Responses to AI’s planning application

Group responses, including those from Planning and Environmental Consultant Charlie Hopkins, and Hydrogeology Expert Dr Helen Rutter, can be found here.

Considerable concerns have been raised by members of the public, whose comments can be found here. Strong objections have also been lodged by Ottery Town Council, West Hill Residents' Association, Devon Wildlife Trust, PTES and CPRE Devon. Natural England's response can be found here.

The Environment Agency's response has been deferred. Unsurprisingly, the EA has been unable to rubber-stamp Aggregate Industries' unorthodox seasonal working scheme. After 4 years of groundwater monitoring and countless reports, yet more information will be requested from water consultants Amec; indication, if any more were needed, of the sensitivity of the water environment at Straitgate, and the recklessness of AI's scheme.

As Dr Rutter says, in response to AI's application:

The only way to maintain the 1m freeboard would be to have continuous monitoring where the excavation is taking place...

The steep hydraulic gradient combined with limited monitoring, in my opinion, is likely to result in errors in the actual depth to maximum groundwater across the site.

This surface is only a model of reality, and may not represent actual groundwater levels across the site (other than where they have been measured).

Variations in the shape of the water table cannot be contoured based on the number of piezometers used in the application.

... the restored soil (and possibly overburden) will not have the same structure as the original, and will have less capacity to attenuate any contaminants infiltrating from the surface. If the soil has been stored for a prolonged length of time it may also be sterile and less able to attenuate contaminants. If intensive agriculture is re-established, then I consider that nutrients and microbes would be more likely to be transported to the water table.

Is this what would happen if AI put 172 HGVs a day on Ottery’s busiest road?

Lorry and car collide near Torr Quarry https://t.co/ZLt9jYLmTS

— SouthHamsNews (@NewsSouthHams) March 30, 2017

‘90% of material will be sold into the Exeter market travelling via the A38 and M5’

It's a small line buried in Aggregate Industries' infamous Transport Assessment. It tells us that 90% of the material that AI wants to win from Straitgate Farm, and take to Hillhead for processing, would eventually be sold into the Exeter market.

Material processed at Hillhead in Uffculme would be 9.5 miles further away from the Exeter market than it would be if it were processed locally, say at Rockbeare. At 20 tonne average loads (TA 8.10) onward distribution of 90% of the ‘1.2 million tonnes saleable’ from Straitgate would require 54,000 loads, or 108,000 HGV movements. Each movement would incur an additional 9.5 miles or 1.03 million miles in total, and an additional 183kg of PM10, 11 tonnes of NOX, 1523 of tonnes CO2, using these figures.

Add that to the 2.5 million miles and associated emissions that it would take to get the material to Hillhead in the first place, and we're now looking at about:

It's hardly surprising that NONE of this information was in AI's application, and it makes a further mockery of this statement:

The Applicant considers that the highway infrastructure improvement measures included in both planning applications [Birdcage & Clay Lane] are sufficient to outweigh the negative impact of transporting the Straitgate minerals to Hillhead Quarry for processing and, therefore, overcome the apparent conflict with Policy M22. 5.4.11 

An unambiguous message to AI and its plans, that rely on this 3rd party land

‘One of the rarest bats in western Europe’ is found at Straitgate

Research on Barbastelle #Bats continues at @EastDartmoorNNR - https://t.co/tSFdZZ5qZC #conservation pic.twitter.com/vamREr6uXg

— Natural England (@NaturalEngland) September 17, 2016

Aggregate Industries' consultants found "at least eleven bat species" 7.133 when they surveyed the Straitgate Farm site in 2013; "bat activity was concentrated along hedgerows and plantation edges" 7.202.

They also found "one of the rarest bats in western Europe".

Barbastelle is listed as Near Threatened by IUCN. It is protected under Annex II of the Habitats Directive.

