Canada geese brought down US Airways Flight 1549...

...the accident dubbed "Miracle on the Hudson" and subject of the recent film "Sully".

Aggregate Industries' plans for Straitgate Farm would see quarrying directly below - just 195m below - Exeter Airport’s landing approach. Invariably there would be bodies of water. Ponding and wet grasslands would be left in perpetuity. Water attracts birds. Birds and planes don’t mix. Canada geese are one of the most dangerous species for aircraft:

...multiple bird strikes – or hitting large birds such as Canada geese – can and have caused serious accidents.

The dangers are so great that some US airports have adopted a "zero tolerance policy" for geese. It's easy to see why:

The CAA's "Safeguarding of Aerodromes Advice Note 3 Wildlife Hazards around Aerodromes" warns that geese are drawn to water and wetlands.

Blackhill Quarry is a good example. Operated by AI, Blackhill is several miles down the road from Straitgate, but still within Exeter Airport's 13km safeguarding zone. For the bodies of water that would be created by any quarrying at Straitgate, AI has a plan. Who would be responsible for implementing it?

Aggregate Industries will be responsible for the implementation of all safeguarding within the site boundaries, monitoring bird numbers and activities and ensuring Exeter Airport is informed if any significant changes to ground and habitat occur and reviewing the performance of the plan.

And when AI is not on site? Outside any campaign periods? After any quarrying has finished? For evermore? Who knows.

If there's any plan for AI's Blackhill Quarry, it's clearly not working. Here are some photos of the 300 or so Canada geese who are currently making Blackhill their home.

The accidents that don't appear in DCC's records

In light of Aggregate Industries' ludicrous plans for the B3174, this video has been reposted by Ottery Fictional Matters - for those who missed it first time around:

Back in the real world, it's fortunate that no-one was injured on the B3174 in this scene from last year:

Or in this scene from earlier this year:

And because no-one was injured in these accidents, the data does not appear in DCC's injury collision records which are used to assess the suitability or not of the Exeter Road for AI's application for Straitgate Farm. If we exclude the accident that happened only last month, here are some more accidents, over the last year or so, that don't appear in the records either:

#Devon In Ottery St Mary we have reports of an accident on Exeter Road near Birdcage Lane. [PL]

— BBC Travel SouthWest (@BBCTravelSW) December 14, 2016

#Devon In West Hill Exeter Road is blocked due to an incident around Birdcage Lane.[SG]

— BBC Travel SouthWest (@BBCTravelSW) September 9, 2016

#Devon Ottery St Mary Exeter Road is partially blocked near Birdcage Lane due to an incident.[SG]

— BBC Travel SouthWest (@BBCTravelSW) June 20, 2016

#Devon #OtteryStMary #B3174 Exeter Road we have reports of an accident around Birdcage Lane, between the hospital and #A30. [SGr]

— BBC Travel SouthWest (@BBCTravelSW) November 4, 2015

Together they add to the evidence that shows how unsuitable the B3174 is for AI's plans; DCC's most recent Road Safety Statistics Year End Report already puts the B3174 Daisymount A30 to Ottery St Mary as one of the worst performing roads in Devon.

Who’s writing Amec Foster Wheeler’s reports?

With so many private water supplies at risk from Aggregate Industries’ plans to quarry Straitgate Farm, you would expect experts in hydrogeology to assess the impact on groundwater and to supply the Environment Agency with any hydrogeological information. Up until now, with Amec Foster Wheeler acting as AI’s hydrogeology consultants, that has at least appeared to be the case.

Up until now.

Following Straitgate application delayed as EA requests more information, AI has now supplied additional clarification on "hydrogeological modelling" to the Environment Agency.

But who is the author of this report? Are we to believe it is Amec, or is it AI themselves - the beneficiary of the scheme?

