AI's latest idea?

Up to 200 44-tonne HGVs pulling into and out of this entrance every day - onto the main 60mph road into and out of Ottery. Crawling up the hill, hauling as-dug sand and gravel 8 miles to Woodbury Common. 

This was what a surveyor was working on this morning. Does that sound sensible? Or safe? Good luck to Aggregate Industries on convincing people of the merits of that scheme.

EDIT 29.1.16 It's all very well that AI may now be desperate to find some way out of this site, having failed to check its legal rights for the first idea, but lots of people are already contacting us to say that they are flabbergasted that this access point is even being considered. As locals attest, this is already a dangerous stretch of road, because of the speed and overtaking it attracts and the blind crest; fully loaded HGVs pulling out and crawling up and down this hill - up to 20 per hour - one every 3 minutes - is just asking for trouble. Here are some of the accident statistics included in AI's Transport Assessment.

Local democracy in action...

DCC councillors yesterday approved, with two votes against and one abstention, the new draft Minerals Plan, with Straitgate Farm as a Specific Site - despite huge questions hanging over deliverability. The draft Plan will now be submitted to the Secretary of State for examination. Watch the webcast to see local democracy in action; discussion on the Minerals Plan begins 33 minutes in.

From the off, the Chair made it clear that he didn't want to talk about Straitgate Farm at all: "that's a request"; "this is about the strategic document, it is not about site specific" - which seems somewhat at odds with a Minerals Plan that is allocating Straitgate as a Specific Site.

Despite that, discussions centred wholly around Straitgate. Cllr Claire Wright made an impassioned presentation, advising members of the Development Management Committee that there were "fundamental issues that cannot be ignored" - namely on water, quantities, access and processing.

DCC’s Head of Planning was having none of it. Straitgate’s "been through numerous levels of evaluation - it clearly fulfils the criteria for the Plan".

But after all these years of evaluation, when allocation as a Specific Site - where viable resources are known to exist, landowners are supportive of minerals development and the proposal is likely to be acceptable in planning terms - has been made apparently "in recognition of the degree of evidence available on its potential impacts" 5.4.9, DCC can't even tell you how this site is to be accessed, how it will be worked, how much material there is, or how it will be processed; four fundamental points that define a quarrying operation.

Specifically, on the matter of access over third party land, the Minerals Officer was asked (58 minutes in): "Were the landowner’s concerns taken into account during the consultation". After some off-mic discussion, the officer carefully answered:

The development of the Minerals Plan has taken account of views of a whole range of people including the farmer, who’s a tenant of the actual extraction site [not correct] and who owns the fields beyond. The evidence at the time from the operator or the indication from the operator was that they believed that they had access rights over this land. In the course of the planning application that’s been received since, it’s been suggested that this is not the case and we are seeking further information from the operator on that. So it’s a very fluid position.

Without site access, there is no quarry. DCC allocated this Specific Site to include the third party land without seeing any evidence that the operator had rights over such land. Click here for the whole story.

It’s been the same all along. As we wrote in our response to the Minerals Plan, "time and time again the Council has taken the operator at its unsubstantiated, unevidenced word, whilst ignoring other voices that have proved to be the more accurate". Still, the unelected officer knows best. Let’s hope we get more sense out of the Planning Inspector. The Public Inquiry has already been booked for the summer. Of course, by then Aggregate Industries’ planning applications may have already been determined.

If water from Straitgate can do this now - just think if a quarry were there

Water from one of the four watercourses originating at Straitgate has today closed the road between Ottery St Mary and West Hill. The road may be closed for several weeks. The Express and Echo writes:

A large hole has appeared on an East Devon road.

The road between Westhill and Ottery has been closed at Foxenhole Mill because of the collapsed culvert.

Police were called to the scene early this morning and on arrival highways crews were made aware.

The hole is described as 2ft by 3ft on the surface and 15ft by 10ft underneath.

EDDC Officer Reports

East Devon District Council raised objections last year to both of Aggregate Industries’ planning applications: to quarry Straitgate Farm, and to process the material 8 miles away at Blackhill Quarry.

Both planning applications have already generated so many documents and responses that it can sometimes be difficult to keep track of them all. For those following matters closely, and further to EDDC objects again, here are links to the EDDC Officer Reports, and an excerpt from the Council's Blackhill objection last month. Who, but AI, could argue with its conclusions?