Barbastellus requires a complex mosaic of habitats to support foraging, roosting and commuting behaviour… It is unknown whether the amount of habitat in the UK is sufficient to support a viable population of the species.

The Bat Report accompanying AI's application to quarry Straitgate concludes:

Of the rarer species recorded… The most significant of these rarer bats is barbastelle… the east edge of the site… consistently recorded barbastelle in June, July, September and October. In addition to species-rich hedgerows a damp ditch is present near here, habitats which may support micro-moth species which barbastelle specialise on. 4.0

It is 2km of these species-rich hedgerows - that provide commuting routes for local populations of Barbastelle and other bats - that AI plans to remove.

DCC had said in its Reg22 request to the previous application that:

Before any works begin the applicant MUST evidence that bat flight lines around the site are maintained (and any important habitat for barbastelles protected or compensated for)… habitat MUST be in place before works start.

AI responded by saying:

The highest level of barbastelle activity recorded within the site was 0.12 [registrations per hour] which equates to approximately one bat every eight hours… Therefore there is no requirement to provide compensation habitat for this species... 4.19

But the raw survey data clearly shows 0.23 rph at Location 4 in July and 0.21 rph at Location 5 in September, and in any case, the Ecology Report makes clear that "...it is impossible to accurately assess the number of bats using the survey area and surrounding locale..." 7.158.

Despite this, and despite its rarity, AI’s consultants, "tempered by professional judgment" 7.158, downplayed the importance of this species, giving Barbastelle, Greater and Lesser Horseshoe bats, a "County" Level of Value. Advice from other ecologists dispute this conclusion.

The Anabat detectors used here for static monitoring have been found inadequate at detecting horseshoe bats, as this Proof of Evidence makes clear:

Horseshoe, Bechstein’s and long-eared bats all have very quiet calls which make them difficult to detect… the types of bat detectors used by the surveyors were not high quality (see Adams et al. Do you hear what I hear? Implications of detector selection for acoustic monitoring of bats) and had very directional microphones (meaning that a horseshoe bat would need to fly towards the microphone in order to be heard)…. The static detector survey using an ANABAT detector was simply inadequate to provide useful information.

AI cannot assume therefore that "Greater horseshoe was extremely rare despite suitable habitat..." 4.0. It is likely that the site’s importance for bats has been under-reported. Barbastelle, Greater Horseshoe and Lesser Horseshoe score 32 in Table 7-8 which is of "Regional" value.

‘It’s killing us’: Christchurch residents by quarry told to wear masks...

... due to health risk. 

This article from New Zealand won't bring any comfort to those living around Straitgate Farm.

Families living by an expanding Christchurch quarry have been told to wear masks on their own properties after health officials discovered the quarry's dust posed a serious long-term health risk.

After years of complaints, two recent independent tests showed the dust was not just a nuisance but a serious long-term health risk. It contains crystalline silica, which can cause lung cancer and silicosis, an irreversible disease, over a long period. It confirmed the residents' worst fears about the dust they had been breathing for years.

Dr Kelvin Duncan, an independent microbiologist and former dean of science at the University of Canterbury, said he was alarmed when he learned about the situation and now works with the residents pro-bono.

"This quarry would not exist anywhere else in New Zealand, let alone the world, that close to a major facility like a road and residences," he said.

The quarry, run by Winstone Aggregates, was given permission in 2015 to expand onto rural zoned land. It is now within 90 metres of one house and 150m from several others.

Christchurch's city plan has no requirement for setback distances from quarries, but the Ministry for the Environment's good practice guidelines recommend a setback distance of 500m from those containing crystalline silica.

Some countries, such as India and Pakistan, insist on a 1-kilometre minimum setback.

And Aggregate Industries' plans for Straitgate?

6.2 In order to minimise any potential impact from fugitive dust, the operator will ensure that there is a minimum stand-off distance of 100 metres between the boundary of mineral extraction and the nearest receptors.