The report is clearly passed off as the work of Amec, but the author and their hydrogeology qualifications are not identified. The note relates to a meeting between the EA and AI; no Amec personnel were present. The note contains various new contour maps and cross sections produced by AI, not by Amec. The commentary also seems to be an AI creation.

Why should it matter? Because information for an Environmental Statement is meant to be provided by "competent experts". The Town and Country Planning (Environmental Impact Assessment) Regulations 2017 are clear:

To ensure the completeness and quality of the Environmental Statement, the developer must ensure that it is prepared by competent experts. The Environmental Statement must be accompanied by a statement from the developer outlining the relevant expertise or qualifications of such experts.

Has AI become a competent expert in "hydrogeological modelling"? Read the report and decide. AI still claims that at PZ05, towards the middle of the site, there would be a "1.0m standoff retained between maximum working base and average summer water low", with the "summer working base coincident with MWWT 'grid'", when this simply cannot be. The Maximum Winter Water Table at PZ05 is modelled to 146m AOD. There cannot be 1m of unsaturated gravel beneath the MWWT in the summer in this area: the summer water level does not fall by 1m; 146m AOD is the base of the gravel (BSPBs). It’s a similar situation at PZ01. These are two of the six locations that have been used to map AI’s base of extraction across the site.

Furthermore, AI makes umbrella-shaped conclusions based on the two new boreholes drilled in 2016, saying that "it is likely the water level in these piezometers may never reach substantially higher levels." But again this is pure conjecture by what appears to be a hopeful geologist, rather than rigorous evidence from a qualified hydrogeologist. Water levels from these boreholes were recorded when the 2016/17 winter rainfall was just 65% of the 1981-2010 average, the driest winter for more than 20 years.

For all that, there’s nothing new in AI’s report, no new data. Just more hopeful predictions using 6 locations to map "the detailed groundwater dynamics of the site" across almost 60 acres. As we’ve said before, the seasonal working scheme for Straitgate can't work as AI describes.

Ottery Herald

Queues of over 100 vehicles from cattle crossing makes AI’s plans unworkable

Photo © Bill Boaden (cc-by-sa/2.0)

Whilst this is a scene from elsewhere in the country - it does show the impact of cows. We’ve mentioned the B3174 and the cows at Straitgate Farm before: the bovine movements and the number one thing that AI had to answer.

Aggregate Industries' plans for Straitgate Farm would remove over 100 acres of pasture. Replacement pasture would therefore be needed to maintain a viable farm, so that unquarried land could be kept in production, and so that farming could be resumed as quickly as possible post extraction - if there’s to be any hope of restoring this best and most versatile farmland. To that end:

To supplement the grazing needs of the tenant’s dairy herd it will be the intention of the applicant to provide a new dedicated route for cattle from the existing milking parlour at Straitgate Farm to the land south of Exeter Road.

In our response we wrote:

There has been no assessment of the impact of the cattle crossing on traffic and the functioning of the B3174. Around 150 cows would need to cross the main road into and out of Ottery St Mary four times a day for replacement pasture. The Transport Assessment has not assessed this, nor has it assessed it cumulatively with the additional HGVs - up to 200 a day - that the applicant proposes.

DCC’s Regulation 22 request had said that for any cattle crossing:

the impacts should be factored into the safety assessments and traffic calculations.

No calculations were forthcoming; AI wanted things dealt with post determination:

The issues raised over signage will be dealt with under the detailed design and the Stage 2 Road Safety Audit that would be necessary following any grant of permission. 1.8

It’s now clear why.

If AI doesn't want to do any calculations, we can do some for them.

We have the traffic counts for the B3174, here and here, performed by Highways England over a two week period in 2015; these were provided to the Council by objectors to replace the fictional count supplied by AI. Highways England's figures showed almost 60% more vehicles than AI had claimed.

The cattle crossing would close a 60mph stretch of the B3174 for up to 20 minutes at a time, 4 times a day, year round, over 10-12 years. Our calculations have focused on weekdays, and assumed only 15 minute closures to reflect the monitoring periods in the traffic counts. We've also assumed that the current milking times of 7am and 4.30pm, for a duration of 1.5 hours, would be maintained.