East Devon District Council responded to the original submission of this proposal on 22nd July 2015 raising objections on the following issues:

Blackhill Quarry is in a sensitive location in the AONB and SSSI and after earlier extensions to its life cycle, East Devon District Council consider the adverse impacts of its retention outweigh any benefits of re-using its processing plant. The quarry should be closed and restored in quick order to prevent further harm to habitats and landscape.

Aggregate Industries have not demonstrated that alternative solutions cannot be utilised.

The road impact of taking materials first from Straitgate to Blackhill, then from Blackhill to the marketplace, is severely adverse.

Under Reg 22 of the EIA Regulations, the applicant has submitted revisions. Of particular interest to East Devon District Council has been Chapter 5 that has tackled need and alternatives to processing at Blackhill.

East Devon District Council understands and accepts there is need for crushed aggregate, sand and gravel and that these quarries are of regional importance in providing materials for development growth.

Straitgate Quarry [sic] has been discounted as a location by the applicant due to noise, traffic and visual impact. Rockbeare Quarry has been discounted for various reasons including silt lagoon capacity, newts and other technical issues. Further afield, Hillhead Quarry at Uffculme has been discounted due to distance and cost.

East Devon District Council are not persuaded that any of the aforementioned processing options are less worthy or less sustainable in planning terms than transporting the 1.5 million cubic metres of material to Blackhill Quarry over 5 years and then shipping it out again to market. Like Blackhill Quarry, all of the alternatives listed have constraints that ultimately have a financial burden on the mineral processor. That burden is a fact of life in mineral production.

It is considered that all of the alternative sites are better than processing at Blackhill Quarry due to the impact on the AONB and sensitive habitats around. The impact on the AONB is wide-ranging, from the visual impact of HGVs traversing the middle of the Common on the exposed B3180, the noise and congestion they cause, the visual impact of stockpiles and the noise and disturbance of processing, particularly when witnessed on nearby public rights of way. Secondary delivery trips by aggregate HGVs spread out through local low-grade roads and residents in villages such as Woodbury are familiar with the lorry movements and the impact they have.

For these reasons, East Devon District Council consider the proposals to be at odds with both the adopted and emerging East Devon Local Plan and unsustainable development.

RECOMMENDATION

Objection raised.

Devon Minerals Plan - update

DCC’s Development Management Committee will meet on 27 January at 2.00pm, and will be asked to endorse the Pre-submission Draft Devon Minerals Plan, for submission to the Secretary of State, and for subsequent examination by a planning inspector. DCC writes:

Whilst a number of objections have been made to the Plan, it is considered that these do not raise fundamental issues of soundness, and submission of the Plan in the form that was recently consulted on is therefore warranted.

DCC's report can be found here. 

Straitgate Farm will still be put forward as a Specific Site; a site supposedly:

where viable resources are known to exist, landowners are supportive of minerals development and the proposal is likely to be acceptable in planning terms,

but, in actual fact, a site where the landowner of the proposed site access is not supportive; a site where processing relies on extending the use of an isolated factory, 8 miles away in an area designated of European importance to nature in the East Devon AONB.

It's hardly surprising then, after the voices of 370 individuals and organisations who objected to Straitgate in 2012 were completely ignored, that in 2015 - after Aggregate Industries had already submitted twin planning applications for Straitgate Farm and Blackhill Quarry, and after people had already written to the Council in response to those applications - many will have considered it futile to respond to the Minerals Plan yet again.

When you scrutinise the actual data...

'Let us quarry right down to your water table', says Aggregate Industries - after all, Amec, its consultants, have been measuring the groundwater at Straitgate for years and should know what's going on.

If that’s the plan, then some scrutiny should be applied to those groundwater figures, the ones that Amec has used to derive this 'maximum' water table - after all, it's people’s drinking water that would be at risk.

Amec has been recording groundwater levels since January 2013 for piezometers PZ01-PZ06, and since September 2013 for PZ07-PZ11. Amec says "The highest groundwater levels on record (20 February 2014) have been hand contoured and are shown in Figure 2.2" 4.2.

But check the actual data, because it's not the same as in Figure 2.2; in fact, the actual data for 20 February 2014 is almost half a metre higher on average than Figure 2.2's "February 2014 (high levels)" - see the workings and data below.

Amec recognises that "the 20 February data... does not necessarily reflect the peak groundwater level at each piezometer" and "has developed an alternative maximum groundwater level grid" such that "when compared with the 20 February 2014 levels, the new maximum water table grid indicated that across the proposed extraction area the water table grids are generally similar and within 1m of each".

In itself, this appears to be an admission by Amec that it cannot predict the maximum water table to any greater accuracy than 1m - reason enough to leave 1m unquarried above the maximum water table. 