PTES ‘strongly objects’ to Straitgate development

People’s Trust for Endangered Species has strongly objected to Aggregate Industries' application to quarry Straitgate Farm, saying:

An extensive amount of important hedgerow will be destroyed. This is completely irreversible. The hedgerows are present on maps dating from the turn of the 20th century (Appendix 1) and are likely to have existed for centuries before this. Compensation planting (for that is what replanting is – not mitigation as suggested) for losses of irreplaceable habitat should be at a ratio in the region of 30 – 1. Proposed replanting and that already done falls far short of this.

This is what’s at stake

National Library of Scotland has digitised historic maps for the UK. Here's a screen shot showing Straitgate in 1888 with all its hedgerows, most of which are still around today. 

But the history goes back much further, detailed in these reports to support Aggregate Industries' planning application to quarry Straitgate Farm: Archaeology and Cultural Heritage Report and Results of Archaeological Trench Evaluation: 

Here's a few more snippets from the trench evaluation:

Including the Long Range site and Areas 2 and 6 at Straitgate it is apparent that this Iron Age open settlement extends over an area of potentially c. 10 hectares... based on the geophysics and trench results, around 12-15 further roundhouses in total might be anticipated... Three pieces of Romano-British period tile from overlying deposits and two holed slates from the large ditch in Trenches 22 and 56 may indicate a ‘Romanised’ building is present in the vicinity... new evidence for Romano-British settlement was identified, dated from the artefacts recovered to the 2nd to 3rd centuries AD, including a substantial linear ditch of 30m length, c. 5m width and over 2.2m depth.

Here's a plan showing the scale of open area excavation that would need to be carried out, should AI's scheme proceed.

What’s AI got to hide?

Since Aggregate Industries' last planning application for Straitgate Farm in 2015, a number of the documents have had a hair-cut. Here are pages 13-17 of AI's Phase 1 Habitat Survey from 2015, and the equivalent accompanying the company's new application.

Why has AI taken the knife to this document? Is it trying to save on paper? Or has AI got something to hide? Is it anything to do with "4.1.4 Potential Impact on Bats" and "4.1.5 Potential Impact on Dormouse"? Anything to do with "4.2 Outline mitigation options"? Anything to do with:

Mitigation and enhancement options will be required as part of the EPS licence application. These are likely to include:

Phased clearance of habitat over a number of years;

Retention of as much species-rich hedgerow as possible, in order to maintain ecological connectivity across the site; and

Strategic (early) planting of additional species-rich hedgerows/woodland such that the habitat is suitable for dormouse when phased vegetation removal commences.

If AI thinks its proposed mitigation plans for European Protected Species are acceptable - why did it see the need to remove this?

How much compensatory planting has AI done? Google Earth tells us

Aggregate Industries would need to grub up hedgerows at Straitgate that are hundred of years old. Its consultants accept:

the presence of dormouse within the site, a species listed on Schedule 5 of the Wildlife and Countryside Act 1981 (as amended), means that all hedgerows within the site may be classified as ‘Important.’ 7.126 

It also claims:

Clearance and extraction of the fields over a 3-phase programme would eventually remove c. 1.75 km of hedgerow 7.195

It's a huge figure, but it's wrong. Because when you measure those hedgerows on Google Earth you find that 2050m would be removed - 1018m, 509m, 234m, 194m, 99m. AI's plans also show another 40m of hedgerow breaks. At a width of 3-4m that's about 0.7ha in total.

Meanwhile, at the Jurston Farm development in Somerset some 2398m of hedgerow, or 0.5ha, is due to be lost. Dormice have been found there too. Somerset County Council's Ecologist proposed an area of compensatory planting, such that six-and-a-half hectares of woodland have already been planted to provide new habitat for dormice; some 30,000 trees. In other words, 13 times the amount to be lost, which is understandable when immature planting is replacing established hedgerows.