The 2015 counts obviously exclude traffic generated from the new developments in Ottery St Mary. They also exclude AI’s planned HGV numbers - up to 1 every 3 minutes.

The impact that we have calculated from the cattle crossing is therefore best case; calculations can be found here. What do we find? During the 15 minutes crossing times, over 100 vehicles can be travelling on the B3174 Exeter Road, in one direction or the other. If we assume an average queuing vehicle length of 7.5m, including gaps, this means that traffic queues could stretch to the A30 Daisymount Junction and half way to Ottery.

This obviously creates huge safety implications, as vehicles back up towards blind parts of the road.

Clearly nobody has thought this through. Or if they have, they've chosen to keep quiet. Remember, DCC was only days away from determining this application.

‘DCC’s job is to deliver Straitgate’

Aggregate Industries’ quest to quarry Straitgate Farm has been a long-running and sorry saga. Anyone hoping that its latest planning application would be decided on its merits - weighing up the multitude of conflicting issues - will be disappointed.

In fact, in the rush to make the 6 September DMC meeting, had it not been for the EA’s concerns, DCC was preparing to write its report for councillors - 10 days before the consultation had even ended.

Why DCC’s rush? Are we to believe that the 61 substantive points raised in the Council’s Reg22 request have all miraculously been resolved, together with the myriad of material issues raised by local people on traffic safety, cattle crossings and the like? No, of course not; the cumulative impact of a 4x daily cattle crossing and up to 200 additional HGVs daily on Ottery’s busiest road hasn’t even been assessed!

So why is DCC so determined? The Council says 'Development Management’s job is to deliver what’s in the Devon Minerals Plan'.

Ah yes, the Devon Minerals Plan. The Plan that was delayed for years, as the Minerals Officer bent over backwards to accommodate AI - ignoring valid arguments from hundreds of people, ignoring warnings over processing, site access, resource figures and land ownership issues. The Plan that, at the last moment, took away the 1m of unquarried material to protect peoples’ water supplies so that AI’s resource figures would stack up:

The Plan that still laughably claims:

Was a planning application to truck 1.5 million tonnes of as-dug material 23 miles away to be processed, from the "southern parts" to the "northern parts" - where 4 million tonnes of permitted reserves still lie in the ground - what the Minerals Officer, who stubbornly advocated Straitgate for the best part of 5 years, had in mind? We warned that the southern/northern logic was "a flawed and misguided proposition", and so it proved.

Although you’d never know it, Straitgate’s designation was actually downscaled in the Minerals Plan. Originally a Specific Site - where "the proposal is likely to be acceptable in planning terms" - it now forms part of Policy M12 as a Preferred Area - "where planning permission might reasonably be anticipated". What does "reasonably" mean? A fair chance, a moderate chance? Whatever it means, it’s far from certain. The Minerals Plan provides for this:

But remember, Policy M12 is just ONE of the policies in the Plan. And as DCC reminds us - in BOLD:

Why is DCC pushing one part of M12 in isolation of other policies? Perhaps DCC thinks that some policies should have more weight than others? Perhaps DCC thinks that the policy that helps the bottom line of a Swiss multinational, should have more weight than the policies to help safeguard our planet, "minimising transportation by road and generation of greenhouse gases", Objective 1, et al? Aren’t any climate alarm bells ringing at DCC yet? None at all? Because even the Minerals Plan warns us that:

Could it be that DCC’s hands are tied; that it has no choice but to push Straitgate? What therefore is the role of Development Management?

Development Management is end-to-end management of the delivery chain for sustainable development

Development Management is an integral part of the spatial planning process; it puts spatial development plans into action and seeks to achieve good design and sustainable development

And what does the NPPF have to say?

