In 1965, Straitgate Farm near Ottery St Mary in Devon was bought by ECC Quarries in the hope it would yield 20 million tonnes of sand & gravel. In 2001, Straitgate Action Group was formed to oppose the development and its potential harm to water supplies, ancient wetland habitats, protected species and much more. In 2023, Aggregate Industries – owned by Swiss giant Holcim – was finally granted permission to quarry just 1 million tonnes following a public inquiry. This blog records the story.
5.3.3 The excavation is designed to include areas of infiltration that will be sized to capture all runoff from the workings and infiltration areas will be incorporated into the final restoration design. This will be designed to enhance groundwater recharge and will increase infiltration and spring flows by the amount of overland flow that would otherwise have occurred.
In 2017, in its Regulation 22 request, the Council requested information on the infiltration areas:
3.6 The MPA has insufficient information about the management of the infiltration/ephemeral pond area to determine whether it will contribute to the appropriate management of surface and groundwater flows; stream recharging; airport safeguarding and long term agricultural restoration.
Two proposed ephemeral water bodies in the low-lying infiltration areas are shown as part of the Straitgate Farm restoration scheme on Drawing SF/6 (Rev.A). The proposed restoration scheme ensures that post-extraction the site will be returned to a similar baseline condition. The proposed enhanced infiltration areas for the Birdcage and Cadhay Wood sub-catchments are not SuDS and as they are infiltration areas they will not be permanent waterbodies. They are simply a feature incorporated into the restored landscape to assist in providing some betterment over the baseline conditions. These will be formed to enhance the capture of ‘overland flow’ and to locally increase the proportion of rainfall that passes to groundwater.
But if the restored landform is to mimic current drainage, why on earth is one of these enhanced infiltration areas – areas designed to "to locally increase the proportion of rainfall that passes to groundwater" – located outside of the area that feeds Cadhay’s spring, drawing water away from a crucial water source for a Grade I listed house?
Within the extraction boundary proposed by Aggregate Industries in its plans to quarry Straitgate Farm there are places where there is zero recoverable sand and gravel; in other places less than 1m.
How is it sustainable to remove, handle, store, put back, more than 2m of topsoil and overburden, best and most versatile agricultural land, to extract less than 1m of sand and gravel? The answer is – it's not.
The plan below overlays the revised maximum water table contours – the base of any quarry – over the ground elevation contours. The difference between the contours is the amount of material above the maximum water table, including soil and overburden. If we assume the soil and overburden is on average 2.28m thick, as stated in the Parkhouse Report 1990, we can arrive at the available resource.
We find that within the extraction boundary there are clearly areas with little or no available resource.
And it may be worse than that. The new resource statement puts the overburden at 600,000m3. Across 22.6ha, an area of 226,000m2, that works out as a soil and overburden thickness of 2.65m.
In June 2018, the Environment Agency confirmed to us in an email:
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.
In August 2018, Devon County Council acknowledged in an email to Aggregate Industries:
... from talking to the EA that there are areas within the proposed working that may not be workable due to the groundwater levels. Whilst we wouldn’t require new plans overall as it’s within the red line area, we would definitely require it to be clearly shown within the working area drawings and also factored into the resource assessment so that the impact on the planning balance can be assessed.
So, where, clearly shown, is this area on the new working drawings? Nowhere to be seen. The reason? Aggregate Industries pushed back – in this now superseded document – claiming "the extraction area, as shown on the Wood E&IS plan, remains unchanged":
The change... results in no area being "excluded for reasons of groundwater protection" but merely a localised effect on the depth of working in a localised (eastern) part of the site.
Good try, but wrong. From the overlaid contours above it's as clear as day that this localised area has no recoverable resource. So why is it still within the extraction boundary?
Aggregate Industries' plans to quarry Straitgate Farm propose infiltration areas along the eastern boundary to control flooding, maintain groundwater recharge for springs and water supplies, and maintain stream flows – all without becoming permanent bodies of water and an airport safeguarding hazard.
We’ve already shown that these areas can’t work as described. Surface water would not infiltrate equally along the length of the eastern boundary given the gradient of the proposed extraction base.
