1.2 million HGV miles - and ‘no adverse effect’??

People were shocked when we posted that Aggregate Industries' plans to haul as-dug sand and gravel from Straitgate to Woodbury Common totalled a million miles. It now turns out to be worse than that, closer to 1.2 million (up to 200, but typically 140 movements x 4 days x 50 weeks x 5 years x 8.2 miles).

An AI Estates Manager told a local paper that the Straitgate application "is the culmination of three years of careful planning and the proposal has been subject to a thorough environmental impact assessment".

But this is the same environmental assessment that concludes that the air pollution generated from these 1.2 million HGV miles on an East Devon B-road would be "negligible"77,78  and would have "no adverse effect" on either the humans or the sensitive European-protected habitats along the route.

Naturally, AI will look to belittle its potential impact. But, as we have already posted, in one traffic survey in Exeter "HGVs make up approximately 5% of traffic flow and yet contribute more than 38% of the total NO2 emissions", and "according to the EEA, HGVs are responsible for 40-50% of nitrogen oxide (NOX) pollution from road transport in EEA member countries". Air pollution is said to be responsible for 600,000 premature deaths in Europe each year, and many other health impacts too.

AI's consultants SLR will produce their own figures, but whatever the spin, HGVs pollute - burning one litre of diesel produces 2.63kg of carbon dioxide, about 14g of NOX and 0.14g PM10. On the basis that a 44-tonne laden HGV produces 2.23kg CO2/mile, unladen 1.34kg CO2/mile, AI’s 1.2 million mile scheme would not only produce over 2000 tonnes of CO2, 2 tonnes every day, but would also put around 14 tonnes of NOX and 225kg of PM10 into the air for local people and local sensitive habitats to suffer.

And why? In 2010, AI said it was for financial reasons that it couldn’t put processing plant at nearby Rockbeare. It knows that won’t wash this time, so has come up with some new reasons - "lack of space especially for stockpiles and silt storage; and non-availability of process water". AI could employ mobile plant, or a silt press if it wanted to; in fact, Rockbeare had processing plant until 2000. But AI will say whatever it thinks is needed in order to win permission for its more profitable Blackhill extension.

But what of the longer term? What will AI do in 5 years time, when it looks to quarry other fields near Straitgate? Will it then look to move its isolated factory to an appropriate industrial location? Or will it just seek another extension on Woodbury Common as in 2002, 2008, 2010, and now 2015 - and put another 140,000 HGV movements past people's front doors, and through an AONB, SSSI, SPA, SAC? 

AI or DCC need to resolve this ludicrous situation once and for all, and the sooner the better.

One of AI's HGVs causes near miss on B3180

Another one struggles to pass an HGV on B3180 near Tipton Cross

AI's planning application - preview of non-technical summary report

Aggregate Industries’ planning applications are still not ‘live’, but the non-technical summary accompanying the Environmental Statement is embedded below, split into parts for convenience.

The application is to extract 1.66 million tonnes, including workable overburden, over a period of 5 years - 40% more than the 1.2 million tonnes AI's glossy brochure and public exhibition wanted people to believe. Up to 200 HGV movements a day would be created, trucking material along the B3180 to Blackhill.

We have put the Summary of Effects and Mitigation Measures part of the report first - local people will find many of its conclusions laughable, with the phrases No adverse effect, Negligible effect, Minor adverse effect (not significant), Slight adverse effect, littering its pages.

AI's consultants SLR consider that up to 200 extra HGV movements through West Hill "would have no significant impact on the operation and safety of the local road network, and the amenity of local residents"68. It considers that up to 200 HGV movements a day through Woodbury Common SSSI, SAC, SPA would be "negligible and the impact of the quarry development on sensitive habitats would not be significant"78; this despite the Heaths already suffering the effects of traffic pollution. Some of the statements seem so divorced from reality, you wonder about the integrity of any of it.