How much has AI planted in mitigation? Last time, it eventually came clean in a Reg22 response that "tree planting in the south is a 20m wide strip totalling 1.2ha and comprising 3000 trees" 6.6. But those trees - or 85% of them, "30% oak, 25% silver birch, 15% hawthorn, 15% field maple" - were planted in the wrong place and were meant to be moved:

...the area is higher than 135m AOD and, following the recommendations of the Civil Aviation Authority and Exeter Airport Safeguarding Team, no new trees should be planted in this area. Therefore the tree species that were planted in this area are to be transplanted... 6.12

AI now wants to keep those trees in place, maintaining them "to a maximum of 4m to avoid future use of the habitat as a rookery", but the new application has revised the planting figure down to 1ha.

1 ha of new woodland habitat was advance-planted using native stock in January 2014, and c. 170 m of new hedgerow planted. A further 220 m of new hedgerow will be planted during Phase 1 of the proposed development... The new woodland and hedgerows will be primarily managed for dormice. 7.275

But that figure is wrong as well. Updated Google Earth pictures means we can work out exactly how much was planted, and the answer is 0.76ha, a shortfall of 2,400m2 on what AI claims.

AI would have to apply to Natural England for a licence in order to destroy this bat and dormouse habitat at Straitgate Farm, and demonstrate that it could meet three statutory tests. DCC would need to address these tests when deciding whether to grant planning permission. "If it is clear or perhaps very likely that the requirements of the Directive cannot be met... then the authority should act upon that, and refuse permission".

And how on earth could DCC be confident that Natural England would award a licence for work - when 0.76ha of currently worthless habitat has been planted in mitigation for the destruction of over 2000m of ancient hedgerows?

DCC spelt out the situation in its last Regulation 22 response:

Measures to mitigate adverse landscape and visual impacts are currently too general and unrelated to where adverse effects would be perceived. The purpose and likely effectiveness of advance planting is unclear. Mitigation measures for landscape are not integrated and consistent with ecological and other environmental mitigation.

Nothing appears to have changed since then - apart from Google Earth telling us the truth at last.

On the same basis as Jurston Farm, AI would need to have planted 9ha in mitigation.

Amec’s water report has been whitewashed

Someone’s had a word with Amec. Certain sentences have mysteriously disappeared from the new water report to support Aggregate Industries' revised planning application to quarry Straitgate Farm. Amec's previous report had talked about uncertainty and steps in the water table related to faulting:

But that's gone in the new report:

The old report talked about incomplete parameterisation of the detailed groundwater dynamics of the Site.

But that's been removed too:

Amec's last report said there was likely to be other unmapped local faulting.

The new report now says may.

Clearly someone has taken a red pen to the old report and removed anything which indicates uncertainty over where the maximum groundwater level lies.

Two piezometers have now been installed in the middle of the site, but have produced less than 12 months of data, and certainly no new maximums. Possibility for steps in the water table related to unmapped local faulting will not have gone away.

It remains the case that the maximum groundwater contours across an extraction zone of more than 60 acres have been modelled from just six high water points. Last year, we asked DCC:

Since AI now intends to dig right down to the maximum water table, perhaps you could ask Amec to confirm the specific level of accuracy (in +/- m) to which their maximum groundwater contours are mapped?

DCC asked Aggregate Industries and Amec for an answer. Amec now says:

Monitoring over the exceptionally wet winters of 2013 and 2014 allow this surface to be defined with confidence. 6.2.2

But Amec still hasn't got the confidence to provide the level of accuracy (in +/- m) this surface is mapped to. It is this level that AI would quarry down to. Amec assures us that:

Groundwater levels would be lower than this elevation for the vast majority of the time 4.2.17 

Which won't sound like a maximum groundwater level to most people. Furthermore, it's very unlikely that during four years of monitoring, Amec will have captured the highest groundwater levels. It is for this reason and others that it is standard to leave at least 1m unquarried above the maximum recorded level. The EA has so far agreed. This was their last response to the Minerals Plan:

Amec says, and this is priceless:

4.1.3 In discussion with the EA they indicated that they would like to see the maintenance of a 1m unsaturated “freeboard” above the highest recorded groundwater level. AI have confirmed their willingness [NOT] to meet this requirement by adopting the following approach to the proposed method of working:

by saying:

Budleigh Salterton Pebble Beds (BSPB) will be excavated down to the elevation determined from the highest recorded winter water level.

