There are so many holes in AI’s story

Aggregate Industries' brochure, showing glossy pictures of four men in hi-vis clothing and how excavators could transform Straitgate Farm, is poor on clarity, poor on facts. There are so many holes in AI’s story you could drive one of its HGVs through it.

For a start, those 100 acres of green fields on the brochure's cover are the ones there now, not the ones we will be left with. But it's the words that are the most misleading:

...working in partnership with the surrounding communities every step of the way.

AI may claim that in East Devon, but in Mid Devon, at Hillhead near Uffculme, residents tell a completely different story. 

Devon will have a shortfall of sand and gravel reserves during the period of the Minerals Plan to 2031.

Perhaps - but not now, not next year, because Devon has over 8 million tonnes of reserves currently available with planning permission. At current rates of use, it may not be until 2025 that the county has less than the seven years of reserves required by the NPPF. 

We’ve provided robust evidence that Straitgate Farm can provide a strategically important and sustainable supply of aggregates…

But not enough robust evidence to satisfy statutory consultees that extraction of that supply could be performed without unacceptable environmental damage. And sustainable?? If trucking 1.2 million tonnes of a finite resource to Woodbury Common is AI’s idea of sustainable, God help us. 

The Straitgate site would be restored...

However, with the intended Phase 2 below the water table, AI can’t tell us how or when. What is clear is that it would never be restored to the "best and most versatile agricultural land" that it is today.

Advanced tree planting and new hedgerow planting has been undertaken…

But a spokesman has already confirmed that many of those trees would need to be removed for archaeological work, and the rest are in the wrong place for long-term airport safeguarding considerations. Some of the new hedgerows planted are now in the wrong place too. 

...dry working option would not affect the groundwater and surface water quantities feeding into the four streams…

Yet AI fails to say a single word about protecting drinking water supplies for the 100 people relying on surrounding wells. The Environment Agency thinks that even dry working "could potentially result in more ‘flashy’ groundwater and surface water flow, and a reduction in water resources during dry periods. This could adversely impact the numerous groundwater and spring abstractions down-gradient of the proposed quarry". 

The proposed restoration scheme offers opportunities for ecological gain over and above what currently exists through the provision of additional hedgerows and woodland planting.

Who does AI take us for? Almost two miles of ancient hedgerows would be ripped out, some up to 4m wide; they have European-protected dormice in them, a bio-indicator of species-rich habitats. Compensatory planting would take generations to come anywhere close. In any case, for airport safeguarding reasons, Exeter Airport wants no trees or hedges planted above 135m AOD, which rules out planting in most of the area AI wants to quarry. AI shows pictures of ponies grazing at Blackhill, restoration that won an award from the Quarry Products Association. AI doesn’t show pictures of its derelict and unrestored site at Hillhead, Uffculme (below).

The B3180 has been used for the transportation of locally won sand and gravel for many decades.

But not the transportation of as-dug material for decades. Material quarried at Blackhill was processed at Blackhill, material quarried at Rockbeare was processed at Rockbeare; material quarried at Marshbroadmoor was only taken to Blackhill on a campaign basis after 2008. Venn Ottery - AI's latest working - is transported 5 miles to Blackhill, and not through a village. Planning permission for Venn Ottery was granted 50 years ago. We work to different standards today, and AI should too. The numbers that are missing from AI’s story are 8.2 - the number of miles between Straitgate and Blackhill, and 100 plus - the truck movements each working day for the 5 years of Phase 1.

All things to bear in mind when speaking "to the team responsible for making it happen" at next week’s drop-in public exhibition .

What isn’t in AI's glossy brochure?

What didn't Aggregate Industries tell residents of Ottery and West Hill in its recently delivered glossy brochure? That the 1.2 million tonnes and 5 years is just the start. Don’t take our word, take DCC’s:

The way that the applicant has presented this scoping document makes it very clear that this is only the first phase of an intended project for which Phase 2 would have much greater potential impacts on the environment in terms of landscape, groundwater and biodiversity.

Maybe local people would like to ask AI or SLR representatives at next week's drop-in events to clarify this omission, and how the site would be restored after Phase 1 if the company wants to dig below the water table in Phase 2. People could also ask them why transporting sand and gravel a million miles to Woodbury Common over the next 5 years, a site of European importance to nature, in times of concern about air pollution and climate change, is morally acceptable. And when it has finished with Straitgate Farm, people could ask AI where next? What other local fields and farms will be quarried and spat out?