No prizes for working out the common phrase in each. Planners should work "proactively" when applicants are delivering sustainable development.

But what if applicants are NOT delivering sustainable development? How much bending over backwards with public money should the Council be doing then, for an international cement conglomerate?

Because, however you frame it, a 2.5 million mile haulage plan to a mobile processing plant further away from its target market, CANNOT be deemed sustainable development by any stretch of the imagination.

So why is DCC so focused on delivering Straitgate, smoothing the way, greasing the wheels, overlooking fineable offences and failure to give notice to people whose land is affected, overlooking the fiction and falsity, letting AI come back with report after report in an effort to make things work? Is there something we don’t know about? Is it all a stitch-up?

Every second we waste denying #climate change is stolen from the next generation who will suffer https://t.co/c9dDvoEdZz pic.twitter.com/FEqfa3aNLt

— climatehawk1 (@climatehawk1) August 7, 2017

Straitgate application delayed as EA requests more information

Aggregate Industries’ planning application to quarry Straitgate Farm was due to be determined by DCC’s Development Management Committee on 6 September 2017.

Determination has now been delayed. DCC confirmed that the Environment Agency has "requested further clarification" following a meeting with AI this week.

The EA objected in April. AI subsequently delivered yet another lengthy water report, which was supposed to address the issues raised in DCC’s Reg22 request. Plainly it didn’t.

The fact that AI still can’t get its groundwater model to stack up after all these years is telling. We recently posted on the issue, saying that "for the majority of the site - except where boreholes have actually been drilled - AI and their merry band of consultants haven’t got a clue where the water is".

No doubt, if AI had just decided to leave 1m unquarried above the maximum water table to protect drinking water supplies - like any normal quarry company - it wouldn’t be in this mess.

The next DMC meeting is scheduled for 25 October. Who knows if the company’s application will be ready by then. As we post below, water isn't AI's only problem.

So, if AI can’t use Birdcage Lane…

... without damaging other people’s property - without the necessary space to allow the unrestricted two-way flow of HGV traffic called for by DCC - what’s left?

Site access problems have dogged Aggregate Industries from the start. Click on the maps below to see the three ideas that have been proposed for Straitgate Farm so far.

Having discarded the Straitgate Farm entrance itself as being too dangerous, AI’s first idea for site access was on the west side of the site. In November 2012, residents found out what that would have been like, when they woke up to find this on their doorstep without warning. The idea was quickly discarded, for a multitude of reasons.

AI’s second idea for site access was at the northern end of the site. Numerous residents had concerns over that idea, and Hugo Swire MP met with the company to voice them. It transpired, in any case, that AI had no rights to use the land in the way it intended - something we'd warned about two years before - and the planning application that relied upon it was subsequently withdrawn.

Useful meeting with @AggregateUK. Opportunity to stress concerns that constituents have about #Straitgate development pic.twitter.com/QOzall1psY

— Hugo Swire (@HugoSwire) September 23, 2015

'If planning is eventually granted then I do feel that DCC should explore alternative entry and exit points to mitigate the disruption that this development will cause.'

AI is now on its third idea. The company's Transport Assessment - the one with the fictional traffic figures for the Exeter Road - reckoned this was an improvement on the previous idea:

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

But that was obviously without taking third party property, trees or the width of the lane into account.

If AI can’t use Birdcage Lane or land to the north, what’s left? Last year, after the first application was withdrawn, AI had looked at another option: Little Straitgate.

It was an odd decision, because Little Straitgate - 75m to the west of Birdcage Lane - 75m closer to the brow of a hill - had already been deemed too dangerous in the company's first application:

Initially two possible locations for site access at Straitgate Farm were assessed, one being in the south of the site and the other at the northern end of the site. 5.43

The southern option, onto the B3174, was dismissed early in the process on highway safety grounds. It would have been too close to existing accesses, including the access to Straitgate Farmhouse, and the vertical alignment of the highway at this point would compromise visibility. It was decided therefore to create a new access at the northern end of the site... 5.44

Nevertheless, AI prepared some access plans for Little Straitgate. This was the option that a Road Safety Audit suggested should be left turn only - not right, the way AI needed to go; the option that subsequently involved installing traffic lights on the B3174. Concerns were raised by DCC, including on visibility splays, and - after the high vis jackets meeting - the whole idea was dropped in favour of Birdcage Lane.

