What hope is there if completely unsustainable schemes, such as the one put forward by Aggregate Industries to transport material from Hillhead to Blackhill for processing (when mobile plant could have been deployed on site), get recommended for approval?
More to the point, what hope is there for the climate or air pollution if planners back schemes where HGVs loaded with as-dug sand and gravel are required to make round trips of over 50 miles - just for processing - before any onward distribution? And where’s the corporate responsibility? It obviously means nothing when AI says:
We have long recognised the consequences of CO2 emissions and how both the manufacture of our products and their use in the built environment contribute to climate change... there is a real focus and drive to minimise the environmental impact of all we do.
But it’s not just the 52 miles for each round-trip. Under the Town and Country Planning Act, "the winning and working of minerals or the use of land for mineral-working deposits" is classed as "major development". This proposal is therefore major development in an AONB, and clearly there is public interest in protecting AONBs. The NPPF says:
Where’s the "Great weight" and "except in exceptional circumstances and where it can be demonstrated they are in the public interest" in the 'planning balance'? There are obviously no exceptional circumstances; AI's argument that the material is needed for Blackhill's restoration falls down when you consider that the 6,000 tonnes of silt generated would contribute a negligible 1.4% to the void that supposedly needs filling.
On the issue of importing nutrient-rich material, Natural England has now withdrawn their previous objection to the proposal:
On the basis of the further information supplied in the new technical note submitted with this consultation, Natural England advises that overall, we are satisfied that the proposed activity does not represent a significant risk over and above how the quarry has operated to date.
But it’s perhaps telling that Natural England also says:
Finally, it should be noted that the advice contained in this response relates to the specific set of circumstances detailed in this application and associated documents. Therefore such advice may not be appropriate in a different set of circumstances and all applications we are consulted on are assessed on their individual merits.
Indicating that whilst 40,000 tonnes might not represent a significant risk, '1.2 million tonnes' from an intensive dairy farm is another story.
The application, DCC/3816/2015, will be decided at the DMC meeting next Wednesday 20 July 2pm. The Officer's report says:
1.3 It is considered that the main material issues in the consideration of this application are whether the nature of the imported material would have significant environmental effects on the adjacent protected sites, the impact of the development on the Area of Outstanding Natural Beauty (AONB) having regard to whether the proposal is a “major” development, and the traffic and sustainability implications of hauling material to Blackhill Quarry from Houndaller (Hillhead) at Uffculme.
6.6 A number of representations have made reference to Paragraph 116 of the National Planning Policy Framework... Although Government guidance categorises all mineral development as “major”, it is questionable whether the temporary continuation of the status quo is truly a major development in terms of its impact.
7.4 A recent appeal decision in Devon has indicated that the Planning Inspectorate tend to take “major” to be a dictionary definition and whilst it is doubtful whether the “exceptional circumstances” statement provided by the applicant would have been sufficient to have supported a proposal with any greater impact, there would be no increase in the impact on the AONB from the current proposal and no extension to the life of the site. Both AONB/Landscape considerations and the continuation of the supply of minerals carry “great weight” in the NPPF but the presumption against mineral extraction in AONB’s is unclear about the weight to be given to ancillary operations which are already in existence.
The "recent appeal decision in Devon" referred to? A small scale farm-based AD facility that "would involve no more than 2 vehicles per day"; not the 88 HGV movements per day for this scheme.
The report concludes:
7.6 The very short term nature of the proposal, the fact that it would not extend the life of the Blackhill processing plant beyond the end of 2016 and would not lead to traffic levels above those already permitted, would suggest that the proposal would not have any significant adverse impact on the locality. It is therefore recommended that permission should be granted to vary the source of materials until the expiration of the current permission in December 2016 to give the applicant the time to find an alternative solution for when this permission expires.
The last line at least indicates that whilst officers recommend this application for approval, Aggregate Industries should clearly be looking for a new plant outside of the East Devon AONB from 2017 onwards.