AI claims to have undertaken many assessments, so someone please ask why the company conveniently forgets Grade II listed 16th century Straitgate Farmhouse, when it claims "the proposed development will have no impact upon the setting of listed buildings".

Experts on groundwater will be present at the drop-in events. Ask them why the removal of 1.2 million tonnes of sand and gravel "would not result in any significant effects on the water environment”, when the Environment Agency is "concerned about the loss of aquifer storage that would occur even through dry working... [that] could adversely impact the numerous groundwater and spring abstractions down-gradient of the proposed quarry".

Ask AI how many jobs would be created? How a quarry would benefit Ottery St Mary? What AI would do to compensate local communities for the impacts it will make? Ask them lots of questions, because DCC wants SLR to report on the results of any public consultation they may carry out and how the proposal has been amended as a consequence.

DCC and statutory consultees respond to AI's scoping request

DCC's Mineral Planning Authority has issued its Scoping Opinion on what it thinks should be contained in Aggregate Industries' Environmental Statement, following responses from statutory and other consultees. The ES is an important document that will support AI's application to quarry Straitgate Farm.

In summary, it's fairly clear that AI and its consultants SLR have been found lacking. DCC highlights "fairly fundamental issues" that have not been addressed, particularly in relation to continued processing at Blackhill and talk of Phase 2 "wet working" (ie. below the water table, involving another 6 years or so beyond the 4-5 years already indicated) and considers "that the Scoping Report as submitted does not contain sufficient information about the likely impacts of the whole project...". 

All the documents can be found here and here. Some are also embedded below, with selected passages.

DCC: It is the view of the MPA that for reasons set out above and in Tables 1 and 2, that the scoping document as submitted is not sufficient to properly assess the likely impacts of the proposal as submitted.

DCC: The MPA is unable to properly assess the likely impacts of this project on the environment without the ES containing an assessment of the impacts of transportation and processing as these are direct effects associated with this project... The Scoping Document states that the scoping opinion is sought for dry working only and so if this is the case then it is not appropriate to refer to a Phase 2 of the project unless the applicant is willing to scope in the likely significant effects of such a project at this stage... It is the advice of the MPA that Phase 2 is likely to have significant Environmental Impacts and any grant of planning permission for phase 1 of dry working should not be considered by the applicant to confer any likelihood that Stage 2 would be acceptable... The scoping document does not identify the likely significant effects of transporting material to Blackhill Quarry, the requirement for settlement lagoons or the consequent need to extend the life of that site as mentioned in the scoping document... the applicant is advised that it is a part of the likely environmental impacts of the project at Straitgate and therefore these effects should be within the scope of the ES supporting the Straitgate proposal.... the MPA has already advised AI that permission for processing of material from Straitgate at this location raises significant policy and environmental concerns... applicants should also take on board the views of Exeter Airport with relation to the advance planting that has already been carried out on this site... It would be helpful if any assessment of alternatives could include a “do nothing” option as the applicant has already advised the MPA that without the Blackhill option the Phase 1 working is unlikely to be viable and so it is known that this option has been considered. The applicant [is] advised to consider the main alternatives to mitigate the likely impacts of this proposal which in the opinion of the MPA would be: (a) Sourcing material from existing permitted reserves (b) Processing the materials in a less environmentally sensitive location (c) Do nothing... The way that the applicant has presented this scoping document makes it very clear that this is only the first phase of an intended project for which Phase 2 would have much greater potential impacts on the environment in terms of landscape, groundwater and biodiversity.

Environment Agency: We are unlikely to support any proposal that derogates any protected water right or is likely to cause unacceptable detriment to any environmental feature that is dependent on groundwater. Mitigation can be considered. Irreversible harm is not likely to be supported... In addition to dewatering impacts, we are also concerned about the loss of aquifer storage that would occur even through dry working... Removal of the Pebble Beds could potentially result in more ‘flashy’ groundwater and surface water flow, and a reduction in water resources during dry periods. This could adversely impact the numerous groundwater and spring abstractions down-gradient of the proposed quarry. The report does not give any detail on any proposed mitigation measures.

Natural England: Taking account of the nature of the proposed development, in particular the additional lorry movements, Natural England considers potential for significant impacts upon European sites of conservation importance or SSSIs in the vicinity, and these potential impacts need to be assessed through the EIA... Natural England advises that the continued use of the processing plant and the potential impacts on the AONB should be fully addressed in the EIA... Our primary concern in relation to the AONB is the proposed continued use of the processing plant at Blackhill quarry, within the AONB.