2.18.3 Quarrying operations will be excavating down to a range of between 3m along the eastern boundary and up to 9m at the western most extremity including the overburden.
In addition, bunds along the eastern boundary would be formed:
2.18.3 The north-south bunds shown on Figure A2.1/A2.2/A2.3 are not intended to retain water, their main purpose being visual/noise screening.
It is claimed the bunds would only act to retain surface water during intense rainfall, including:
2.18.4 In the event of an extreme rainfall event filling up void capacity, such that depths exceeded the excavation depth and backed up against the bund. Given a maximum of 1.45m of depth is expected during the design (1 in 100 year + climate change allowance) rainfall event, and the maximum void depth is 3-9m, a significant exceedance event would be required.
However, given the elevated groundwater levels recorded along the eastern boundary, and the newly-submitted maximum winter water table contours – the base of any extraction – it is clear that it would be impossible to dig 3m deep along this boundary without breaching this new MWWT.
The diagram above overlays three plans: the phase 2 infiltration area, the surface contours and the MWWT contours. The numbers indicate the depth from the surface to the MWWT elevation at points where contours from the latter two plans intersect. Clearly, along at least half the length, a depth of 3m is not available for excavation.
The phase 1 infiltration area would have similar problems too.
And what's the impact on flooding? The elevated groundwater levels recorded at three locations along the eastern boundary – PZ2017/02, PZ2017/03 and SG1990/21 – may have informed a new base of extraction, but they have not informed the Flood Risk Assessment which was written in 2016.
Without assessment of this new information, who knows what the flooding implications might be? Obviously not Devon County Council, the Environment Agency, or any councillors unlucky enough to determine this mishmash of chaos.
The issue of how surface water is to be managed has always been recognised as critical if any quarrying were to be permitted at Straitgate Farm. Clearly Aggregate Industries' planning application is still in no fit state to be determined.
Aggregate Industries may have made its "final submission of additional information" for its planning application to quarry Straitgate Farm, but it's clear that one of the most important pieces of information is still not known with any certainty.
We're referring to the maximum winter water table, the MWWT, the base elevation of any quarry, critical in determining how deep to dig, critical in determining the amount of material available, critical in determining the impacts on water supplies and stream flows.
Aggregate Industries' guesstimate of the maximum water table at Straitgate Farm – which consultants had claimed "builds in a conservatism" – has been found wanting ever since it was produced.
a negative tolerance represents conservatism and contingency which is incorporated in the selection of the MWWT
It sounds like bullshit, and it is. For obvious reasons, consultants did not address the inherent inaccuracies of the interpolation method itself, of estimating groundwater levels across 55 sloping acres with just a handful of numbers.
So for all that confidence, conservatism and contingency, what do we now find? Just as we thought likely last year, when we said:
Aggregate Industries' realistic assessment will no doubt have been breached YET AGAIN. Earlier this year, PZ10 reached 102.4 mAOD – 70cm higher than in 2018. It’s virtually certain that a number of the newer piezometers – PZ2017/02 and PZ2017/03 in particular – will have recorded new maximums.
And hey presto, water levels did indeed exceed Aggregate Industries' guesstimate AGAIN. The maximum water level in PZ2017/02, which exceeded the MWWT back in 2018, went nearly 50cm higher in 2020. The groundwater level in this location has now exceeded the company's original guess by a whopping 1.75m. Water levels in PZ06 – installed back in 2013 – also reached a new maximum, as did three other piezometers. So much for the promise from Aggregate Industries' consultants – and backed up by the Environment Agency – that 2014 groundwater levels "are likely to reflect the highest groundwater levels that may occur at Straitgate."
How could consultants get it so wrong? Was it by erring not on the side of caution, but on the side of its profit-hungry client?
Consultants Wood have had another go and have re-guesstimated the MWWT contours. Who knows whether they're right this time? Certainly not Aggregate Industries, Devon County Council or the Environment Agency. In 2017, Dr Rutter warned:
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.
