Another round of drilling at Straitgate over

There were interesting scenes on the B3174 out of Ottery St Mary this morning, when the rig contracted to Aggregate Industries headed back to Straitgate to await removal after two weeks of drilling in and around the farm. Locals, tourists, farmers and borehole-drillers all vied to use the road at the same time; no prizes for guessing which one doesn't belong here.

The groundwater levels in the five new boreholes, in addition to the earlier ones, will be monitored over at least 12 months to determine seasonal variations and the impact of rainfall. Such data will either support or undermine AI's mitigation plans. The picture below shows one of the holes being drilled. There was no shortage of water, as the drillers will attest.

Further ten years allowed for quarry in Cairngorms national park

That's the headline in Minerals Planning. What a disgrace you might think? How could they? However, compare and contrast this last paragraph of the article with the plans for Straitgate:

The authority noted that the proposals were small scale and the impacts were local and temporary. In addition, the site was relatively remote and there would be no loss of amenity for residents. Extending an existing quarry was more sustainable than opening a new site and the restoration had the potential to enhance the natural heritage of the area by restoring agricultural land and improving the appearance of the site. The development would also support the local economy.

Does any of that apply here? No. OK, East Devon's not a national park, but the article highlights that there are ways that quarrying can cause less impact on people and people's lives, and there are places where quarrying can cause less impact on people and people's lives. Straitgate Farm, Ottery St Mary, is not one of those places; Aggregate Industries' proposal is not one of those ways.

Not fracking, but a precursor to something potentially as harmful to local water users

No, not fracking or hunting for shale gas in East Devon. But it is exploration of a sort. Aggregate Industries today started drilling additional boreholes at Straitgate Farm, to set up further groundwater monitoring points in an attempt to understand the area's hydrogeology to support its mitigation plans.

The requirement to drill these extra boreholes is an indication of how important the area is in terms of groundwater. AI's proposal - excavating a huge pit right in the middle of this area, removing millions of tonnes of groundwater-bearing sand and gravel both above and below the water table - could result in irreparable damage to the local water regime, causing loss to the people, the agricultural land and the ancient woodland that rely upon it. AI's mitigation proposal is based on limited information at this stage - in other words, it's a hypothesis, or conjecture. Such a proposal is in any case, as we have outlined before, contrary to airport safeguarding requirements.

Birdstrike quotes - a top 10

Now that Aggregate Industries' "wetland and open water habitats" mitigation plans are on the table - with their inherent risk of attracting birds and conflicting with the safeguarding of Exeter Airport - here's a timely reminder of why such 'watery' proposals are unacceptable. Below are 10 quotes on the subject of birdstrike that we have previously posted over the last year or so:

1. Under the Air Navigation Law, it is a criminal offence to endanger an aircraft or its occupants by any means. Exeter Airport 

2. To ensure aviation safety it is suggested that no ponds or body of water be allowed as part of this development. Exeter Airport 

3. Almost without exception, water developments increase the bird hazard in ways that cannot be adequately controlled. CAA

4. It must be recognised that it is not possible for an aerodrome or aircraft operator to mitigate the hazard caused by water bodies and watercourses, or to prevent birds using areas of open water in the vicinity of the aerodrome. CAA 

5. The exact position of a site within the safeguarding zone is another important factor. If an extraction operation is located directly under the take-off and landing approaches, then this is going to be far more critical than a location 12km out on the runway flanks. Surrey County Council

6. With the move away from infilling sites, those within safeguarding zones worked below the water table and with wet restorations will provide a particular challenge. SCC 

7. Wetland creation is one of the most problematic development types in terms of birdstrike prevention at aerodromes. Wherever possible developers should seek to keep proposals as far from aerodromes as possible and outside the 13km safeguarded zone of major civil and all military aerodromes. Birdstrike Avoidance Team

8. Bird management plans should thus be regarded as an additional measure to give aerodrome managers confidence that no additional risk will result after location and design modification measures have already been used to minimise any additional risk from a wetland development. They are not a means by which otherwise unacceptably hazardous developments can be transformed into acceptable ones. BAT 