Exeter Airport: The risk of bird strike from increased bird activity caused by open workings, ponding water and planting plans will need to be addressed. It will need to be proved that the bird strike risk is no more than at present... No trees or hedges must be planted to the west or south of the site. The land in this location already penetrates the OLS [obstacle limitation surfaces] and any further penetrations would be unacceptable [AI's newly planted trees are in this location]... Areas for storage of soils should not be introduced on the highest part of the site because as previously highlighted this could cause OLS penetration issues... As previously advised and until such a time as the full planning application is received, has been studied and suitable and sufficient control and mitigation measures are in place covering all the aforementioned areas, the airport maintains an objection to the proposals on the grounds of aviation safety.

Minerals Policy: This seems to ignore the substantial permitted reserves at Houndaller which would suffice for several years beyond 2016 in quantitative terms... Just because AIUK only propose dry working, it doesn’t follow that there will be no impacts [to groundwater]... it would be worth getting an EHO view on the scope for health effects from Respirable Crystalline Silica... the scoping report ignores the site’s location within a consultation zone for Exeter Airport... Alternatives – address in terms of: Other potential locations for sand and gravel including existing permitted reserves... Other aggregate resources that could meet needs – crushed rock, secondary and recycled aggregates, imports from other counties (i.e. what would happen if no more sand and gravel resources were to be permitted in Devon?) Other ways of working the site?

AI announces dates for public exhibition concerning Straitgate proposal

Some local residents have just received notification from Aggregate Industries that it will be holding two public drop-in events next week prior to submission of its planning application to quarry Straitgate Farm:

Monday 2nd March 14.00 - 18.30 British Legion, West Hill

Tuesday 3rd March 14.00 - 20.00 The Institute, Ottery St Mary

For those wanting to interrogate AI on why it thinks quarrying Straitgate Farm and trucking sand and gravel along the B3180 to Woodbury Common for years to come is a good idea, then this is the ideal opportunity to do so - albeit at very short notice. We hope that as many people as possible will be able to attend and make their feelings known.

Straitgate has already been a disaster for AI

When Straitgate Farm was bought in 1965 the 'available resource' was estimated to be 20 million tonnes. It has been falling ever since.

By the time planning permission was refused at the 1968 Public Inquiry, this amount was down to 17.15Mt, after "taking into account losses due to landscaping and to modifications to conserve water resources". By 1990, following extensive borehole surveys and losing part of the site to the new A30, it was down to 8.1Mt. By the time of DCC’s public consultation in 2012, the eastern half of the site had been 'abandoned' leaving 3.6Mt. Now, Aggregate Industries has revised that figure to 2.8Mt, and, determined to retrieve something, anything, after spending a fortune over the years on not only the site but on consultants, surveys, borehole drilling, monitoring, testing etc, the company is putting in a scoping request for just the 1.2Mt above the water table. It’s been a terrible investment by any metric.

Of course, the cynically minded might think AI has just split the resource into the two smaller amounts, above and below the water table, in an underhand ploy to increase its chance of winning further extensions at Blackhill, the thinking being that two consecutive 4-5 year extensions might stand more chance of succeeding than one of 10 years. However, what realistic prospect does AI have of extracting the material below the water table, when groundwater from Straitgate plays such a critical role to private water supplies and wetland habitats in ancient woodland, as indeed the Environment Agency recognises? AI's 1.6Mt below the water table is a stranded-asset and needs to be written off. Twenty million tonnes to 1.2Mt - only 6% of the figure first estimated in the 1960s.

Back in 1968, the planning inspector concluded:

… it may be that the review of the development plan will contain proposals for 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 is also on that basis, apart from the water supply considerations. (408.p)

He recognised the disadvantages and the water problems with Straitgate, but could rule the site out on prematurity considerations alone. The site may no longer be as premature, but with birdstrike, dormice and archaeological assets there’s now an even longer list of disadvantages.

In 1968, before any talk of supporting "the move to a low carbon future", initial processing was to be at nearby Rockbeare; now the best that AI can come up with is trucking 1.2Mt of sand and gravel 8 miles away to Woodbury Common. That’s not a plan or a quantity that’s worth destroying a farm for, that’s worth causing so much environmental damage for.