So that:

in all circumstances except the few weeks that it will take to strip the BSPB and replace the overburden – there will be at least 1 metre of overburden above the High Winter Water Table. 5.3.6

In other words, confirming AI's willingness to NOT leave the 1m freeboard that the EA requires.

How would AI's scheme work?

Continuous groundwater level monitoring throughout the life of the quarry will ensure that this level is confirmed. 6.2

But look at the latest groundwater results - the ones that have not informed AI's application. Piezometer PZ05 failed in October 2016 and is still not active.

Amec assures local residents reliant on the site for their drinking water that:

No working down to the winter water level will be undertaken during the winter months (unless required in an emergency situation)

What an emergency situation might be, Amec does not say. To AI, running low of gravel stocks could be an emergency.

For anyone wondering what assurances there would be for restoring water supplies if problems were to occur. In 2015, the EA had said:

We therefore recommend that a Section 106 agreement is put in place prior to the commencement of the works. This would require the ‘making good’ of any derogation to an agreed list of water supplies by the provision of alternative supplies

DCC requested that AI produce a "Heads of terms of a s.106 agreement to replace private water supplies affected by workings":

This should include very clear proposals for responses to allegations of derogation of water supply, including timescales and methodology for action.

A draft Heads of Terms was provided "for discussion with DCC", set out in Item 11 here. Many local people were not happy with "If we dispute that the derogation is caused by our working we may..." etc etc.

But in this application? Nothing. There's no draft Section 106, and nothing about making good. Surely if AI's so confident that its unorthodox seasonal working scheme would not impact private water supplies, it could offer a Section 106 with all the bells and whistles? After all, what's it got to be worried about?

AI’s previous traffic consultants had different ideas altogether

After Are AI’s B3174 Exeter Road traffic count figures fictitious? and You really couldn't make this up you have to ask yourself, how did AI's latest consultants arrive at the conclusion that: 

The traffic impact assessment has been conducted using a figure of 200 movements per day and concludes that the proposed development at Straitgate Farm is acceptable in highway terms. 8.7

Because only last year, in Have AI’s new access plans run into trouble already?:

another set of consultants are set to recommend that, for safety reasons, HGVs exiting the site would be restricted to only turning left onto this fast straight road...

And before that, AI's previous consultants SLR told us how dangerous the B3174 Exeter Road would be:

The southern option, onto the B3174, was dismissed early in the process on highway safety grounds 5.44

It's no surprise those comments don't appear in AI’s new application. In fact, funnily enough, completely the reverse:

The presently proposed access is better for goods vehicle movements from Straitgate Farm than the initially proposed route. 9.29

So what made this set of consultants say it was such a good idea? When at least two other sets of consultants didn't?

Because, in reality, lumbering 44-tonne trucks turning right, across this fast road, to travel up the hill to Daisymount is obviously no better. In fact, many local people think it's downright dangerous. This recent sign on Birdcage Lane had it right. AI should have taken note.

AI intends to process Straitgate material with mobile plant. How sustainable is that?