But it gets worse, because the actual maximum groundwater level for each piezometer (data highlighted below in yellow) is over one metre higher on average than the Figure 2.2 data. No surprise that the discrepancies are in AI's favour.

Amec doesn’t have enough data to produce a maximum groundwater contour map with any degree of accuracy. Now it's clear that the data it does have is not being used properly. It's simply astonishing then that AI thinks it should be permitted to quarry right down to Amec's predicted 'maximum groundwater level' - when there are so many people dependent on the site for their drinking water, and when there are so many inaccuracies, inconsistencies, unknowns and anomalies.

But then Amec wrote its hydrogeology reports never really thinking that AI intended to quarry right down to the maximum water table - as all the documents and cross sections illustrate.

The proposed quarry at Straitgate Farm would work the mineral dry and to a proposed limit of 1m above the highest predicted water table. 3

Quarrying still the most unpopular form of development

Latest survey by Development Intelligence sees quarrying at bottom of table for third year running

OPPOSITION towards new quarries has hardened and quarrying is still the most unpopular form of development, recent research by strategy consultancy Development Intelligence has revealed. DI Tracker, an annual survey commissioned by Development Intelligence, showed that three-quarters of people would oppose a new quarry in their local area and just one in 10 would support it. The survey, carried out in late 2015, spoke to 2,005 British adults and found that twice as many people would be prepared to support fracking in their area rather than a quarry...

...reports Agg-Net - a news service for the quarrying industry.

AI truck comes off the road on Woodbury Common

There's already plenty of photo and video evidence to show why the B3180 is not suitable for Aggregate Industries’ HGVs. AI's planning application to quarry Straitgate Farm relies on using this road to haul as-dug sand and gravel, through the village of West Hill, to its isolated processing plant at Blackhill, on Woodbury Common in the East Devon AONB.

If any more evidence were needed, here’s a report of an incident involving one of AI's HGVs on the B3180 from this week's Exmouth Journal: Police called as lorry ends up in a ditch on Common road. Fortunately, no one was injured, but it could have been far worse - if, for example, it had involved a pedestrian or a cyclist. Read the article, and then read AI’s claims afresh, because the company thinks it’s fine to put up to 200 of these 44-tonne HGVs on this road each day. AI says:

the proposed B3180 is considered to be suitable as the recommended route for the transport of material from Straitgate Farm to Blackhill Quarry 4.2.1 the increased flows along [the B3180] are insignificant to cause a noticeable impact to road users 4.3 Based on the findings of this assessment it can be concluded that the proposed development will have no material adverse impact on the operation or safety of the local road network. 8.0

As with other parts of AI's planning applications, these claims are just utter nonsense.

Picture: Simon Horn

#Devon On Woodbury Common the B3180 is NOW CLEAR - the broken down lorry has been recovered [PL]

— BBC Travel SouthWest (@BBCTravelSW) January 7, 2016

‘...we are moving into a period of unknown extremes’

Watercourses originating from Straitgate pass through four communities downstream; communities that are prone to flooding. Any quarrying at Straitgate Farm must not make the situation worse, either during work or afterwards. DCC has requested that any plans make the situation better. How this could be so, with the loss of millions of gallons of groundwater storage capacity in the unsaturated layer of sand and gravel on top of the hill above these communities, remains to be seen.

The EA's flood defence scheme at Thorne Farm Way in Ottery St Mary was completed in 2012, following flooding from the Cadhay Bog watercourse in 2008 - when 6.3 inches of precipitation fell in 3 hours, a total of 7.4 inches over 27 hours. What has come out of the dreadful Christmas flooding in the North of England is that the EA says we need a "complete rethink" on UK flood preparations in the face of climate change and extreme weather events. In the Cumbria floods of 2009, 12.3 inches of rain fell in single day. In December 2015, this record was surpassed when Honister recorded 13.4 inches in the same period. In Keswick, the new £6 million flood defences built to withstand the 2009 highs were overwhelmed. The Mayor of Keswick said: "The flood defences were designed for a one in 100 year event and since it's six years since we had the last one, we were sort of surprised that we got one so soon". The EA deputy chief executive admitted: "We are in a period of known extremes and we are moving into a period of unknown extremes".

Any flood mitigation at Straitgate must therefore be more robust than that planned in 1968, when 5 inches of rain fell in one day in East Devon; downstream communities will know exactly who to blame if not. AI's plans inspire little confidence; it's clear the company hasn't fully grasped what's at stake.