The issue of surface water management is critical at Straitgate Farm if any quarrying is to be permitted. In 2015, Devon County Council warned:
The surface water management is inextricably connected to Flood Risk Management/Airport safeguarding and the need to maintain and recharge watercourses. This issue is so important in terms of the likely significant impacts of the proposal the MPA would wish to ensure that a SWM scheme can be designed to meet all of the requirements identified in advance of the determination of this application.
The surface water management strategy should identify location of the infiltration features and how these fit into the site; It should be confirmed how the water will be collected in the catchment for these headwaters to supply the stream heads (bearing in mind airport safeguarding requirements) and the proposed phasing of the site. This should include detailed design regarding their size, details whether infiltration is permitted at the proposed locations and where targeted at areas where infiltration is required to support the spring lines of the existing watercourses (as commented by the Environment Agency), together with details of exceedance pathways. Due to the nature of the flood risk downstream, greenfield performance should be achieved and the site should be designed to the worst case scenario as detailed in the FRA and should ensure that drainage from the site mimics, as closely as possible, the natural hydrograph in perpetuity. The MPA will wish to have it demonstrated that the applicant has engaged with the LLFA, the EA and the Airport to design a scheme that can accord with all of their various requirements.
2.18.2 Figures A2.1, A2.2 and A2.3 in Annex C of the submitted Surface Water Management Plan, provided in Appendix C of the Flood Risk Assessment (FRA) (Amec Foster Wheeler document reference: 33679rr145i4) details the proposed areas of the void base for phases 1, 2 and 3 where runoff will collect as it infiltrates. The figures show the sub-catchment divides, where gradient parallel bunds and contouring will be required to ensure the proportion of runoff draining to different sub-catchments remains the same during the extraction process (i.e. it is targeted to the required sub-catchment).
We have posted before that Aggregate Industries' infiltration plans were unworkable.
Since then, the maximum winter water table contours have been revised, and the problem has become more apparent.
Whilst existing ground elevation contours run parallel to the eastern extraction boundary, the base of any quarry as defined by the newly revised MWWT contours would not.
As shown above – where the infiltration areas overlay the revised MWWT contours – the proposed base of extraction in the areas set aside for infiltration in phases 1 and 2 does not mimic ground elevations to maintain pre-extraction infiltration characteristics. In phase 2, for example, the base of extraction in the infiltration area falls from 140mAOD to less than 135m.
Surface water running off the extraction site would not infiltrate equally along the eastern extraction boundary. In phase 2, run-off would flow to the north-east, directing water away from the Cadhay Wood stream, the stream feeding Cadhay's mediaeval fishponds, and away from the Cadhay spring, the spring supplying drinking water to Grade I listed Cadhay and a whole host of others. In phase 1, water would be directed towards the middle of the infiltration area.
Of course, this not only has implications for flooding, springs, stream flows and airport safeguarding, but also for the resource available – freshly cut to 1.06 million tonnes.
How much care has gone into the new documents supporting Aggregate Industries’ planning application to quarry Straitgate Farm, the ones now subject to public consultation?
Has anybody at Aggregate Industries bothered to check them? It certainly doesn’t look like it. It’s almost as though the company can’t be bothered any more.
Take the newly supplied Transport Assessment. This is the company’s third transport assessment since 2015, from its third set of traffic consultants. This one is from Horizon Consulting Engineers Ltd. It may be newly supplied, but it’s not newly written. It’s dated July 2018. The traffic count is almost 3 years old; collision data more than 4 years old.
It’s been through some changes too. As submitted, it stands at Revision E which claims:
1.1.8 It has been agreed with the Tenant farmer... that there will not be a need to intensify livestock crossings over the B3174 Exeter Road...
Devon County Council wrote to Aggregate Industries in November 2017, saying:
... in order to assess the potential highway safety impacts the MPA needs to have reliable information on existing and potential agricultural crossings of the Exeter Road and, in particular how this would be controlled in the future in the interests of highway safety....
If we do not receive this information in full I cannot address the likely highway safety impacts in any report to the County Council’s Development Management Committee.
But neither Aggregate Industries nor Devon County Council can tell the farmer how to run their business. There are no laws preventing farmers herding livestock across or along roads. The highway authority has no explicit powers to prevent a farmer doing so. As long as it's done safely, with crossing points washed down, if the farmer needs to put cows across the road to sustain their business then they can do so. It happens all over Devon.
