With all the groundwater modelling problems posted below, it’s obvious to everybody and his dog that the available resource at Straitgate Farm is no longer what is claimed, and should be recalculated. It wouldn’t be the first time. This site has a long history of surveys, boreholes and test pits, and has already seen the available resource fall to just 6% of what was first expected.
Plainly, it’s important that any quarry planning application details not only the intended depth of extraction, but also the amount of resource being clawed from the earth. This is the 'benefit' of the application that planners must 'weigh' against a proposal’s adverse environmental impacts. Without an accurate figure, how can the 'benefit' be assessed? How can the 'planning balance' be determined?
The amount also acts to cross-check an operator's intentions, that it is not planning on digging deeper than it should, that it is leaving sufficient material in place for hydrological purposes. Because not every mineral operator can be trusted, not even Aggregate Industries.
In fact, especially not AI. In 2015, the resource figure acted to cross-check the company’s intentions for Straitgate Farm, exposing the fact that the company planned to dig deeper than both DCC and the EA had understood, exposing the fact that a 1m unquarried standoff above the maximum water table would not be left in situ – despite assertions to the contrary, including to the EA.
Such assertions meant the resource figure didn’t stack up and that AI was overstating what was recoverable by at least 500,000 tonnes. When AI failed to give clarification in a Reg22 request, DCC was forced to push further "for absolute clarity":
Given the importance of this point, to you as the proposed operator, and evidently to the MPA and the EA who were both of the understanding that you had agreed to this restriction. I am now asking you to clarify in writing whether you are intending to work to the proposed levels set out in the Amec technical Note to the Policy Team and the EA (and on which their recommendation was clearly based) or whether you wish for the MPA to consider your proposal as working to the highest measured level of the winter water table without the 1m standoff. You will understand the importance of this point and the need for absolute clarity in your response as it has serious implications for the further progress of this application.
Nevertheless, nothing came from this, but seven suits did subsequently turn up at the EA. Only later, however, were we able to reveal that AI’s idea of a 1m standoff was not the 1m that the EA and DCC understood, but was in fact nothing, a big fat zero; a fact that AI hurriedly confirmed in a resource statement the following year, less than two weeks before the Examination hearings for the Devon Minerals Plan.
In 2018, AI is still intending to leave a big fat zero to protect surrounding water supplies, relying on an unorthodox seasonal working scheme – which the posts below have already shown to be flawed.
AI says its application for Straitgate is for the "extraction of up to 1.5 million tonnes of as raised sand and gravel." As raised, or as-dug, sand and gravel includes a 20% waste component, so that’s actually up to 1.2 million tonnes of finished, saleable, useful product. That same figure is quoted in the Minerals Plan.
But there’s not 1.2 million tonnes of saleable resource available to AI at Straitgate – not unless AI’s excavators go below the water table, not if any material is to be left to protect springs and water supplies, not if permanent water bodies are to be avoided.
It is one thing being loose with resource figures for a Minerals Plan, it is another thing if those same loose figures are still being wheeled out for a planning application. Especially when they’re wrong. Imagine an application for up to 1200 homes, and the builder in reality is only able to deliver less than 900 – and even those risk standing in water.
We’ve long argued that there is nowhere near the resource at Straitgate that is being claimed, but ever since ECC (AI’s predecessor) bought the farm back in 1965 with the promise of 20 million tonnes, the farm’s available resource has been on a steep downward trajectory; we posted that Straitgate has already been a disaster for AI and made comparison with You have two cows.
In more recent times, AI’s geological survey in 2011 confidently predicted 7.25 million tonnes being available, but DCC’s Minerals Plan consultation the following year cut that to 3.6 million tonnes after "the site appraisal found that there is likely to be a significant impact on the water environment (and consequently on biodiversity) if mineral extraction occurred in the eastern half of the [site]". In 2015, AI’s request for a scoping opinion was still talking about 2.8 million tonnes (above and below the water table), but that was cut to 1.66 million tonnes (above the water table, to include some overburden) by the time the planning application was submitted the same year. But even that was too much, and by the time the Minerals Plan was adopted there was "Up to 1.2 million tonnes from extraction above the protected water table": 17% of what AI put forward in 2011; 6% of what was thought possible in 1965.
But the decline hasn’t stopped there. After the extraction area was reduced last year, the available saleable resource – according to AI’s own figures – fell to 1.1 million tonnes.
And after all the recent issues with groundwater modelling that amount is plainly not available now either.
How much worse can it get? Well, considering that the proposed extraction area will have to be reduced again and the proposed quarry floor will also have to be raised, AI is now looking at less than a million tonnes in total; arguably less, ironically, than DCC belatedly accepted in 2016:
Given that Aggregate Industries has stated the quantity by which their original resource figure would be reduced by compliance with the requirements of Table C.4 of the Plan, I consider that it would improve clarity of the Plan if the currently-modified reference to “Up to 1.2 million tonnes” be replaced by “Approximately 0.9 million tonnes”.
But that prompted AI to rush out the resource statement referred to above, talking about PERC Standards being "rigorously applied", and DCC backtracked, rolled-over, and removed the 1m buffer to protect people’s water supplies in the process:
People will rightly question whether AI's scheme at Straitgate is still financially worthwhile. Even back at the 1968 public enquiry, ECC was making the case that:
... for financial reasons it is necessary that approval should be obtained for large sites... only large projects could carry the cost of restoration...
... no aggregates operator would consider (for example) trying to develop a sand and gravel deposit of less than one million tonnes
But AI obviously lives in an alternative economic world. It must do, if it not only thinks it can still make a go of a sub-million tonne site with its colourful variety of constraints, but that it can also stomach the costs of hauling the winnings a 46 mile round-trip for processing – some 2.5 million miles in all. Of course, when AI pulled the last application for Straitgate, and dreamt up this bonkers plan, diesel was sitting at £1/litre; now it’s 25% higher, and the construction industry has hit the skids. But hey, that’s life.
The NPPF says that, when determining planning applications, local planning authorities should:
give great weight to the benefits of the mineral extraction
but also:
ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety...
So what amount of material would outweigh the adverse environmental impacts of carving up an East Devon farm? Obviously, even with great weight, 1 tonne of minerals would not have enough benefit; neither would 10,000 tonnes. So what amount would? Councillors eventually determining this application, and local people bearing the brunt of AI’s plans, have a right to know.
Clearly, therefore, and to act as a cross-check of the company's true intentions, AI needs to produce a revised resource statement – since its application for Straitgate Farm and associated 'benefit' is not what it was, and is not what is claimed.