AI would have us believe that it can't process at Rockbeare any more "due to lack of space especially for stockpiles and silt storage; and non-availability of process water"36. Yet as recently as January, AI's Scoping Report said: "Sand and gravel which may then be potentially worked from the “wet working option” would be processed at Rockbeare". In fact, AI staff have assured us for years that they could process material at Rockbeare, 'the old block works is just sitting there waiting'.

To cap it all, AI/SLR think they can get away with saying that we should expect this sort of development:

Quarries have been worked within 2km of the Application Site and in East Devon setting a precedent for this type of development. The proposed development is appropriate given the long history of extractive industry in the area demonstrated by historic quarries recorded on the heritage record.83

Straitgate Farm - and the visual impact from East Hill AONB

Does AONB mean anything?

This is the view that visitors to East Devon's AONB currently enjoy, looking from East Hill - AONB - towards Aggregate Industries' workings at Venn Ottery - AONB - with Tipton St John in the foreground.

More delays

Aggregate Industries' planning applications to quarry Straitgate Farm and process the as-dug sand and gravel eight miles away on Woodbury Common will not now be validated and advertised until week commencing 25 May at the earliest; DCC has had to request that consultants SLR amend significant amounts of documentation and supply additional plans in the interests of clarity.

Visual impact of AI's Woodbury Common factory at Blackhill from Woodbury Castle

Utter madness - AI's derelict industrial site is 6 miles closer than Woodbury Common

Two planning applications from Aggregate Industries, one to quarry Straitgate Farm, one to process the material on Woodbury Common, are now being checked by DCC and should be uploaded here in the next few days. In summary:

Aggregate Industries wants to to quarry a greenfield site - a productive dairy farm hosting miles of ancient hedgerows, dormice, and spring water for ancient woodland and 100 people - at a time when the county already has millions of tonnes of sand and gravel with planning permission.

Aggregate Industries wants to process this material in the middle of an AONB, in a Natura 2000 site that is threatened by traffic pollution - when the company's old block works site at Rockbeare, shown below, lies empty, derelict and two miles by road from Straitgate, not eight.

It is shameful that Woodbury Common still forms part of AI’s misguided plans for Straitgate. AI should work out its existing reserves, clear up its existing mess and use its existing industrial sites - before being permitted to despoil any more of our precious farmland and internationally designated wildlife sites.

But it’s not just us saying that the alternatives must be properly assessed. Since Woodbury Common is an SPA/SAC, a Natura 2000 site, the EC Habitats Directive 92/43/EEC Article 6.4, enshrined in the Conservation of Habitats and Species Regulations 2010, has something to say about it too:

If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. 

Where the site concerned hosts a priority natural habitat type and/or a priority species the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest. 

In other words, if the planning authority decides there is no alternative to Blackhill - and plainly these photographs show otherwise - then plans, such as AI’s heavy polluting HGVs, that impact a Natura 2000 site, can only proceed for imperative reasons of overriding public interest; "projects or plans that serve only the interests of companies or individuals are not covered by the [imperative reasons of overriding public interest] test". No allowance should be made for excuses such as the one used in 2010 to justify the decision to process Venn Ottery material at Blackhill:

The option to provide fixed plant at Rockbeare has the advantage of the site being outside of the AONB. However, [AI] considered that this would be uneconomical in terms of the investment required due to the limited permitted reserves at Venn Ottery and Marshbroadmoor. [6.17]

DCC must remember that profits of a multinational cement giant are not supposed to enter the equation.

AI's planning application set in motion

Aggregate Industries has now given formal notice and details of its planning application to quarry Straitgate Farm to directly affected landowners. A public consultation period is expected in due course. We will post again when we have more information. DCC has yet to upload any details.

In the meantime, it will be Devon Minerals Local Plan 2004 that will provide the planning policy framework for assessing AI’s applications for quarrying and processing; DCC's new Minerals Plan has suffered repeated delays over a period of three years because of AI’s inability to demonstrate that quarrying Straitgate would be possible without unacceptable environmental harm.