If AI was to revisit Little Straitgate - it would have to factor in the cows too - the ones that would need to cross the road 4 times a day to find replacement pasture - the ones that would need two more entrances onto the Exeter Road; one of which would be between the Little Straitgate and Straitgate Farm entrances, and one opposite. Would the HGVs and cows each have their own set of traffic lights?? It’s all looking very complicated. Perhaps it would be simpler if AI helicoptered the sand and gravel out.

But don’t quarry companies always find a way around these things? Not always. In June of this year, an attempt by Tarmac to reopen a quarry was blocked by councillors over road safety concerns:

My main concern is that fully-laden vehicles leaving this site slowly, entering into fast-flowing traffic, is a major problem.

I’m not quite sure that the proposals to improve the signage and cut back vegetation to improve views is the answer.

Sound familiar? Tarmac was looking at "up to 13 vehicle movements per hour" onto a 50mph road; here, it’s up to 20 per hour, onto a 60mph road, on a hill.

Two-way HGV traffic cannot work on Birdcage Lane

It's not only the damage it would cause to third party property.

You only have to take one look at Aggregate Industries' swept path drawings below to see that two-way HGV traffic cannot work on Birdcage Lane. See how AI's trucks would cut across the central white lines; see how AI's trucks could not pass each other or anything else at this point.

Whilst this may be acceptable to AI, it would obviously be less so for oncoming farm or other vehicles being faced down by 44-tonne articulated lorries. Who would reverse to let the other through? Tractor and trailer or 50-foot artic?

Without free-flowing two-way movement, and with up to one truck every 3 minutes, HGVs could even be forced to queue up towards and onto the Exeter Road.

DCC had insisted on a 6.5m wide two-way carriageway for Birdcage Lane, for the whole stretch from the B3174 junction to the site access. We've said before that it didn't look possible. The drawings below clearly show that it isn't, within the given constraints.

Meanwhile, at Uffculme, for AI's ‘inextricably linked’ application to import Straitgate material into Hillhead:

It is proposed to widen Clay Lane on its western side by between 1 to 2 metres to achieve an overall carriageway width of 7.3 metres. This will allow the safe two-way lorry movements for all mineral and waste related traffic 4.5.2

If 7.3m is proposed for safe two-way lorry movements on Clay Lane, for the import of Straitgate material, we can obviously assume that the 6m or less proposed for Birdcage Lane for the export of the same material would create unsafe lorry movements.

And while we're talking safety, see where AI's trucks would swing out beyond the carriageway, by the field entrance - exactly where children stand waiting for school buses.

AI hasn’t done enough compensation planting so it’s come up with a new wheeze

One of the marvels of biodiversity offsetting for planning consultants is being able to show that you can rip out 1.5km of ancient hedgerows, lose 6 mature oak trees, cut down 6000m2 of advance planting, not restore things for more than 10-12 years, replace natural history hundreds of years old with saplings and tree tubes - and then show a net biodiversity gain. It's like magic!

No wonder nature’s in trouble.

Aggregate Industries' Reg22 Ecology Report says:

It is recognised that ‘no net loss of biodiversity’ will not always be possible within a development red line boundary and therefore the option of Biodiversity Offsetting has been considered within the proposed development.

Based on the Phase 1 Habitat Survey, and the proposed development footprint, the application site represents 130.06 biodiversity units before development, and 183.96 after development; a net gain of 53.90 biodiversity units.

It is acknowledged that there will be a time lag between the clearance of habitats and the establishment/ development of new habitats of equal or greater value. 

