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.