Moreover, within reason, the farmer can take whatever time it takes to move the 150 cows across the B3174 Exeter Road and clean up afterwards.
Some cows can’t be hurried, despite what Aggregate Industries’ traffic consultant claims. Revision D in March 2019 was updated to Revision E in June 2019. The only substantive change?
3.2.6 Dairy herds of similar size have been observed at other farms in Devon crossing a similar distance, without splitting the herd, in 4 minutes.
Really? And how long did the traffic consultant scour Devon looking for such herds? Or was it the task of an Aggregate Industries’ operative? Or was it no one? In any case, it’s immaterial. Cows will take whatever time cows will take; 150 cows from this Devon herd would certainly not take 4 minutes:
So the Transport Assessment is fatally flawed. It has not assessed the impact of the additional cattle that would have to cross the B3174 Exeter Road as a direct consequence of the planning application, an application that seeks to remove almost 90% of pasture for mineral extraction and associated infrastructure. It has not assessed the impact on the functioning of the road network, including the A30. It has not assessed the impact on safety.
What other clangers are there? The usual inconsistencies:
4.1.1 Over an eight to ten year period it is proposed to extract circa 1.5 million tonnes of ‘as-raised’ sand and gravel...
5.1.1 Sand and gravel extraction at Straitgate Farm is proposed... over an estimated 10 to 12 year period.
Which is it? On the risk to school children:
5.5.6 To address the identified risk to students of HGV’s the Applicant has agreed to an embargo during term time on HGV movements between the hours of 08:05 and 08:30 in the AM peak...
3.2.11 A site visit was undertaken... The coach arrived at 8.36 am.
Brilliant. On site access:
4.2.1 The purpose of this report is not to revisit the previously discounted access points...
5.44 The southern option, onto the B3174, was dismissed early in the process on highway safety grounds.
On being so out of date, events have already superseded it:
5.5.10 ...the Applicant would assist the Tennant [sic] in submitting an application for an agricultural access
Aggregate Industries submitted such an application to East Devon District Council last December, not as some kindly act of assistance, but to facilitate its quarry plans.
On accidents:
3.2.32 ...No collisions involving HGV’s [sic] have occurred within the three year period...
Aggregate Industries wants to haul material along the B3174 to the A30 Daisymount Junction. So why not assess that stretch? Why assess just this little area?
Is it because when consultants looked further they discovered this fatal accident?
And we all know how many accidents there have been since then – including HGVs – on this stretch of the B3174 Exeter Road, where Aggregate Industries wants to put up to 216 HGV movements per day. There’s even a label – B3174 accident – on the side of this blog pointing some of them out.
Which makes this Devon County Council internal email – released through an FOI request – all the more embarrassing:
And where are we now? Going out to yet another consultation, seeking comments on a document riddled with errors.
Do Aggregate Industries and Devon County Council think local people have nothing better to do with their time than waste it on mineral consultations, going through error-riddled-document after error-riddled-document, pointing out problem after problem, problems that should have been ironed out BEFORE seeking their views?
After all, it’s not as though Aggregate Industries hasn’t had the time.
Aggregate Industries wants to grub many of them up, saying whatever it can to dismiss their importance.
The company's wildlife assessments of Straitgate Farm are years out of date. Surveys of hedgerows, dormice, bats, birds, badgers, etc., were all performed back in 2013. Devon County Council requested an update, and last year a consultant working on behalf of Aggregate Industries had a bit of a walkabout. The independence of this ecologist is obviously questionable given this Freudian slip:
Mike was accompanied by My Clive Tompkins of Aggregate Industries during the visit.
But not only for that reason. On the subject of hedgerows, the ecologist reckoned "most have been recently flailed back hard." It was another fabrication, as the above photo taken this week confirms.
US: The Texas Commission on Environmental Quality has approved a request by Holcim US to use more petcoke at its integrated Midlothian plant. Local health and environmental campaigners had hoped to challenge the decision at a meeting in late March 2021, according to the Fort Worth Star-Telegram newspaper. The changes will enable the company, part of Switzerland-based LafargeHolcim, to more than double the plant’s carbon monoxide (CO) emissions to 7000t/yr. 35 local residents submitted requests for a hearing to query the application. Holcim US was identified from state data as the leading emitter of industrial pollutants in North Texas in 2019.