How many, many times have we heard from Aggregate Industries representatives that mobile processing plant is not up to the job for material from the southern part of Budleigh Salterton Pebble Beds? More than we care to remember, but here we are, a new application for Straitgate Farm, with this:

New mobile processing plant is to be installed in [Hillhead Quarry] and it is this plant which would be used to process the Straitgate minerals. 3.14

Local people will remember that in 2010 for the Venn Ottery quarry application, AI justified the need to extend the life of Blackhill processing plant on Woodbury Common - instead of using the industrial site at Rockbeare - by claiming:

The option to provide fixed plant at Rockbeare has the advantage of the site being outside of the AONB. However, the Applicant considered that this would be uneconomical in terms of the investment required due to the limited permitted reserves at Venn Ottery and Marshbroadmoor [Rockbeare]. Again, if mobile plant were to be used at Rockbeare the range of materials would be less, sales reduced, and the life of Venn Ottery Quarry prolonged. 6.17 

In 2015, it was the same for the last Straitgate planning application:

The substitution of the Blackhill plant with a mobile processing plant would severely restrict the output and product range to serve market demand. 8.30

If AI's mobile processing plant is now to be used for material from Straitgate, presumably we can assume that this would again severely restrict the output and product range to serve market demand.

That’s not a very sustainable use of what is apparently such a rare and precious resource, is it?

AI secures Thames Tideway Tunnel contract

Aggregate Industries role will be to remove the 800,000 tonnes of spoil produced from the tunnelling process, to be loaded, transported via the River Thames... By using this method, it means approximately 34,000 less vehicle movements on the road network.

It’s good news that material is being transported using methods other than by road, and AI has proudly put out a press release:

Importantly our ability to ship the spoil via the River Thames means we can alleviate congestion on the roads and reduce our impact on the environment.

What a pity then that those figures are dwarfed by AI’s new plans for Straitgate Farm.

There’s no press release from AI for the 107,000 HGV movements needed to haul 1.5 million tonnes, 23 miles by road to Uffculme. In fact, AI can’t even bring itself to put the number in its planning application.

We will remove 800,000 tonnes of spoil from the western section of the @TidewayLondon project via the River Thames. https://t.co/XEwXN52PMq pic.twitter.com/aLIPy2EmZL

— Aggregate Industries (@AggregateUK) March 15, 2017

AI’s 2.5 million miles would mean ‘31 tonnes of NOx air pollution and 4,463 of these’

...based on these figures; real world emissions - as shown by dieselgate - are likely to be even higher.

You wont find these numbers, or the mileage of its haulage scheme to Uffculme, in Aggregate Industries' new planning application for Straitgate Farm. Which is funny, because:

How thoughtful and responsible is this?

AI plans to haul as-dug material to Uffculme; 20% of this would be silt - a waste product. Therefore, of the total 2.5 million miles, 20% or 500,000 miles would effectively be for waste. How sustainable is that?

How does AI square the 2.5 million miles, with the policy conflict in M22 of Devon's newly adopted Minerals Plan: "mineral development should minimise the distance that minerals are transported"?

AI's answer is by giving us road improvements. Local people here may be surprised we need them, but:

The Applicant... is proposing improvements at both ends of the route between Straitgate Farm and Hillhead Quarry. The widening of Birdcage Lane at Straitgate will provide a safe means of accessing the B3174 Exeter Road... 5.4.10 SS

The Applicant considers that the highway infrastructure improvement measures included in both planning applications are sufficient to outweigh the negative impact of transporting the Straitgate minerals to Hillhead Quarry for processing and, therefore, overcome the apparent conflict with Policy M22. 5.4.11 

You have to laugh. What world does AI live in? It's quite bizarre how AI thinks that the negative impact of air pollution and 4,463 tonnes of CO2 with an atmospheric lifetime of up to 200 years can be outweighed with some road improvements.

And it's not just that. It's acknowledged that Clay Lane at Hillhead needs improvements - to accommodate AI's trucks - but Birdcage Lane?? Well, it's been managing just fine thanks - for farmers, dog-walkers, cyclists, joggers, ramblers, horse-riders, even sheep. Up until now at least.

