Monday, 9 March 2015


People will take one look at Aggregate Industries’ Straitgate Farm - B3180 - Woodbury Common scheme and think is this really the best that the company can come up with - for itself, for Devon, or for the environment? Because, even from a dispassionate standpoint, it really doesn’t look like it.

AI, and its consultants SLR, will have to address why the company has chosen this way of doing things, and not any of the less environmentally damaging alternatives, in its Environmental Statement. As a minimum, AI will need to supply:
An outline of the main alternatives studied by the applicant or appellant and an indication of the main reasons for the choice made, taking into account the environmental effects.
Good practice will look for more, says the Institute of Environmental Management & Assessment.

How important is it that planning applicants - whether for an environmentally sensitive potential quarry site, for a B-road haulage route or for a processing plant in an area of European importance to nature - thoroughly investigate the alternatives? Sometimes it can be very important.

Overall, there is insufficient convincing evidence to support the conclusions drawn in relation to alternative locations to clearly demonstrate that the proposed site is the most suitable, deliverable and available option for the [Liquid Sludge Import Centre]
Or take AI and its plans for a concrete plant opposite The O2 in London that were rejected because the planning inspector was critical of the apparent failure of the company to consider "alternative layouts and arrangements of structures" that would be less harmful to the surroundings.

The MPA would also strongly advise the applicant that the alternatives section of the ES should consider processing at sites other than Blackhill as the MPA has already advised AI that permission for processing of material from Straitgate at this location raises significant policy and environmental concerns. 
The relative environmental impacts of known alternative means of providing the aggregate supply should be considered including processing materials at Rockbeare and sourcing material from existing consented supplies within the eastern Devon area as advised by the NPPF. 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 therefore 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.
What alternatives are there? Well, apart from using the secondary aggregate littering the county, AI could fully work out and restore its existing local sites for a start. There are still 4 million tonnes of sand and gravel with permission at Houndaller near Hillhead Quarry. AI may claim ‘it’s too sandy’, but the deposit was good enough when the company intended to move Blackhill plant to it six years ago:
Uffculme Parish Council Minutes of the Meeting held on 2 October 2008
Plant at Hillhead Quarry demolished, site closed except for storage. The current economic downturn has put movement of plant from Blackhill to Houndaller on hold
Hillhead Quarry itself still has 0.5 million tonnes. So that’s already 4.5 million tonnes, potentially 12 years worth, before even having to think about the 8 million tonnes at Penslade, a greenfield site identified by DCC in the 2012 consultation as N6/N8, to the east of Houndaller. None of these sites have the same hydrological and environmental constraints, on-site processing restrictions, or airport safeguarding issues that Straitgate has. All could deliver saleable sand and gravel to the M5 at Exeter with less total haulage-miles (using predominantly A-roads and motorway) than any Straitgate material.

So it will be interesting to see how AI argues that none of these alternatives would be more acceptable. And if AI doesn’t look properly at ALL the alternatives - for site, route and processing - local people, councillors and, if it gets to that, a planning inspector no doubt will, because hauling as-dug sand and gravel, whether 16.4 miles for Plan A or 28.8 miles for Plan B through Devon villages, to an isolated processing plant in the middle of of an AONB/SPA/SAC is patently absurd.