But the real question is this: How can there be enough compensatory planting for dormice - if there wasn’t enough before, and 60% is now due to be removed?

UK dormice in danger of extinction as numbers plummet 72 % in 21 years - caused by Habitat Loss & #ClimateChangehttps://t.co/ZeG4R6XnJY pic.twitter.com/mIIhVvHO16

— David Henderson 🌱 (@Dodo_Tribe) June 28, 2017

AI's revised plans for Straitgate would see the removal of 1.5km of ancient hedgerows; dormice - a European Protected Species - are assumed to be in all them. AI has consistently underplayed the amount of hedgerow that would be lost and overplayed the amount of compensatory planting.

DCC’s Reg22 wanted to know:

The MPA must ensure that the application provides sufficient compensatory habitat for loss of species rich / ecologically valuable hedges and associated species.

As a dormouse licence is required from NE [Natural England] we need to be sure that the three Habitats Regulations tests will be met and that it is likely that NE will issue a licence. Please can the applicant provide information to evidence that the favourable conservation test will be met and that they believe that NE will issue a licence.

In relation to the Habitats Regulations tests, AI’s consultants argued that:

With regard to Test 3 consideration of dormouse has taken place since 2014 with supplementary planting of new woodland and hedgerows. These have developed significantly since being planted, with the latter already suitable for dormice.

However, 60% of this supplementary planting will now be removed:

6,000 m2 (0.6 ha) of advance woodland planting within the application boundary will be removed due to issues relating to Exeter Airport.

Despite that, despite the fact that dormouse numbers have plummeted 72% between 1993 and 2014; despite the fact that the PTES 'strongly objected' to the Straitgate proposal saying:

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;

despite Devon Wildlife Trust saying:

We note that the restoration proposals include the replacement of the existing hedgerow field boundaries but we believe that further consideration needs to be given to the fact that these will need many years to reach a state in which they can perform a meaningful part of the ecological network of this area;

despite all that, AI’s ecologist thinks that:

Given the above I am satisfied that NE will issue an EPSL for dormouse in relation to the Straitgate 
proposal.

Of course, working for AI he would, wouldn't he? However, who the "I" is we do not know; there is no name on the report.

Is it any wonder that dormice are going extinct?

‘Drillers were really surprised they struck water so quickly’

That's what one local was told, after Aggregate Industries’ latest round of drilling at Straitgate Farm in June this year, for one of the boreholes.

It was surprising, after such a dry winter, and in the middle of the summer too, but Aggregate Industries’ Technical note: Straitgate Farm Unsaturated Zone Infiltration Tests June 2017 confirms it.

Infiltration testing was performed in five locations. This is where "Test Hole 4" lies:

And this is what AI’s report says about "Test Hole 4":

It is possible that a hydraulic connection to the water table was achieved at this test holes due to the closeness of the water table to ground level in this area.

You can see where "Test Hole 4" is located on AI’s work of fiction below.

Those contours apparently show the difference between the maximum winter water table (MWWT) and average summer low groundwater levels. AI is using this to show it can be trusted to dig to the MWWT during the summer months without affecting surrounding drinking water supplies or wetland habitats in ancient woodland.

Essentially AI's 'model' has been derived from just 6 locations. As Dr Rutter says in her report:

This surface is only a model of reality, and may not represent actual groundwater levels across the site...

AI has extrapolated data from these 6 locations across some 60 acres and pretended that measurements can be deduced to the nearest cm: "At the nearest point to PZ01 within the excavation, difference is 1.17 m", etc, etc. Here's AI's maths:

Guesstimate (in metres) minus Wilder Guesstimate (in metres) = Who Knows (in centimetres)

Of course, it's utter nonsense; you don't need to be a mathematician to see that.

In reality, for a site this sloping, AI can’t make predictions to the nearest metre; that's why 1m is normally left above the MWWT when sensitive groundwater receptors are at risk. As Dr Rutter says again:

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.