9. Whatever the actual increase in risk, the key test that an aerodrome manager applies is one that asks the question ‘if there was an accident involving loss of life at my aerodrome could I defend allowing this development to proceed without objection when I believed that it would cause an increase in the birdstrike risk, however small?’ A planning inspector is likely to ask him/herself the same question. BAT 

10. The aviation industry, be it the airport itself, the MOD or CAA, has never lost a public enquiry regarding an objection if an unacceptable birdstrike risk has been predicted from a development. BAT

And finally, a reminder of what a planning inspector said, in connection with a farmer appealing for permission to keep a 40x25m pond:

...because of [the pond's] critical location so close to the main flight path of the aerodrome at a point where aircraft are on their final approach to the runway, aircraft safety must be paramount. I consider that this development feature which has the potential to attract birds in increasing numbers at this location poses a serous risk to aircraft safety. I find this unacceptable. I conclude that the undoubted ecological benefits of the development cannot outweigh the safety needs of the aerodrome.

It all seems clear to us, but is it causing any head-scratching at AI yet? One might imagine a scene at AI HQ: "To mitigate we need ponds and wetlands, to safeguard aircraft we can't have ponds and wetlands. To mitigate we need ponds and wetlands, to safeguard aircraft we can't have ponds and wetlands. To mitigate... ah, for goodness sake, how difficult can this be?" Or perhaps we underestimate, perhaps AI has a cunning plan...

The elephant in the room

Reports written, plans supplied. Can DCC now rely on Straitgate Farm for its Minerals Plan?

Not in our view. There's a huge conflict that Aggregate Industries has not even attempted to resolve: the conflict between water, birds and aircraft. The plans and mitigation measures put forward outline wetland and water features being created. In fact the consultants say that, for mitigation attempts to work, it is a requirement:

The contours along north-eastern, eastern and south-eastern boundaries of the site should encouraged [sic] groundwater and surface water to pond along these boundaries to replicate the storage that has been lost due to the removal of the unsaturated and saturated zones at the site. (3.3)

But this brings its own complications:

The provision of water storage along the north-eastern, eastern and south eastern boundaries of the site, to mitigate flooding and maintain groundwater flow, also offers the opportunity to create a priority wetland habitat and therefore enhance the ecology of the area. (3.3)

Actually, more than "offers the opportunity" - it will create wetland habitats. And this is where the problem lies, where AI remains completely silent: If an operator wants to quarry under a flight path, it is all about creating and leaving areas unattractive to birds - obviously not like Blackhill Quarry, or Hillhead Quarry, or 100s of other quarries. It's not about "ecological enhancement by the formation of wetland and open water habitats (3.4)" - exactly the reverse in fact. Guidance is given on the matter. Exeter Airport sent DCC a copy. Exeter Airport sent us a copy. And it's not that we haven't said anything about it either - click on "birdstrike" on the side of this blog. AI is either choosing to ignore the issue, or just can't find a way to accommodate it. Here's a reminder from the CAA:

Where water features are absolutely necessary, measures to reduce the ecological diversity of water features and minimise their usefulness to waterfowl should be adopted and should include all of the following, where applicable:

(i) Depth: water should be as at least 4m deep with steeply shelving (preferably vertical) margins, to minimise or eliminate bottom-growing vegetation.
(ii) Perimeter: banks and edges are a source of ecological diversity and important for feeding, loafing and nesting. Their extent should be minimised by the shape being as close as possible to circular, without bays, promontories and islands
(iii) Banks: as in (ii) above, banks should be steeply shelving with minimal vegetation and cover. If possible, there should be a vertical lip or fence to prevent birds from walking in and out of the water.
(vi) ... a wet meadow would attract feeding ducks and nesting waders, and should be avoided.

In summary, follow all CAA guidance to "reduce the ecological diversity of water features". There are other measures too - for example on tree planting. Oh, we can leave all that until the airport make a fuss, AI might say. We'll buy a bird management plan. But for perpetuity? In any case, Exeter Airport may take a different view with aircraft flying directly over the site many times a day at low altitude. And DCC must be confident that the site is deliverable in the face of a seemingly catch-22 situation - can't mitigate without such water features, can't have aircraft safeguarding with such wetland habitats.