More than a year of protests from Midlothian activists came down to a few minutes of discussion among state officials. The result was not what residents fighting cement pollution were hoping for. For @startelegram + @Report4America: https://t.co/0XcSD4gAZw
Jane Williams, a long-time environmental activist who chairs the Sierra Club’s National Clean Air Team, said Midlothian Breathe’s predicament is not unique to Texas.
“No matter what state you’re in, no matter what local jurisdiction you’re in, these cement plants are very savvy at getting local authorities to be friendly toward whatever they want to do. You’re really in a David v. Goliath battle from the beginning. You’re fighting not only the industry, but also usually the process of the state government.”
Despite the landscape implications, Aggregate Industries’ application DCC/4189/2020 for a new asphalt plant adjacent to Broadpath landfill site next to Hillhead Quarry has been recommended for approval.
The company's supporting statement for the proposal says "there will be an intrinsic link with Hillhead Quarry due to the use of sand and gravel from the quarry in the asphalt making process."
Previous posts on this potential eyesore can be found here.
The planning officer’s report reads:
7.3 Taken in isolation, the landscape and visual impacts of the proposed development are such as to warrant refusal of the application due to the significant harm to the local landscape character and visual quality. Although some mitigation is proposed in the form of building design and tree planting, this is insufficient to outweigh the harm caused to the landscape, and the proposals are considered to fail to accord with relevant policies, notably M18 and M20 of the Devon Minerals Plan and DM1 of the Mid Devon Local Plan.
7.4 However, it is necessary to weigh the adverse landscape impact against the benefits that will be derived from securing the closure of the existing asphalt plant at Westleigh Quarry and cessation of the associated lorry movements through Burlescombe, particularly those during the night. The strong support for the proposal from Burlescombe and Holcombe Rogus Parish Councils is noted, as is the location of the site within a landscape that has been subject to extensive mineral and waste development.
7.5 It is considered that, while the proposal is contrary to the Minerals Plan in terms of Policy M18, the benefits of facilitating the relocation of the asphalt plant away from Westleigh to a location where operational and traffic impacts will be lower is sufficient to offset the landscape impact. It is therefore considered that the principle of the development is acceptable in overall policy terms, having regard to the Devon Minerals Plan as a whole together with paragraph 203 of the NPPF, and that the development should be approved subject to the conditions set out in Appendix I.
We would now ask that our application is progressed to the next available committee and confirm our agreement to a time extension until the 31st July 2021 in order to achieve this.
This additional information was originally requested almost 4 years ago, but seemingly it still didn’t tick all the boxes that Devon County Council had wanted. On 11 March 2021, Devon County Council wrote back to Aggregate Industries saying:
Additional information is required to determine the associated application at Straitgate Farm reference DCC/3944/2017… I am writing to ask you to formally agree to extend the period for the determination of your application until 30 September 2021. You have indicated this will give you adequate time.
Despite the above, no further information has been provided beyond that final submission.
On 7 April 2021, Aggregate Industries wrote to Devon County Council again, this time saying:
We would now ask that our application is progressed to the next available committee and confirm our agreement to a time extension until the 30th September 2021 in order to achieve this.
Devon County Council has now started a new 30-day public consultation on this application and also DCC/3945/2017 which seeks to import the as-dug sand and gravel from Straitgate Farm into Hillhead Quarry near Uffculme for processing – a 2.5 million-mile operation.
How the public are supposed to wade through the disparate collection of documents and muddle is anybody’s guess. You might have hoped – in all the intervening years – that Aggregate Industries would have done some serious thinking about this application, that it would have all its ducks aligned. But no. This final submission contains the normal assortment of nonsense, omissions, falsity and contradictions.
We therefore conclude that any increase in animal or farm traffic crossing this road is a direct consequence of the current planning application and needs to be assessed as a part of the highways impacts.
