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.