Smoke and mirrors

Amec has now come back with the scope of additional work it will carry out in an effort to show why its client, Aggregate Industries, does not need to leave the 1m of unquarried material above the maximum water table to protect people’s drinking water supplies; the 1m that is typically required of other operators. Yet another report will be produced and consulted upon to support AI's planning application to quarry Straitgate Farm, this time to include a full survey of all surrounding groundwater dependents including the mediaeval fishponds at Grade I Cadhay, the results of infiltration testing of overburden, and:

Description of the plan for excavating to the maximum water table level but still maintaining a 1 m unsaturated freeboard, and justification of why the use of overburden will be suitable. The results of the infiltration testing etc. will inform this section of the Summary Report. In addition, the concepts will be illustrated by annotated sketches.

When Amec says "maintaining a 1 m unsaturated freeboard", what it really means is a summer and winter working regime, entrusting AI to only quarry down to the maximum winter water table during the summer months when groundwater levels are lower, backfilling with top soil and subsoils before groundwater levels rise in the winter. Of course, restoring just 1m of soils above the maximum water table would not normally be considered adequate to protect drinking water supplies from future land use pollutants - the infiltration testing on site this month, of back-fill against in-situ material, will check drainage rates not attenuation of nitrates. Furthermore, the estimated maximum groundwater level is unlikely to be the maximum, when it has only been derived from the last couple of years' data.

It’s interesting, because not so long ago Amec was the same set of consultants that assumed that 1m of sand and gravel was to be left unquarried:

The proposed quarry at Straitgate Farm would work the mineral dry and to a proposed limit of 1m above the highest predicted water table. 3

And made its conclusions based upon that:

In removing a proportion of the unsaturated zone including the soil layer there will be a reduction in the storage capacity/buffering and so recharge may move more quickly through the unsaturated zone. The extent to which this makes the groundwater hydrograph more “flashier” would be difficult to quantify with a high degree of certainty… Within the proposed development the establishment of a 1m freeboard over and above the highest known water level provides for this eventuality.

Amec was the same set of consultants that admitted uncertainty over where the maximum groundwater level actually was:

...there is uncertainty about how smooth the [seasonal groundwater elevation] transition is because there is no piezometer in the centre of the Site and there is the possibility for steps in the water table related to faulting 2.4 ...unmapped local faulting... 3.1 ...the two [maximum water table grids] therefore represent just two of the many possible interpretations of the data which themselves are based on an incomplete parameterization of the detailed groundwater dynamics of the site 4.2 Groundwater levels do not fluctuate evenly across the site... 4.2

But then Amec was also the same set of consultants that produced a "conceptual cross section across Straitgate Farm" , Fig 3.1, to illustrate the groundwater regime - the same sort of smoke-and-mirrors diagram that AI used in the seven suits meeting to hoodwink the EA and DCC; a cross sectional diagram showing the piezometers PZ01, PZ02, PZ03 and PZ11 where groundwater levels are recorded.

But look carefully, and in the new report too - when Amec says that "the concepts will be illustrated by annotated sketches", because there are NO piezometers running in a line across the middle of the proposed extraction area; the position of the piezometers don’t even match the corresponding section line that Amec has drawn on Fig 2.2, see below. When PZ01, PZ02, PZ03 and PZ11 all lie outside the area AI wants to quarry, it's no wonder Amec admits that there's "incomplete parameterization of the detailed groundwater dynamics of the site".

So is Amec really prepared to now make the case for AI to quarry right down to the maximum water table and forget its previous conclusions, forget about all the uncertainty over groundwater levels, forget about rigour and professional integrity? AI has put Amec in a difficult position. But that's what you can do if you are a multinational cement conglomerate - and the first set of conclusions don't suit.

EDDC objects again

Following East Devon District Council’s earlier objection to Aggregate Industries’ planning application to quarry Straitgate Farm, the Council has responded again, this time to the company's Regulation 22 response:

In light of the further information, East Devon District Council still objects to the application for the following reasons:

it has not been satisfactorily demonstrated that the proposal for processing materials from this site is sustainable having regard to the environmental sensitivity of the area;

it has not been demonstrated that the proposals for mitigating the landscape impacts of the development and for the restoration of the site are appropriate and achievable having regard to the landscape value of the site and airport safeguarding; and

concerns remain regarding flood risk and impact on the water table, particularly in relation to the potential effects on local residents.

Here is EDDC’s earlier objection to AI's plan to extend the operating period of Blackhill Quarry.