Remarkably, but tellingly, no assessment has been lodged on what impact 150 cows crossing four times daily would have on the functioning of the main road into and out of Ottery St Mary. The application lodged with East Devon District Council to facilitate such a crossing remains undetermined.
The final submission supplied by Aggregate Industries includes:
TRAFFIC: Transport Assessment, July 2018, which supersedes previous assessments.
LANDSCAPE & SOILS: Set of revised plans to accompany above report, which supersede the previously submitted versions of all the following plans
CLIMATE CHANGE: Greenhouse Gas Assessment of the Proposed Quarry at Straitgate Farm, Centre for Energy and the Environment, Exeter University, March 2021
Comments on this final submission, or any other part of the applications, should be made to Devon County Council, either online or by email to planning@devon.gov.uk including name, address and the reference numbers above.
Following the post DCC willing to agree YET ANOTHER extension with AI, Devon County Council has uploaded a multitude of additional documents – supplied over a month ago by Aggregate Industries for its planning application DCC/3944/2017 to quarry Straitgate Farm.
These documents, including some correspondence dating back to 2017, were presumably too sensitive at that time for public eyes.
So, in date order, here is some of that correspondence so that others can see what has been going on behind the scenes.
14 August 2017, Devon County Council to Aggregate Industries:
Clearly, your proposal to carry out works in the highway is, as admitted in your own application documentation, likely to have a detrimental impact on the oak tree within the hedgerow known as "Tree H."…
The issue, however, is whether Devon County Council as Highway Authority, in entering into a s.278 agreement with Aggregate Industries for works within the highway would knowingly be sanctioning works that would damage the property of a third party.
It is clear that the size of vehicles involved in the application render a ‘no dig’ solution inappropriate for the depth of road construction that would be required. It is also clear that the Section 278 works for widening and construction of the carriageway are likely to result in damage to the tree and its potential demise. The tree in question is in the ownership of a third party and the highway authority is aware that he is opposed to any damage to the tree. He considers it to be in relatively good health, a view that is shared by the district council’s tree officer. In these circumstances the highway authority would not be in a position to enter in to a S278 agreement unless this matter is resolved. I would strongly suggest that you contact the owner of the hedgerow and tree and try to reach agreement before you proceed further with this application or come back to us with a proposal that might be acceptable which does not impact on third party assets or possessions.
13 September 2017, Devon County Council to Aggregate Industries:
… you need to provide sufficient information and a detailed Stage 2 safety audit of the proposed cattle crossing or of the scheme to include the proposed cattle crossing to enable the Highway Authority to properly assess the safety and network impacts which should include the potential for queueing traffic. This cannot be left to a determination by the District Council with relation to any subsequent planning application for a new crossing, as the any grant of permission for the quarry could lead to your tenant using the existing farm track and field gates without the need for any separate permission. We therefore conclude that any increase in animal or farm traffic crossing this road is a direct consequence of the current planning application and needs to be assessed as a part of the highways impacts.
6 October 2020, Devon County Council to Aggregate Industries:
We still do not appear to have resolved the issue of the cattle crossing in any final way since that time and my last advice from Mr Tompkins was that negotiations were ongoing with the tenant….
This application has now been with the County Council for nearly three years [now almost 6 years, not forgetting the previous pulled application of 2015] and the uncertainty for the local community is a situation that the County Council as Mineral Planning Authority can no longer accept by continuing to request further delays in the determination due to a lack of the information we have been asking Aggregate Industries to provide.
I must advise you that any extension of the determination date will now be limited to a reasonable period of time for you to do this work. The County Council will not be requesting a further extension of time beyond the end of this year and if the information is not provided in sufficient time for a determination at the meeting on 27th January, then it is my advice that the County Council is likely to proceed to determine the application as it stands and in the absence of the clarification we have requested on a number of important points.
I regret that we find ourselves in these circumstances, however, the guidance in Paragraph: 002 Reference ID: 21b-002-20140306 of the National Planning Policy Framework is clear that no application should spend more than a year with the decision makers.
Although this "planning guarantee" may be superseded by agreed extensions of time, I believe that the age of this application is such that we shall have to proceed to a determination unless you decide to withdraw it and re-submit with all new and updated material which although it would require yet another formal consultation would at least clarify where we are with the status of the documentation and the dates.