Perhaps AI has difficulty putting those abstract CO2 numbers into context. If so, here's an example that might help. This hydro electric system in Lyme Regis hopes to save 13 tonnes of CO2 annually. It would need to operate for 343 years to balance AI’s senseless plans.

Amazing. Processing Straitgate material at Hillhead is now ‘logical’ and ‘appropriate’

Or that’s what we're being told - in Aggregate Industries' Supporting Statement for its revised planning application to carve up another chunk of East Devon. AI claims:

The choice of Hillhead Quarry to process the Straitgate Farm minerals has been the subject of great debate... 5.5.8

In fact, Chapter 4 of the ES bizarrely claims:

Hillhead Quarry is considered to be the most appropriate and, indeed, only site available in the County for the processing of the Straitgate mineral deposit. 4.6

Not only that; AI even says that this scheme "would seem to be logical". 5.4.7

But it wasn't so very long ago that AI was fighting tooth and nail to stay at Blackhill, trying to persuade us:

It is considered that processing the Straitgate deposit at Blackhill Quarry is the only practical solution which is also the most sustainable solution. 8.40

even telling DCC that:

without the Blackhill option the Phase 1 working [at Straitgate] is unlikely to be viable

However:

Critics will, no doubt, point to the distance which the Straitgate Farm minerals will need to travel to Hillhead 5.4.8

And AI’s right, critics will point at the distance, but they won’t find that distance:

2,500,000 miles - equivalent to 100 times around the Earth

in any of AI’s documentation. It’s conspicuous by its absence. As are other numbers. Critics won’t find the total number of HGV movements, which for a 28 tonne load is a staggering:

107,142

Critics will find that "there will be 9 inbound and 9 outbound vehicle movements per hour" 8.5 but won’t find that that means:

one movement every 3 minutes 20 seconds, for a 10 hour day

Which makes a mockery of the statement:

The increase in traffic flows on the B3174 from the Straitgate Farm proposals is not deemed material. 4.5.7

And again, it wasn't very long ago that AI was making the case for using the B3180, ruling out longer alternative round-trips of 29.4 miles and 34.6 miles using the A30/M5, by saying:

The two longer routes would give rise to a substantial increase in carbon dioxide emissions from quarry-related transport, as compared to the preferred route. 5.49

A balance has to be struck between the perceived impact of road traffic on local communities in terms of noise and general disturbance, air quality and road safety, and the effects of increased transport distance on climate change factors. 5.46

AI's now wanting to do a round-trip of 46 miles, but has gone quiet on the subject of climate change.

Critics won’t find any information on the NOX pollution that AI's HGVs would belch out; nor any information on the CO2 emissions. So, let’s remind ourselves of AI’s last application again:

Critics will find that AI claims "the existing processing plant at Hillhead Quarry is... ideally located to supply these markets [in Devon, Dorset and Hampshire]"3.9.5, forgetting that the new Transport Assessment tells us that "approximately 90% of material will be sold into the Exeter market"7.5, and forgetting this from the last application:

Does AI really think it can hide all this? Does it really think people have such short memories?

You really couldn't make this up

After all the palaver over site access last time - when Aggregate Industries' planning applications were pulled because they relied on third party land for access, for which permission was sought but denied - you'd have thought the company would have been more careful this time.

But guess what? This new set of plans again relies on the use of third party land for access - for which AI has sought but not gained, nor is likely to gain, agreement.

We said that Birdcage Lane was not wide enough for AI’s plans - it turned out it isn't. D M Mason, AI’s traffic consultant - the same person with the questionable traffic counts, the same person tasked with designing the access arrangements for Birdcage Lane, the same person who assured locals that no trees or hedges would need to be removed for the site access - claims:

Adjacent to Straitgate Farm, Birdcage Lane has a carriageway width of about 2.5 metres with a verges of 1.9 metres on its west and 4.5 metres on its east side. 3.3

But there is not 4.5m of verge on the east side; there is no more than 3m.

Why is this matter critical to the whole operation?