This is not some after-thought, some planning condition footnote. It's important and should have been covered in AI's submission. In fact, if you were AI, wouldn't you have knocked the issue on the head once and for all - if you could? AI was aware that the airport was not happy with water. Why did it not deal with it? But not a single sentence, on potentially one of the biggest and most intractable issues on whether Straitgate is suitable for quarrying. Wetland habitats all along the eastern boundary of the site - and not a single word on the safeguarding of aircraft. Amazing. The elephant in the room.

SLR's water report - Hydrological Position Statement

Can DCC rely on Straitgate Farm for its Minerals Plan? A lot hinges on SLR's report which outlines the impact a quarry would have on water - to people, to ancient woodland and on flooding. SLR has put forward a hydrological model and various mitigation measures. It will be up to the Environment Agency to decide whether it all makes sense or not.

The report is a more thorough affair than the last one, the Hydrological Baseline Report of 2012 - it had to be. That report was scant and inaccurate on detail, concluding there were no "significant constraints to site development", that "any encountered groundwater would be pumped and discharged to the local watercourses" and "local water supplies would be monitored and mitigation in the form of an alternative supply would be available if required". That's all changed.

SLR recognises that there are now constraints to development. "Additional monitoring data have been collected and revisions made to the working proposals to limit the potential constraints to development and to answer the concerns and comments raised by the Environment Agency. An updated hydrological impact assessment has been undertaken in light of the additional data and revised working proposals".

SLR recognises that "the ecological site most at risk from the proposals is Cadhay Bog, as it includes significant water dependant habitats" and that "such woods are now scarce nationally and this is a good example of wet woodland". SLR also recognises that there are a large number of properties and farms at risk, and that a detailed field survey is required over an area to be agreed with the Environment Agency. On the positive side, SLR is of the view that "the development offers the opportunity to reduce the current flood risk downstream of the site by the provision of areas within the quarry that can be designed to hold back flood waters during a storm event".

SLR considers that mitigation of the negative impacts may be possible. This would rely on "maintaining the current groundwater flow regime" by leaving 1m of pebble bed on the base of any quarry, creating cut gradients on the eastern side to promote infiltration, and operating no "active dewatering". However, working below the water table is still proposed - "extraction in the more saturated eastern areas of the site takes place when groundwater levels are at their lowest (in the late summer to autumn) and that winter working is restricted to the relatively dry eastern part of the site". It will of course be the EA and DCC who decide on the wisdom of such a measure with 100 people dependent on the area for their drinking water supplies, not AI or SLR.

SLR is of the view - and bear in mind who its customer is - that although Straitgate Farm is a "hydrologically sensitive" site, it "can be worked so that the current groundwater infiltration and flow directions are maintained and storage is provided to mitigate the loss of storage in the aquifer".

The EA will now need to decide whether the mitigation measures put forward stand a chance of working. DCC will need to decide on whether to rely on a report where, as SLR emphasises, "a definitive assessment of the impacts cannot be provided [until] further data is collected on the seasonal variation of groundwater levels and surface water discharge rates".

And finally, what can be said about AI's plans and drawings

Well, Aggregate Industries has made a few changes since its last plans - and remember, these are just concept drawings at this stage to satisfy DCC's Minerals Plan - moving the access from the west to the north for example, bringing the extraction boundaries further from homes, leaving some material on the base in an attempt to mitigate water impacts.

But AI is still claiming it has 3.1 million tonnes of recoverable and saleable sand and gravel at Straitgate - down from 3.6 Mt. This is of course totally dependent on AI being permitted to extract sand and gravel below the water table, and with so many people reliant on water from the site, it is unclear whether the Environment Agency would sanction that. AI was only permitted to quarry down to one metre above, above not below, the water table at Thorn Tree Plantation, Blackhill.

