That much is clear from DCC’s Regulation 22 Request, issued today.
Aggregate Industries' Environmental Statement had crowed:
Save for the access point, the scheme now applied for is very similar to the 2015 scheme and having been through detailed consultation with the first application, the Applicant is extremely confident that it understands and has adequately covered all the likely significant effects of the proposed development. ES Ch1 6.13
But AI's confidence was misplaced. Its application to quarry Straitgate Farm is in a mess. The company has clearly not understood or adequately covered all the likely significant effects.
Following on from the EA’s objection and the LLFA’s objection, DCC has now served the company with a Regulation 22 request for further information on 61 substantive points - ranging from bovine movements to "novel" working techniques. The number of points is quite remarkable when you consider that this is AI’s second attempt at the site, and when you consider just how many years the company has been running around trying to make this work.
Readers may remember that back in July 2015, at the same stage of the last application, a similarly long list of requests was issued. Several months later, the company was forced to pull the application.
As far as DCC is concerned, this request now 'stops the clock' on the current application until such time as the relevant information is supplied. Here are just a couple of the things that DCC wants to know:
On Transportation of material:
8.1 It is noted that current ES does not provide the information on comparative transportation distances and CO2 emissions, and the applicant is requested to explain why the previous view on the unsustainability of Hillhead Quarry as a location for processing materials from Straitgate Farm appears to have changed. Reason: Policy M12 establishes the principle of extraction at Straitgate Farm, but one of the key requirements of supporting Appendix C is that “transportation of extracted materials for processing elsewhere should meet the requirements of Objective 1 and Policy M22 for minimal transportation by road” [Objective 1 also seeks to minimise generation of greenhouse gases].
On Alternatives:
8.4 It is understood that the mobile processing plant installed at Hillhead Quarry is incapable of maintaining the product range offered by the Blackhill Plant. If the resource at Straitgate and its potential product range is economically important then can the applicant explain why this proposal is not premature until such time as there is sufficient processing capacity to deliver the most efficient use of this diminishing resource?
