Tuesday, 24 February 2015

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?