Has AI fallen into the sunk cost fallacy? Is it making irrational decisions in an effort to recover anything from its investment in Straitgate? AI proudly claims "We are pioneers of best practice in sustainability" but then admits that "transport CO2 emissions have gradually increased since we started to monitor them in 2007". Is it any wonder, with plans like Straitgate? It’s time for Holcim's bean-counters to tell AI to stop throwing good money after bad and leave the farmers to get on with farming the land, as they have done for hundreds, even thousands of years.

Never underestimate the impact of a European Protected Species

Persistent newts put the brake on a Transport Secretary's rail showpiece

It is a story of David vs Goliath if ever there was one: an 18-month battle between the newt and the minister. And – so far – the newt is winning.

Fishponds

And talking of heritage assets and settings of listed buildings, this is the setting of Grade I listed Cadhay, resplendent with mediaeval fishponds in the foreground, themselves Grade II listed. What we said in our last blog would apply equally here too. A reliable supply of spring water from Straitgate, particularly during drier periods, is critical to the functioning of these ponds.

This is what was said at the Public Inquiry in 1968:

396. Cadhay is a historic house, listed as being of historic and architectual importance, and is open to the public. One of the features is the fish ponds immediately to the south of it. They are fed by the reservoir [in Cadhay Wood] and [Cadhay Wood] stream. They are not lined and water seepage takes the whole outflow. 397. It is contended that if the present water supply to the ponds were no longer sufficient to supply them they would be lost to posterity in the way in which they have existed for centuries, which would be a wanton destruction of a valuable historic monument.

The position of the spring is indicated by our arrow on ECC’s 1967 working plans below. No doubt it was in an effort to protect this water source [53] that ECC intended to leave the surrounding area unquarried.

Aggregate Industries has made no allowance yet for this spring on any plans we have seen.

Yet more for AI to subtract from its ever decreasing resource?

In 1968, the planning inspector concluded that any loss of flow to springs and streams at Cadhay "could be made good from the Straitgate lake...". [408] Without a lake, it's not exactly clear how AI could achieve that now.

Harm to setting of listed farmhouse already means presumption in favour of refusal

There can be no argument - quarrying Straitgate Farm would substantially harm the setting of its Grade II listed farmhouse, for ever more; surrounding fields would be removed, different levels would be introduced, screening would be ineffective, farming may no longer be viable. In 1967, Aggregate Industries (then English China Clays) wanted to bulldoze the farmhouse; today it is protected in law.

Straitgate has been farmed for more than 400 years, as copies of legal papers we have confirm. The farmhouse is thought to date back to around 1580. Part of the surrounding land is also listed, and the rest is fundamental to the setting of the farmhouse and its continuation as a working Devon farm.

In the 2012 S1-S10 site appraisals, DCC wanted us to think that "there is a medium risk of harm to the listed building which sits within an historic landscape of Barton Fields, which may require the retention of a buffer area to preserve its setting", and that nothing could be a ‘showstopper’ for S7/Straitgate. Only later, when the Sustainability Appraisal looked at the matter, did it consider that "the setting of the Grade II listed Straitgate Farm would experience a significant negative impact".

Now, in 2015, Aggregate Industries proposes that:

An impact assessment will identify the significance and sensitivity of all heritage assets affected by the proposals, and includes an impact assessment to evaluate the magnitude of change and thus direct and indirect impact on heritage assets. In particular the potential impact on the setting of designated heritage assets within 2km will be considered in relation to the Landscape and Visual Impact Assessment. If mitigation can be designed to reduce the effects of potential impacts on the settings of the statutorily protected heritage assets, then a strategy will be written and (assuming its implementation as part of the permitted scheme) the reduced residual effect will be assessed in light of the mitigation.

The issue of 'heritage assets' could be very important - not just a material planning consideration.

We mentioned the Barnwell Manor Appeal Court decision last year, but we have been reminded again by CPRE of its potential implications for Straitgate Farm. This Court of Appeal judgement upheld an earlier decision overturning permission for wind turbines in the setting of various heritage assets. CPRE, who have made representations to DCC regarding Straitgate in the past, wrote:

It is being treated as a landmark decision and is frequently referred to in subsequent planning decisions/appeals.

The importance is that it highlights the significance of the setting of a heritage asset, i.e. a listed building such as Straitgate Farmhouse. The setting includes not only views from the heritage asset, but views of the asset and its surroundings - anywhere that you get a view of the heritage asset.

