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".
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.