AI has given "categorical" assurances that there will not be processing plant at Straitgate - it doesn't have the water resources to do so anyway. This will therefore mean the transportation of as-dug material on public highways - for the lifetime of any quarry, which AI estimates to be 10 years or more. At Venn Ottery, this equated to an average of 110 HGV movements a day or 10-12 per hour - according to AI's own Haulage Statement, October 2010, payload 29 tonnes, gross vehicle weight 44 tonnes. How sustainable, ethical or environmental is that? And AI has still not given up hope of processing the material at Blackhill either. Of course, DCC and Natural England will obviously have something to say on that matter.

And there's another issue. AI's plans now rely on the use of third party land - namely for site access, the storage of overburden amongst the line of veteran oaks, and for advanced planting "for visual mitigation measures". AI does own the mineral rights in these fields. However, it is unclear whether AI has the rights to anything more. Advice is being sought. What can be said for certain is that no rights have been agreed from the different owners of the fields. DCC will need to assure itself of the merits of relying on a site where AI does not have surface ownership of the access route.

There are a number of other points: Grandiose plans can be made for tree planting and aftercare, yet AI's existing woodland around the site has had no management in many years; an attempt at underplanting 10 or more years ago completely failed through lack of light and ivy encroachment. AI plans bunds of earth next to A30, changing the aspect for users, for which advice will need to be sought from the Highways Agency. AI plainly accepts that the quality of the farmland will be lost, with the "long term afteruse being light agricultural grazing" - in other words, adequate for sheep and little else. And where's the silt going - back to Straitgate for restoration? Or to Rockbeare or Blackhill?

And what do the restoration plans offer to the community. Much has been said on this blog about companies giving back - leaving something worthwhile as recompense for the loss of amenity, the dust, the noise, from 10 years of quarrying and 100 HGV movements a day - something to win over local opposition. So, if it was to ever get as far as restoration, what does this community get left with? A footpath around the void. An interpretation board. We're overwhelmed.

AI's submissions to DCC

Below are the documents that Aggregate Industries has supplied to DCC for the purposes of showing that Straitgate Farm can be relied upon as a Preferred Site for the new Minerals Plan. The documents raise questions and we will make comments in due course.

Hydrological Position Statement
Overview of Landscape Proposals and Aftercare
Letter to DCC from AI

AI reports on Straitgate Farm

For the purposes of Devon's new Minerals Plan, Aggregate Industries has finally supplied DCC with two reports, a Hydrological Position Statement and an Overview of Landscape Proposals and Aftercare, to show that, in its view, Straitgate Farm is workable and that DCC can rely on it as a Preferred Site for sand and gravel extraction. DCC will send the reports to consultees for scrutiny, including the Environment Agency, Natural England and Exeter Airport. AI has sent copies of the reports to us, and we will provide an update in due course.

The hydrological report will obviously be preliminary in nature since detailed and long-term water measurements have yet to be taken, and some piezometers yet to be installed. Without such data, it is unclear how the report can be relied upon to demonstrate that private water supplies will be protected or stream flows to ancient woodland maintained.

‘development with care’

Alongside sustaining a considerable amount of local employment, [the site] also provides an opportunity to add new and improved community and tourism resources to the local area, both during mining operations as part of [the company's] ‘restoration first’ approach to its surface mining schemes and as part of the site’s final restoration. 

Our planned investment has the potential to offer so much to both local people and visitors to the area, and we are therefore announcing our intentions at the earliest possible opportunity to start a dialogue with local residents, businesses, tourism bodies and visitors, so that we can understand their views better and enable them to have a direct influence on the site’s design and the benefits it will bring to the area. 

We want [the site] to set a new benchmark for modern minerals developments, delivering significant economic input alongside substantial benefits for the local community and wildlife alike, and our absolute priority is to design a scheme that delivers tangible, long-term local and regional economic, environmental and social benefits from day one of the project.

Sorry - this is Banks Mining, not Aggregate Industries. Open cast coal mining, not sand and gravel. Are these just words? Maybe not. The company created the giant Northumberlandia ("Lady of the North") earth sculpture near Cramlington as part of its Shotton surface mine. If a quarry should transpire at Straitgate Farm, local people should expect more.