The emphasis is on S66 Listed Buildings Act (1990) and the "special regard to the desirability of preserving the building or its setting". This statutory duty outweighs any policies (such as the NPPF), and as the Listed Buildings Act is worded more strongly than subsequent policies, it is helpful.

Harm to the listed farmhouse's setting would be substantial; yet, even if it were not, the judgement says:

It does not follow that if the harm to such heritage assets is found to be less than substantial, the balancing exercise referred to in policies HE9.4 and HE10.1 should ignore the overarching statutory duty imposed by section 66(1), which properly understood (see Bath, South Somerset and Heatherington) requires considerable weight to be given by decision-makers to the desirability of preserving the setting of all listed buildings, including Grade II listed buildings.

That consideration "can outweigh even considerable planning benefits such as, in this case, temporary (25 year) generation of zero carbon renewable energy". As the Planning Resource article, Pickles prioritises heritage in wind turbine decisions, puts it:

Judges ruled that once the decision-maker finds some harm to a heritage asset, that harm should be given "considerable weight", creating a "strong presumption" against the grant of planning permission.

In other words, there is a presumption in favour of refusal if harm is present.

The onus will be on AI to demonstrate that sufficiently powerful material considerations exist to justify such harm. For the decision-maker, this is not just "a simple balancing exercise but whether there is justification for overriding the presumption in favour of preservation"; preserving the setting is not a "mere material consideration to which (he) can simply attach the weight (he) sees fit in (his) judgement".

AI will also have to demonstrate that "there is no clear alternative which would generate equally powerful public benefits". If you think of AI’s extensive mineral rights in the region, covering thousands of acres, that might not be so easy; because of course there are sand and gravel deposits in other locations that wouldn’t cause as much harm, that would generate 'equally powerful benefits'.

WHRA's response to AI's scoping request

"This response has been prepared by West Hill Residents’ Association..."

Cllr Wright's response to AI’s scoping request

Response to scoping exercise for controversial plans to quarry at Straitgate Farm, Ottery St Mary

Why should local people believe AI this time?

Aggregate Industries has said lots of things over the years. It nows tells us, in its Scoping Request, that:

Subject to planning consent, it is therefore proposed that mineral processing from Straitgate Farm would take place initially at Blackhill Quarry for a period of approximately 4-5 years until the end of 2021. Sand and gravel which may then be potentially worked from the “wet working option” would be processed at Rockbeare.

Blackhill, of course, was meant to be restored years ago. It’s now an isolated sand and gravel processing factory sitting in an AONB, adjacent to areas of European importance to nature, 8 miles from Straitgate. AI’s unsustainable plans would generate a million HGV miles on Devon’s roads over 5 years.

Can we take AI’s new plans at face value, or should we instead read:

We have no intention of processing at Rockbeare. Holcim, our Swiss paymasters, won’t expense the move. If we did ever win permission for “wet working” at Straitgate, we would apply to extend permission for Blackhill again. DCC has given permission before, and before, and before, and we expect them to do so indefinitely.

Are we being disingenuous? Let’s see what Aggregate Industries has told people in the past:

2001, Blackhill site visit, considering planning permission for working Thorn Tree Plantation:

…[Blackhill Quarry] would close completely after the application area was excavated, because the quarry site is limited by the Special Protection Area, candidate Special Area of Conservation and other landscape designations.

2008, Supporting Statement, Blackhill Quarry, Importation of material from Marshbroadmoor:

It is estimated that winning and working of mineral within the Thorntree area will be completed in late 2009. At this point, the processing plant will be dismantled and removed from site, leaving only the weighbridge and stock piles operation whilst stock is depleted.

2010, Planning Application, Blackhill Quarry, Importation of material from Venn Ottery:

3.6.1 It is anticipated that importation and processing operations will take place over a period of approximately 5-6 years based upon predicted sales… Upon cessation of processing operations it is anticipated that final restoration would be completed within 12 to 18 months.

Whilst it was making claims about Blackhill, AI was also making claims about Rockbeare. It may not want to use Rockbeare for processing Straitgate material now, but in 2003 it was a different story:

It is this Company’s view that there is an inextricable link between Straitgate Farm and the Rockbeare Minerals Working Area... It is the Company’s intention to transfer [Blackhill] plant to Rockbeare as soon as working is completed at Blackhill... Working the reserve at Straitgate Farm initially and possibly wholly through our existing mineral site at Rockbeare we believe is both efficient and has environmental benefits.

