The folly of Aggregate Industries' plans to quarry Straitgate Farm has finally been laid bare, following its formal request to DCC for an Environmental Impact Assessment "Scoping Opinion" - to identify the information needed for the Environmental Statement accompanying the company's planning application.
[AI] hereby gives the Council notice in writing that it intends to make a planning application, and to accompany such applications with an ES.
The scoping request "sets out the principal issues upon which SLR [AI’s consultants] considers that the EIA should specifically focus on", and is subject to consultation with statutory consultees and anybody else who wishes to comment on what AI's Environmental Statement should contain - not on the merits or impacts of the proposed development itself.
But what the scoping request also sets out is how AI intends to proceed. And this is the good news, because after eleven boreholes, two years of groundwater measurements, regular stream-flow monitoring and prolonged pre-application discussions - between AI, its consultants, DCC, the Environment Agency and Natural England - the scoping request, and therefore AI's future application, is only for a "dry working option", only for the resource lying above the water-table, only for 1.2 million tonnes of sand and gravel, only for one third of the amount DCC originally consulted upon, only for 4-5 years of working, and only for the amount that we have been saying is available all along. AI talks about a "wet working option" (extracting below the water-table) at a later stage, but plainly if that were possible the data and statutory consultees would have indicated as much by now, and the scoping request would have been for the whole resource.
That’s the good news. The bad news is that, with the diminished quantity and to save plant relocation costs, AI wants to process this as-dug material at Blackhill Quarry, 8.2 miles away along the B3180 on Woodbury Common AONB, SPA, SAC, SSSI. AI’s permission to run a sand and gravel processing factory in the middle of an internationally important conservation site runs out in 2016. AI will be seeking, in a separate application, to extend this to 2021.
Why could this bad news be good news? Because the chance of AI securing a Blackhill extension must surely be heavily weighted against it. Because it's inconceivable that DCC officers and councillors would permit this, when as far back as 1999 AI was told to get off the Common and was given millions of pounds in compensation. Because it's inconceivable that yet a further extension would be granted, after AI has already won various extensions in 2002, 2008, 2010 - continually delaying restoration of the East Devon Pebblebed Heaths. Because it's inconceivable that such an unsustainable proposal could ever be allowed - 16 mile round trips, over 100 HGV movements a day, over a million HGV CO2 polluting miles, over a 5 year period. Because it's inconceivable that such a proposal would be permitted, when similar planning applications for sites elsewhere with the same designations have been rejected.
And what if AI's application for a Blackhill extension were rejected, and there was not enough 'dry material' at Straitgate to justify moving plant to Rockbeare - what then? If AI can’t get planning permission for Straitgate and Blackhill, then all the 'southern' sites could be off the table.
What of the Scoping Request itself? What else does it tell us? Well, the report may have been "prepared by SLR Consulting Limited with all reasonable skill, care and diligence", but the three references to "Birdcage Walk" won’t impress the Queen. There are major fails too.
The omission of any reference to increased bird activity from standing water and changes in tree cover a few hundred feet beneath an international flight path won't impress Exeter Airport or the CAA.
The omission of any reference to the environmental impact of processing at Blackhill, for example importing nitrate-rich sand and gravel to an SPA, SAC, SSSI, won't impress Natural England either:
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...
People can comment on AI’s scoping request until 6 February, as detailed below.
