the drive to Cadhay House. This is the stream where Aggregate Industries have in the past planned to discharge run-off from a quarry at Straitgate. If removing groundwater storage or compacting the ground increases the run-off though Cadhay Wood in times of extreme weather, it is not difficult to predict negative consequences. These photographs, taken on 7 July, show how much water Aggregate Industries would need to manage after 50mm of rain. The Climatic Research Unit at the University of East Anglia, however, predicts an increase in heavy rainfall events over the next few decades. Any plans for Straitgate Farm would, according to the Environment Agency, need to be "...subject to a scheme being submitted for the management of surface water that will safely manage the ‘1 in 100 year plus climate change’ rainfall for the lifetime of the development", and furthermore "any development of this site should seek opportunities to reduce these risks of flooding...".

If Devon had relied on the forecasts of 1968...

How much faith should we have in forecasts? ECC (now Aggregate Industries) based their planning application to quarry over 800 acres of East Devon in 1968 on forecasts. Now in 2012 DCC has decided it needs to identify new sites for future sand and gravel quarrying, again on the basis of a forecast, which has identified a shortfall of reserves some time over the next 20 years. 

The Public Inquiry of 1968, deciding the fate of those 800 acres, heard a number of forecasts, and now with the benefit of hindsight we can see how accurate they were. ECC's submission to the Inquiry forecast that "58)...the demand from the two complexes in the year 2000 will be 2.42 million tons, made up of 1.23 for Blackhill and 1.19 for Rockbeare. This is based on a probable increase between 1966 and 1980 of 6.3% per year, following the official forecast rate of increase, and an increase of 4.5% between 1980 and the year 2000, based on official forecast population increases for the South West". The Planning Authority challenged this forecast, and thought "it should be 2.11 million tons". In the year 2000 the actual figure for Devon turned out to be only 0.8 million tonnes, or just 33% of the forecast; in 2011 it was even lower at 0.44 million tonnes or 18%. Their submission also maintained that "55) Nationally, the production of sand and gravel increased annually between 1958 and 1966, from 60 to 100 million tons, and the forecast for 1980 is 215 million tons." The actual national figure in 1980 was less than 100 million tonnes, or 45% of forecast.

Mr. Douglas Frank QC, acting for the Devon River Authority, East Devon Water Board and others, challenged these forecasts, "348) It is contended that no decision should be taken in the absence of a full investigation, to avoid another "Stanstead" case. The company have assessed future need far in excess of any normal period for making forecasts of demand, and on the theoretical basis of population estimates, which are noted for their inaccuracy. This may be inevitable in the case of development plans, or planning water resources, but they do not look 60 years ahead and population figures should not be relied on for a long period. It is equally dangerous to relate population to production in the past. 349) Who is to know what new materials or circumstances there will be in 40 years time? The official estimate is that there is not enough sand and gravel for more than 20 years. If this is right, then an alternative will have to be found, and it may be decided that it will be better to exploit the alternative than to do so much damage."

Mr. Frank's remarks proved to be the more prescient. How fortunate for Devon that the Inspector and Minister both decided that the applications to extend Blackhill, and open new sites at Colaton Raleigh and Straitgate "be not approved."

What are we to learn from this? Some may conclude that mineral companies and Planning Authorities are poor forecasters of future aggregate demand. Others, that long term forecasting is fraught with difficulty and that the Council must take the utmost care in allocating sites, preferred or with permission, before they are truly required, and before all the alternatives have been explored. At the end of 2010 the County had 9.62 million tonnes of sand and gravel reserves, over 20 years worth with the ever decreasing amounts used each year. Borrowing the Inspector's concluding remarks, which still seem relevant today, there may be "408) (p)...other land with less disadvantages, and it is not possible to say now that the need for the Straitgate site is in any way overriding. For this reason any approval would be premature, and my recommendation not to allow that application also is on that basis, apart from water supply considerations."

Near miss on the B3180

We have been notified by a local resident of a near miss this week on the B3180:

On Monday 2 July 2012 at 10.20am we were driving South on the B3180, towards our home. We left the 30 mph restriction zone of West Hill at Tipton Cross and approached the double S bend. Turning the blind corner we immediately encounterd a large lorry reversing towards us. Luckily we were able to stop in time. We, and a car following us, then had to reverse as the lorry continued to do so. We were on a blind bend in a potentially very dangerous situation. The lorry was reversing in order to allow a Parsons aggregate truck (44 tonne) to pass, going North towards West Hill.

The passenger captured the following images on their phone. The Parsons truck was part of an operation by Aggregate Industries transporting sand and gravel from Marshbroadmoor to Blackhill Quarry for processing, the same route proposed for transporting Straitgate material.

Why did Straitgate Lake increase in size?

With water being such an important issue at Straitgate we were not surprised to see a water feature of some sort on the 1967 restoration plans. What did surprise us was its size - "Straitgate Lake" was to cover 32 acres. However, between February 1967 when the plans were submitted, and 9 July 1968 when the Public Inquiry started, Straitgate Lake had "grown" to an even larger 49 acres. From the report by the Inspector to the Minister of Housing and Local Government, then the Right Honourable Anthony Greenwood MP, 8 October 1968, on the applications to quarry at Blackhill on Woodbury Common, Colaton Raleigh Common, and Straitgate Farm, it seems apparent why this happened. 