The widening of Birdcage Lane at Straitgate will provide a safe means of accessing the B3174 Exeter Road... 5.4.10

Birdcage Lane will be widened adjacent to the site access to accommodate turning and travelling vehicles. Birdcage Lane will be widened to 6.5 metres to allow a vehicle to enter the lane from Exeter Road whilst a vehicle is waiting to leave to Exeter Road and to allow vehicles to pass. 7.8

The actual details of AI's access plans are buried in the trees report:

It is also proposed to widen a small section of Birdcage Lane from the new access to the junction to the south with the B3174 Exeter Road and to make improvements to the road junction. In order to protect the RPAs of the mature trees within G15A, the widening works has been confined to the east side of the existing carriageway and therefore it will not be necessary to remove any healthy trees larger oak specimens. However it will be necessary to remove a U category English oak (Tree H) close to the junction, on the east side of the road which will need to be removed regardless of the impact of the development works.

But, AI doesn't own the oak tree, hedgebanks and land on the east side of the existing carriageway. As things stand therefore, the company's plans CANNOT be implemented in the manner presented.

Was it too much to ask AI to have sorted all this out, confirmed in writing, before landing local people with yet another consultation?

Does anyone from AI ever sense-check this stuff?

Five years or more in preparation, not far off two years since the last application, you would have thought that Aggregate Industries' revised planning application to extract 1.5 million tonnes of as-dug sand and gravel from Straitgate Farm would have ironed out some of the gremlins by now. But no. AI claims:

This planning application addresses all those concerns raised during the first application and provides a comprehensive resubmission.

But AI can’t even make up its mind about the area of "mineral extraction"; the Supporting Statement and Chapter 3 of the Environmental Statement say 25.6ha; the Landscape and Visual Impact and Ecology Reports are convinced it's 24.6ha.

The Supporting Statement says "ECC Quarries... in 1969 [sic] had planning permission refused for mineral extraction following a public inquiry, the issue being one of prematurity", but as the EA reminded us for the Minerals Plan:

The Non Technical Summary tells us that "During operational periods, the site would be worked between the hours of 09.00 and 17.30 Monday to Friday" and that "Mineral transport will be between 07.00 and 18.00". But something’s not right, because trucks don’t load themselves for 2 hours.

The Landscape and Visual Impact Report tells us that "isolated residential properties lie in close proximity to the east of the site, such as... The Green". But try finding The Green.

The Dust Report tells us us that "recent IAQM Guidance on the Assessment of Mineral Dust Impacts for Planning, 2016... now categorises the sensitivity of residential receptors as being ‘high’". AI's new application has the access, haul road and soil storage areas in completely different locations from the last application, but the report's conclusions are just the same; in fact almost word for word identical as the last report in 2015.

AI tells us in its Supporting Statement that "The number of full time employees at the site would be three" - for a part-time operation with 2 or 3 campaigns per year.

The Hydrogeology Report claims "there are eight piezometers within the potential extraction area", when clearly there are only 4 (marked PZ on the map below), and 2 of those have less than 12 months' data.

In the Transport Assessment, AI's quarry manager tells us "of a planning application to extract circa 1.6 million tonnes of sand and gravel from Straitgate Farm". But if AI’s quarry manager can’t even get that number right in a planning application, how could you trust how far down he would dig into the aquifer supplying peoples' drinking water?

The Flooding Report tells us that "DCC have requested additional detail regarding the management of runoff generated in the ancillary service areas and new access road from Birdcage Lane", but Amec doesn't seem to know where they are, and locates them at the north of the site, not the south east corner.

And for anyone who remembers Colemanballs, here's that Transport Assessment again, which, when talking about "Access to Hillhead Quarry", comes up with:

The road safety data reviewed in Section 5 above indicates that there have been no collisions involving quarry vehicles over the five year study period, although it is acknowledged that Hillhead Quarry has been dormant over this period.