Let's therefore look at some of the policies from the current Minerals Plan, with Straitgate Farm in mind.

First of all, and unlike Penslade at Uffculme, Straitgate Farm is NOT in the Devon Minerals Local Plan - not as an Area of Mineral Resource, not as a Mineral Consultation Area. AI’s application is therefore not in line with any development plan. It could even be argued that the resource is not important enough to be identified or safeguarded by the County. Emerging policy, that looked to make Straitgate a Preferred Site, provoked such strong opposition from local people and statutory bodies alike that it should not be relied upon as having any weight. The NPPF says "Proposed development that accords with an up-to-date Local Plan should be approved, and proposed development that conflicts should be refused unless other material considerations indicate otherwise".[12]

AI’s application immediately appears to fail against a number Devon Minerals Local Plan policies:

MP 2 Proposals for mineral development within an Area of Outstanding Natural Beauty will not be permitted if they would conflict with the objective of preserving and enhancing its natural beauty. Proposals for mineral development which would harm the natural beauty, character and special qualities of a nearby Area of Outstanding Natural Beauty or National Park will not be permitted.

MP 5 Proposals for mineral development which would conflict with the objective to preserve Listed Buildings and their settings will not be permitted.

MP 24 Proposals for aggregate mineral development at new mineral sites will not be permitted if the mineral is available: (a) at Mineral Working Areas; or, (b) as extensions to Mineral Working Areas; or, (c) as extensions to existing mineral sites. Where the mineral is unavailable at such locations, development will only be permitted if: (i) such proposals would contribute to the maintenance of the landbank identified in Policy MP 20; or, (ii) the proposal would result in a reduction of the distance aggregates are transported; or, (iii) the mineral to be worked has particular qualities which can not be met from secondary or recycled materials, or which would override the overall landbank issue; or, (iv) the proposal would reduce adverse environmental effects of existing mineral development at the Mineral Site (including the potential adverse environmental impacts of reopening inactive or dormant planning permissions); and, (v) there is no demonstrable harm to interests of acknowledged importance, having regard to any proposed mitigation or compensatory factors. 

MP 43 Proposals for mineral development will not be permitted where the generation of heavy goods vehicle movements could not be satisfactorily accommodated on the existing local highway network and/or would cause demonstrable harm to noise sensitive properties in the vicinity of the route(s), unless appropriate highway improvements can be carried out which do not cause demonstrable harm to interests of acknowledged importance. 

MP 44 Proposals for mineral development affecting the best and most versatile agricultural land (Grades 1, 2 and 3a) will not be permitted if: (i) there is land of lower agricultural quality available (providing that this does not harm features of landscape character, nature conservation or historic significance); and, (ii) in cases where an agricultural after-use is proposed, the land cannot be restored to its former, or if possible, improved condition. 

MP 52 Proposals for the importation of materials to a minerals extraction site where minerals processing takes place will be permitted where increased lorry movements to and from the site would not give rise to unacceptable impacts on the environment or on local communities and: (i) importing materials enhances the use that can be made of existing processing and/or manufacturing plant without creating excessive demands on storage capacity within the site; or, (ii) importing materials promotes the use of secondary minerals and of recycled aggregate. Conditions will be imposed to limit the duration of the permission to ensure that continued minerals processing on the site does not interfere with any programme for site restoration.

If AI’s proposal is judged acceptable against these policies, then quite frankly what is the point of a Minerals Local Plan, the Public Inquiry and all the associated expense entailed?

And if all this isn’t enough, let’s not forget Devon Minerals Core Strategy Options Consultation Paper February 2011:

5.1.4 For as long as adequate sand and gravel reserves (i.e. a minimum of seven years’ supply) continue to be present at the existing quarries, there are no grounds to allow their further extension or new quarries. However, when the remaining reserves at the existing quarries decline to the point where further resources need to be identified to maintain the county’s landbank of sand and gravel reserves, choices are available on where those new resources should be worked.