This week, there was more correspondence from the Environment Agency in relation to Aggregate Industries' planning application to quarry Straitgate Farm, this time in response to a planning lawyer saying the EA's position statement was ‘insufficient to enable DCC to determine Straitgate application lawfully’. The EA said it was all a mixup:
With regard to the position statement we previously sent you, there appears to be some confusion about what the document represents.
But there was no confusion when on 20 December 2019, in its response to Professor Brassington’s concerns, the EA wrote :
Thank you for your email (15 November 2019) and your patience while we have worked to bring together all the information needed to respond to you enquiry.
Please find attached a position statement regarding the proposed quarry at Straitgate Farm, Ottery St Mary. If you have any questions regarding the content of this document, please contact us at DCISEnquiries@environment-agency.gov.uk.
Thank you and goodbye. Ok, so there was no thank you, and no attempt to explain why the EA disagreed with Professor Brassington. This week, the EA had another go, regurgitating a lot of worn out arguments, disparaging the views of a Professor of Hydrogeology responsible for textbooks on the subject:
There’s little point in going over the same old ground here, save for one thing. The EA, the protector and guardian of our precious groundwater, says:
the boreholes making up our groundwater level network in the Straitgate area all show that 2013/14 groundwater levels were the highest on record (with some records going back to the late 1960s).
By coincidence, this was the very same time Aggregate Industries started groundwater monitoring at Straitgate Farm. That's right. What are the chances?
However, the EA relies upon the 2013/14 levels to underpin Aggregate Industries' model of the maximum water table – the MWWT, the base of any quarry – despite knowing that 1990 groundwater levels were 2.8m higher than the MWWT in one location, despite knowing that 2018 groundwater levels then exceeded the MWWT in four locations, despite knowing that stream flows from the site indicate higher groundwater levels in other years too.
The EA relies upon the 2013/14 levels to write off the need for an unquarried buffer, the sort typically employed elsewhere, despite knowing the above, and despite having no idea of the accuracy of Aggregate Industries' model.
For clarity, when the EA talks about the "Straitgate area", it means East Devon. One of the handful of boreholes the EA relies upon in the "Straitgate area" is Bussels No 7A, many miles away. Dr Rutter says "I don’t consider it relevant… this well is over 90m deep and unlikely to respond to recharge in the same way as the shallow groundwater." Prof Brassington agrees, saying "a competition between observation boreholes has little meaning" and instead bases his conclusions on stream flows originating directly from the site:
The only conclusion that can be drawn from this hydrograph is that the groundwater levels on the Straitgate Farm site would have been at a higher elevation than those in 2013/14 during the winters of 1976/77 and 2000/01.
The EA has at last grudgingly accepted that the elevated 1990 figure should now be taken into account – which puts groundwater 2.8m above Aggregate Industries’ guesstimate in one area – but then they take a swipe at us:
The 1990 groundwater level information that Straitgate Action Group previously provided to us was one spot reading with no provenance given. Professor Brassington’s report gave the provenance as: SJ Parkhouse, 1990, ‘Report on the reserves of pebble beds at Straitgate Farm near Rockbeare’. We requested this report from Aggregate Industries and agreed with Professor Brassington that the data within it should be used to update the grid.
But the allegation that we supplied "no provenance" is bunk. Not one, but three documents were attached to our email to the EA in June 2018, to provide provenance for the 1990 figure:
Attachments: Straitgate_Geology_Plan_a.pdf (667K), R0001 SJP Dec 1990 Report on reserves of Pebble Beds at Straitgate Farm (dragged).pdf (520K), R0001 Appendix 6 (dragged).pdf (557K)
In other words, not only the relevant data from the said report, but also a map from Aggregate Industries – annotated below – showing groundwater data from 1990. The EA would have had this map from at least 2012, when the Minerals Plan was being put together. If they had bothered to look, the EA could have seen for themselves that at SG1990/021, groundwater in June 1990 was just 1.3m below the ground surface – indicating no resource would be available around this location.
On the same day we sent the email to the EA, we also sent an email to DCC, and posted AI has ‘forgotten’ one 1990 borehole – that puts groundwater 2.8M ABOVE MWWT – the modelled maximum winter water table – writing:
This is clarified in "Report on the reserves of Pebble Beds at Straitgate Farm, near Rockbeare", supplied to us by AI some years ago; a report that was based on analysis of 24 boreholes. The full borehole logs show that on 12/6/90 the water level in borehole 21 was 1.26m below the surface.
Both links went directly to that provenance. On the same day, DCC wrote back:
I have already been in communication with the EA asking for them to address the issues in your recent blogs in their final comments to ensure that my Committee is aware of all the issues at Straitgate.
But if the EA is really looking for someone else to blame for any shortcomings, perhaps it should point the finger at Aggregate Industries and its merry band of consultants. Perhaps the EA should ask them why the 2.8m higher 1990 figure was not included in Aggregate Industries' model of the water table, why it didn’t inform extraction boundaries and infiltration areas, why it didn’t influence resource calculations.
Last month, the EA revised its conditions in relation to the Aggregate Industries' application. On the issue of the EA’s revised conditions still allow AI to dig below MWWT, the EA doesn’t care:
on annual update of the MWWT grid, we draw your attention to the following recommended condition:
Continuous (daily) monitoring of all site piezometers, and interpolation between them, shall be used to ensure, during working, that the base level to which the quarry is worked is no closer to the contemporaneous measured groundwater level than 1m.
We feel this sufficiently addresses this issue.
But of course it doesn’t address the issue. If groundwater levels surpass the MWWT – as they have before – so long as water levels recede during the summer by more than 1m, as they invariably do, the EA are effectively saying it’s fine to continue to quarry to the breached MWWT levels (i.e. below the level of the maximum water table) until such time that Aggregate Industries gets around to adjusting its model, maybe never judging by previous water reports.
Even the condition above isn’t clear. As someone pointed out: "Continuous (daily) monitoring" is not the same as "Continuous daily interpolation". Does the EA therefore mean "... quarry is worked no closer to the contemporaneous interpolated groundwater level than 1m"? Who knows? Perhaps not even the EA.
And while digger drivers try to work to contemporaneous interpolations, groundwater levels across the site can rise by up to "1m in 5 days". What an earth could go wrong?
The EA of course doesn’t want to trouble itself with knowing how any of this unorthodox untested untried seasonal scheme is going to work:
It is not for the Environment Agency to advise on the precise methods by which the operatives will work. DCC should agree this with the quarry operator.
