What is a quarry planning application, if it is not about knowing the area and depth of the proposed hole – so that environmental impacts can be properly assessed, so that the available resource is known, so that councillors can make an informed decision BEFORE they cast their vote?
Nonetheless, put yourself in Aggregate Industries’ shoes. You’ve been trying to design a workable quarry at Straitgate Farm since 2012 – trying to overcome a multitude of water constraints (vis-à-vis private water users, flooding, airport safeguarding, wetland habitats in ancient woodland, listed mediaeval fishponds), producing numerous revisions, all the time monitoring groundwater levels to determine and confirm the depth of extraction – and then in 2018 you get results you don’t like. Results that blow a hole in your consultants’ predictions. Results that necessitate the extraction area to be reduced and the extraction depth to be raised. Results that necessitate infiltration areas to be moved. Results that lead to a reduction in the available resource and the overall benefit of the application.
You face a dilemma. Do you revise your plans, so that councillors and the public can see exactly what is intended, or do you do some deal behind-closed-doors to agree to sort out all those messy details post-determination, out of the eyes of public scrutiny; the messy details that you haven’t been able to resolve in the previous six years?
Yep, you’ve guessed it. As of last month it appears that AI is taking the latter route.
Despite recent groundwater levels that put AI’s quarry plans for Straitgate Farm underwater, last month AI confirmed that it will not be submitting revised plans "following discussion with the EA and DCC". The Environment Agency also confirmed that the agency does not intend to ask for revised plans prior to determination - only "immediately before operation of the quarry begins".
What does DCC say about the matter?
I have asked AI and the EA to discuss the groundwater situation and if the final working “grid” which the EA has asked them for affects the working area then amended plans will be required.
And even though the EA confirmed in June:
The large circle cut out of the quarry area in the 1967 plan is in the area where groundwater levels are close to the ground surface. Therefore, working in part of this area may not be possible in any case
and even though the EA confirmed last month:
If the maximum water level in any of the piezometers exceeds the height of the MWWT grid then the MWWT grid shall be updated using that data
and even though groundwater levels have indeed already exceeded the Maximum Winter Water Table in 4 piezometers, DCC still maintains:
As this issue is currently being discussed between AI and the EA, the County Council would not wish to commit to anything until its resolved. If the final methodology affects the mining area then amended plans would be required but if not (and this is what the EA and AI are currently discussing) then there would be no requirement for additional plans.
Can readers smell the direction of travel?
With AI’s quarry plans up to 2.8m underwater, local people and other readers will no doubt find it simply staggering that DCC cannot already confirm that AI will be asked to amend their plans BEFORE determination – as a matter of course – knowing that groundwater levels have been recorded above the proposed base of the quarry at five different locations; knowing that groundwater levels have been recorded above the base of the proposed infiltration areas in four locations - as little as 0.5m below the ground surface - thereby negating their primary purpose of preventing flooding; knowing that the current plans could result in permanent ponding, contrary to the conditions recommended by Exeter Airport; knowing that the current plans contravene the Minerals Plan, which states that any working must be above the water table.
It is utterly ridiculous that this sort of thing – a fundamental part of any quarry design – should not be resolved BEFORE determination, when the drinking water supplies of more than 100 people are at stake. It would obviously leave DCC wide open to all sorts of challenges, with such important environmental matters not properly considered and not on the table BEFORE determination.
You have to ask, what has all the groundwater monitoring been for, if not to inform the planning application BEFORE determination? You have to also ask, having already waited years, what is the harm in having revised plans BEFORE determination? What is it that AI, the EA and DCC are so worried about? That any revised plans will make the Straitgate Farm proposition look even more nonsensical?