In the submission by the Devon River Authority (now the Environment Agency) the report talked about the likely effect on flooding: "342) Villages affected by flooding from those areas generally including the proposed sites are as follows:- ..... Cadhay [from] Straitgate". (Thorne Farm estate had not yet been built.) "343) Although the pattern of development of these villages renders the present flooding conditions tolerable to some extent, any increase in the frequency and extent of such flooding as a result of the company's proposals would be intolerable. 344) Control of such flooding could be effected by means of either:- (a) Additional flood relief channels and culverts within the villages, or (b) Use of the proposed lakes for "balancing" flood flows with appropriate settings of the proposed overflow weirs. 345) Agreement in principle on the second solution has been reached between the river authority's officers and the company's representatives, and only matters of detail e.g. the precise settings of the overflow weirs, remain to be finalised."

It would appear therefore that Straitgate Lake had grown from 32 to 49 acres by negotiation in order to satisfy the requirements of Devon River Authority in mitigating the flooding effects on Cadhay. This scheme was only possible because the eastern half of the site was to be quarried creating a void of sufficient proportions. Today there is no plan to quarry this area: DCC states "site appraisal found that there is likely to be a significant impact on the water environment (and consequently on biodiversity) if mineral extraction occurred in the eastern half of the S7 site", and it did not therefore form part of the Consultation. To create an area now to hold the amount of water planned in 1968 would require the extraction of approximately 1.2 million tonnes of material. We wonder how much area Aggregate Industries are now proposing to set aside to capture storm run-off to protect the residents at Thorne Farm, Cadhay, Salston and Coombelake from flooding? 

It was also clear from the Public Inquiry report that the Devon River Authority did not believe that ECC's proposals to recharge the aquifer would work. "336) As to the recharge proposals; the company seek to effect flood-control, maintain river flows, and recharge the aquifer sufficiently to compensate the losses as a result of the proposals, all by means of lakes formed from silt ponds. 337) These are incompatible objectives, and in particular such experience as exists on the artificial recharge of aquifers indicates the impracticability of the proposals in that respect. 338) This is apparent when the recharge proposals are considered in more detail. The shallow - sloping faces of the Pebble Beds intended to effect the recharge would experience silting on the lower and weed and algae growth on the upper sections, thus achieving the opposite effect. Furthermore the lakes would range in level from about their full 10 feet depth to perhaps 6 feet depth in extreme conditions. Therefore accurate control of the rate of recharge would be impossible with such wide variations, and the wide band of expected Pebble Beds when lake levels were low would encourage weed growth still further."

Something to bear in mind if Aggregate Industries think they can maintain the wetland habitats of Cadhay Bog and Cadhay Wood through recharge ponds; the ponds that would of course be contrary to the advice of Exeter Airport.

Cross section of 1967 restoration scheme

DCC newsletter published

The ninth issue of ‘Devon Minerals Update’ has just been published by Devon County Council.

We hope the Plan will be published by Summer 2013, with an opportunity to comment in advance of it being submitted to the Secretary of State. After this, a Planning Inspector will examine the Plan through a public inquiry. If the Plan is found to be sound, Devon County Council will formally adopt the Minerals Plan in 2014.

AI wanted housing for Foxenhole Quarry

Foxenhole

Restoration plans may have included beaches, boathouses and landing stages in the 60s, or woodland clearings with picnic areas and footpaths with educational boards today, but the reality is often very different, as the residents of Uffculme will know, with quarried "brownfield" sites turning into landfill, composting and blockwork operations. In the 1967 planning application for Straitgate, ECC Quarries (now Aggregate Industries) promised to restore half of the land back to agriculture, and claimed this would be of a "higher agricultural quality" than before. At Foxenhole, just 1000m south east of Straitgate, local farmers will attest that the outcome was in fact the reverse. This land was quarried until the mid 90s, and the once productive farmland has now been lost. This did not bother Aggregate Industries however, who had more profitable uses in mind. In 2010 they took an unusually keen interest in how our community should be shaped, and made a number of submissions to the East Devon LDF Core Strategy Preferred Approach Consultation. They mentioned Foxenhole some 14 times: "Growth ensures that rural communities are more socially mixed and can help make productive use of surplus land (such as land at Foxenhole in West Hill)", "West Hill and particularly land at Foxenhole, stands strongly against the test for being a suitable location for tourism related accommodation", "...it is considered that West Hill, and in particular land at Foxenhole, provides a sustainable and appropriate location for affordable housing outside the settlement boundary", "...the land at Foxenhole represents a strong opportunity for further growth in the village and it could come forward within the first 5 year period", etc. 

As it turned out, Aggregate Industries sold the 15ha (38 acres) of land they owned last month, having faced highway constraints with the site. Given that residential building land in the South West with outline planning permission was averaging about £1.5m/ha (VOA Property Market Report 2010) you can see what had piqued their interest. Restoration doesn't generate a profit, selling a hole for development or landfill does. When Aggregate Industries propose a restoration scheme for Straitgate, will anybody believe it?