We’ve already exposed the lie at PZ05, where the difference is supposedly and very conveniently shown as 0.99m. In reality the groundwater movement here is next to nothing - as the water record - and Amec's report shows:

Now "Test Hole 4" exposes the lie at another location too.

AI’s contours at the location of "Test Hole 4" pretend that 4m separates the MWWT and the summer groundwater levels. In AI’s world, summer water levels should be about 6.5m below ground level. However, in the land of reality, "Test Hole 4" demonstrates "the closeness of the water table to ground level in this area".

In fact, if instead of looking at average summer low groundwater levels we look at maximum summer groundwater levels (MSWT), AI’s model falls apart completely, with half of the piezometers around the site showing significantly less than a metre difference between maximum winter and summer levels. It makes a mockery of this statement:

...the working method ensures that the floor of the excavation will always have at least 1.0m of unsaturated gravels beneath. 2.4.7

It all goes to show that for the majority of the site - except where boreholes have actually been drilled - AI and their merry band of consultants haven’t got a clue where the water is.

No wonder AI kept this document back

DCC’s Reg22 wanted to know why:

Some (but not all) of the information on headwaters impacts has been reproduced in the current submission (AFW December 2016), but the information on the loss of the unsaturated zone has been mainly excluded.

The information on both the headwaters and the unsaturated zone is important and should be included so that it can be considered in relation to the current planning application.

AI has now supplied Technical note: Straitgate Farm – summary hydrogeological assessment of dry working: further clarification, AFW, June 2015, "so that the salient points can be taken into consideration".

Why did AI not include this document before? One of the salient points is this:


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.

As we all know by now, AI’s unorthodox seasonal working scheme does NOT propose to leave "a 1m freeboard over and above the highest known water level". Obviously we can now assume, by inference, that a flashier groundwater hydrograph has NOT been provided for.

AI was asked a very simple question

The applicant is requested to provide information on other sites either in their control or operated by another company where the proposed working technique is used successfully.

DCC asked this question, in its Reg22 request, because:

The MPA will wish to consider whether the proposed working technique is a "novel approach" as set out in the NPPF Paragraph: 048 Reference ID: 27-048-20140306 in respect of the requirements for guarantees on the amelioration of impacts on local water supplies should there be any technical failure. 

How telling that Aggregate Industries could not point to a single other site where its unorthodox seasonal working scheme has been tried before 8.5.

Should the 100 or so people who rely on the site for their clean and uninterrupted drinking water be delighted that they could be part of this new experiment?

Not if AI’s Reg22 response is anything to go by. AI's water consultants have changed their tune since 2015, and now claim:

By working only to the MWWT then during the summer months the water table will be lower. Therefore across the areas being worked the zone of water level fluctuation is undisturbed. This zone is at least 1m thick. 2.2.8

AI says:

The proposal to dry-dig to the MWWT and no lower at any point in the year, for the duration of the development, actually preserves between 2 and 5 metres of BSPB above the Aylesbeare Mudstone Formation. 8.5

In reality, however, there are large parts of the site that have very little or no zone of water level fluctuation to allow a 1m ‘freeboard’ between the maximum winter water table and the summer water level; Amec previously confirmed this in 2015:

PZ01 and PZ05 are located where the saturated thickness of the BSPB is at its thinnest and the hydrographs show little or no fluctuation seasonally or otherwise.

In reality, digging to the MWWT at PZ05 would preserve 0m of BSPB above the Aylesbeare Mudstone Formation. Here's the log for PZ05 - which is towards the middle of the site.

If AI can’t provide any examples of its unorthodox scheme, its architect can now at least point to some "cartoons" instead. In the minutes of a meeting with the Environment Agency:

EB to include "cartoons" showing method of working

Here are those cartoons. Locals, whose water supplies are at risk, will draw their own conclusions.