It’s common sense to assume that high fertility soils from a dairy farm would not be compatible with the restoration of low fertility heathland on Woodbury Common SAC SPA SSSI.
The proposal to add the silt washed from the ‘as dug’ quarried material from Straitgate into the lagoons at Blackhill requires further detailed investigation and analysis. The designated heathland communities surrounding Blackhill quarry are nutrient poor and an increase in available nitrogen as it leaches from the lagoons could result in a change in the vegetation composition of parts of the site and affect the composition of any regeneration that may happen as the quarry site is restored. We advise that there may be an increase in nitrogen and other soil nutrients due to the land at Straitgate being farmed as a dairy enterprise. [our emphasis]
In Aggregate Industries' Regulation 22 response, there is no detailed investigation or analysis. AI says:
Any nutrients added to the surface as part of the dairy management practices would be unlikely to infiltrate through the top 1m of slowly permeable soil material to accumulate in quantities in the overburden and mineral resource that will be taken to Blackhill Quarry for processing. 2.12
There is therefore little evidence to suggest that the mineral and overburden that would be transported to Blackhill Quarry for processing would contain significant quantities of nutrients that might potentially affect the integrity of the surrounding habitats. 2.14
Slowly permeable or not (and remember, AI's drainage scheme "is feasible because of the highly permeable geology at the site" 3.40) Straitgate has been farmed for hundreds of years; slowly doesn't enter the equation. The fact is, AI has no idea by how much or by how far nutrients have permeated over this time, into the overburden and minerals it wants to work, and admits elsewhere in its response:
The pH and nutrient status of the existing soils is currently unknown, although productive farming is an established activity on the site and it is assumed that regular fertiliser applications and/or other husbandry will have sought to increase fertility. 5.33
Furthermore, in the original application, AMEC reported that at Straitgate:
All water samples showed elevated nitrate (NO3) concentrations ranging between 18 to 46 mg/l ...[one] showed nitrate concentrations greater than the UK threshold p18
Plainly therefore, AI has NO evidence to suggest that Straitgate's soils would not affect the integrity of a site of European importance to nature; its plans rely on a wing and a prayer.
