Following on from the Noise, dust, statutory nuisance post, why is it that residents around Straitgate are facing quarry proposals from Aggregate Industries with extraction just 70m from their homes, and construction of screening bunds even closer? Why is it that DCC is even entertaining such distances?
Take just three dust impact reports: one for an extension to Newbold Quarry in 2011, one for an extension to Kempsford Quarry in 2013, and one for Straitgate Farm in 2015 - same consultants, same author, same material, all commissioned by AI.
These might be mistaken for off-the-shelf reports; much of the text is the same - certainly for the dust mitigation measures outlined in Section 8.0 of each report - but there’s one important difference; it’s not difficult to spot:
Newbold Quarry
9.1 The potential for fugitive dust emissions from the proposed excavation of sand and gravel associated with the south and west extension at Newbold Quarry is minimal due to the inherently high moisture content of the ‘as dug’ material.
9.2 Potentially, the most dust sensitive receptors associated with the development not in the ownership of the Applicant are... there will be a minimum stand-off distance of 200 metres between the extraction area and these receptors, again minimising any impact.
Kempsford Quarry
10.1 The potential for fugitive dust emissions from the proposed excavation of sand and gravel associated with the south and west extension at Kempsford Quarry is minimal due to the inherently high moisture content of the ‘as dug’ material.
10.2 Potentially, the most dust sensitive receptors associated with the development are... there will be a minimum stand-off distance of 150 metres between the extraction area and these receptors, again minimising any impact.
Straitgate Farm
9.1 The potential for fugitive dust emissions from the proposed excavation of sand and gravel at Straitgate Farm is minimal due to the inherently high moisture content of the ‘as dug’ material.
9.2 Potentially, the most dust sensitive receptors associated with the development are...
That’s right. No mention of a minimum stand-off distance for those living around Straitgate, just:
6.4 The nearest boundary of the mineral extraction area for Phases 2B and 2C are approximately 70 metres from [homes]…
Why do the people around Straitgate warrant just 70m? Has AI put in place some special, magical dust mitigation measures? Something over and above Newbold and Kempsford? No. Just the same Section 8.0, the same wing and a prayer:
... the operator will ensure the diligent application of appropriate mitigation measures as outlined in section 8.0
Devon's new draft Minerals Plan Policy, M23: Quality of Life, says:
Peoples’ quality of life, health and amenity will be protected from the adverse effects of mineral development and transportation. Development proposals must demonstrate that the following adverse impacts will be strictly controlled or mitigated to avoid any significant nuisance being caused to dwellings and other sensitive properties close to the site or its transportation routes and other users of these routes: (a) noise and vibration, including effects on areas of tranquility; (b) dust and other reduction in air quality;(c) loss of privacy or natural light; and (d) light pollution and visual intrusion.
Following AI's original application, DCC made a Regulation 22 request:
The applicant should submit for consideration a detailed dust management and monitoring scheme for the site and for the HGV traffic moving between the site and the processing plant. Reason: The applicant should demonstrate that increased dust would not have significant adverse impacts on local residents.
So, AI bought itself another report - with suppression measures (a repeat of that Section 8.0 again) and a complaints procedure - but no-one has demonstrated that increased dust would not have significant adverse impacts on local residents; how could they, with homes just 70m away?
Let's not forget that:
Large dust particles (greater than 30 µm), which make up the greatest proportion of dust emitted from mineral workings, will largely deposit within 100m of sources. Intermediate-sized particles (10–30 µm) are likely to travel up to 200–500m. Smaller particles (less than 10 µm) which make up a small proportion of the dust emitted from most mineral workings, are only deposited slowly but may travel 1000m or more. 1A.5
Fine particles of PM10 (particles with an aerodynamic diameter of less than 10 µm) are of concern to human health as the particles can be inhaled deep into the lungs, whilst coarse dust relates to nuisance impacts. 3.5
Dust emission, dispersion patterns and impacts are difficult to predict due to the wide range of activities on site that may give rise to dust, and the lack of reliable knowledge of the dust-generation capacities for these activities, together with the influence of local meteorology and topography. 1A.6
As with noise,
There are no statutory limit values for dust deposition above which ‘nuisance’ is deemed to exist – ‘nuisance’ is a subjective concept and its perception is highly dependent upon the existing conditions and the change which has occurred. 2.3.2
the following matters constitute "statutory nuisances"... (d) any dust, steam, smell or other effluvia arising on industrial, trade or business premises and being prejudicial to health or a nuisance; (e) any accumulation or deposit which is prejudicial to health or a nuisance 79
It's another example of just how fast and loose AI is playing with Straitgate, local people and the local area: 70m standoffs from homes can be added to the long and growing list of other things AI is trying to get away with - not leaving 1m unquarried above the maximum water table to protect drinking water supplies, a water table not known with any degree of accuracy; processing 8 miles away in an AONB and an area of European importance to nature, a total of 1.2 million HGV polluting miles on an inappropriate B road; fallacious arguments for not processing at nearby Rockbeare instead; loss of 2km of ancient hedgerows with barely any appropriate mitigation planting for dormice; inaccurate resource figures; non-existent GCN survey; doctored HGV accident reporting; and more.