AI is in the business of winning permissions. It will say whatever it thinks it needs to, as demonstrated above, and local people will rightly assign little weight to any claims it makes about the future.

The truth is, if AI had moved to Rockbeare when quarrying at Thorn Tree Plantation had finished, and had not been so profit-hungry, so short-sighted, it could have used the site to process both Venn Ottery and Marshbroadmoor material, covering moving costs, saving hundreds of thousands of polluting miles on Devon roads, and now be in the right place should it win Straitgate. That it didn’t is the company’s problem, and not one for which local people or Woodbury Common should now pay the price.

Surely the NPPF must have something to say on unsustainable proposals like AI's?

As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport.

As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport.

As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport.

It's a claim Aggregate Industries keeps wheeling out. Perhaps if it says it enough it might act like it too...

And not push million-mile HGV proposals onto local communities and European-protected sites. It's one thing ruining a perfectly viable farm and risking water supplies for 100 people, but it’s another thing continuing to blight the East Devon Pebblebed Heaths.

It is staggering that AI is still kicking around this ridiculous, unsustainable and polluting plan - to transport Straitgate material all the way to Woodbury Common for processing - when it owns an alternative site just 1/4 of the distance away at Rockbeare; an industrial site already sitting empty; a site that would save more than 750,000 HGV miles on Devon roads over 5 years; a site 0.5 miles from the strategic road network, for sales distribution, not 6 miles as at Blackhill; a site that’s apparently good enough for AI's improbable 'Stage 2' plans for Straitgate, and that therefore must be good enough for 'Stage 1' too.

How many other sand and gravel operations can there be in the UK, where 8 miles separate quarry and processing plant? We haven’t come across one yet. The reason being that transport costs normally limit the economic supply radius of low margin aggregate to 30 miles or so; AI's plans reduce that by 16 miles.

If AI can't do the right thing, what does the NPPF say on the subject - could anyone pretend that digging out Straitgate and transporting the spoil 1,000,000 miles for processing is sustainable development? Yes, if they could demonstrate that the economic benefits outweigh the social and environmental harm - but the issues page clearly shows that won't be easy. But what exactly is sustainable development? We have written about this before, but it comes back to what’s written on page 2 of the NPPF:

Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy Securing the Future set out five ‘guiding principles’ of sustainable development: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.

The NPPF states that "to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system" [8], but of course the NPPF is open to interpretation, particularly because "the policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development in England means in practice", which is why many argue that it has done nothing to protect us from unsustainable development. But election time is coming, and different noises are coming out of the Government:

the Government are committed to doing far more to publicise those recent cases widely, to provide reassurance that unsustainable development should be resisted

And the Communities and Local Government Select Committee has now recommended:

that the Government remove from the NPPF the statement that the policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development means in practice. The definition on page 2 of the NPPF needs to stand on its own. [13]

In the meantime, let's highlight two very salient parts of the NPPF that are relevant here:

Firstly, on the issue of Meeting the challenge of climate change, flooding and coastal change, the NPPF says: "Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions... This is central to the economic, social and environmental dimensions of sustainable development [93]. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change... in line with the objectives and provisions of the Climate Change Act 2008" [94].

In other words, planning must be in accordance with the Climate Change Act, whereby "it is the duty of the Secretary of State to ensure that the net UK carbon account for the year 2050 is at least 80% lower than the 1990 baseline", and that’s not going to happen by allowing proposals like AI’s.

The Committee on Climate Change was tasked by the Government to provide advice on How local authorities can reduce emissions and manage climate risk. One of the key messages is: "It is particularly important that local authorities use their plan making and development management control functions to... reduce transport emissions...".

Secondly, on the issue of Promoting sustainable transport, the NPPF says: "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion [30]. Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised..." [34]. The NPPF has more on this, but the Campaign for Better Transport has scrutinised the document far better than we ever could, and produced the very relevant Sustainable transport and the NPPF - a guide for local councils and communities.

Looking beyond the NPPF, there’s also the moral issue in all this, because continued processing on Woodbury Common is so demonstrably wrong, on so many fronts. If AI can’t be trusted to do the right thing now - to minimise the impact on local people, the East Devon Pebblebed Heaths, or the planet - how could it be trusted to do the right things if it were to actually win permission for Straitgate?