5 March 2021, Aggregate Industries to Devon County Council:
Please find attached our final submission of additional information in respect of the above planning application. We would now ask that our application is progressed to the next available committee and confirm our agreement to a time extension until the 31st July 2021 in order to achieve this.
11 March 2021, Devon County Council to Aggregate Industries:
Additional information is required to determine the associated application at Straitgate Farm reference DCC/3944/2017… I am writing to ask you to formally agree to extend the period for the determination of your application until 30 September 2021. You have indicated this will give you adequate time.
Make of all that what you will.
On 6 October 2020, Devon County Council told Aggregate Industries: "the County Council will not be requesting a further extension of time beyond the end of this year." On 11 March 2021, the same council wrote: "I am writing to ask you to formally agree to extend the period for the determination of your application until 30 September 2021."
Any concerns about local people suffering "consultation fatigue" have plainly been cast aside.
If every minerals-related planning application went as disastrously as the one Aggregate Industries has spent the last 6 YEARS pursuing at Straitgate Farm, there would be no minerals industry.
Last month, Aggregate Industries lodged a new assortment of documents with the usual nonsense, mistakes, omissions and falsity. Aggregate Industries may be good at digging holes – who knows? – but obviously planning applications are just a bit too much.
The whole thing can only be described as a clusterfuck:
(noun) A disastrously mishandled situation or undertaking
A generally futile attempt to solve a problem by throwing more people at it rather than more expertise.
Whichever definition fits best, pictorially it might look something like this:
The fiasco has been going on for so many years, we risk forgetting some of the many twists and turns along the way. So let's remind ourselves. Where has Aggregate Industries gone wrong?
By arguing it had the "necessary rights" to use third-party land for site access, soil storage, etc. It hadn’t.
By forgetting that silt from intensively farmed soils would have to be dumped in a highly protected nitrate-sensitive area of European importance for conservation if Straitgate material was processed at Blackhill.
By hoping its own report of the site back in 1990 would stay buried, the report that put the water table 2.8m higher than the company’s modelled maximum water table in the very same location proposed for infiltration areas to control flooding and maintain stream flows.
By claiming a S106 would take care of the risk to private water supplies, then showing it can’t be trusted with water monitoring S106s, by not sticking to the one at nearby Blackhill.
By ditching nearby Rockbeare as a suitable place for processing because of GCNs, whilst claiming there were none around Straitgate when it hadn’t looked.
By becoming bogged down with the cattle crossing conundrum,claiming there would be no additional livestock movements across the B3174, despite wanting to remove almost 90% of the available pasture.
Switzerland’s LafargeHolcim is proposing to simplify its name to Holcim Ltd, the world’s largest cement maker said on Friday, reverting to the name of the dominant partner in the 2015 merger that formed the company.
The reason given: for "efficiency and impact, while building on the group’s legacy."
In 2018, the Environment Agency launched an investigation into illegal dumping by a 'significant number of companies and individuals' at Stowey Quarry, a former limestone quarry near Chew Valley reservoir – a water supply for Bristol. We posted about it at the time.
Much of the waste arriving at Stowey Quarry was misleadingly described as a ‘soil substitute’ in a deliberate attempt to circumvent the rules.
The illegal operation, which accepted waste from around England, was described at Bristol Crown Court as one of the most serious risks of harm in the country during the past 30 years.
Other defendants in the case are due to be sentenced later.
Virtually all sand and gravel quarry operators process on-site – not 23 miles away as Aggregate Industries has proposed for Straitgate Farm. It makes economic sense. It makes environmental sense.
This week, Warwickshire County Council approved planning application RBC/20CM010 from Smiths Concrete to process sand and gravel at Wolston Fields Quarry rather than hauling material to a processing plant 3 miles away. Only two public objections were received. One councillor remarked:
By making sure it is going to work for the local community as well as being the known operator in the area is shown by the relatively low number of objections. With something like this you can sometimes have pages and pages and we’re just not seeing that this time which shows that this has been well thought through, well worked through with the proper consultation and everything has been considered.
The applicant claims that the proposals would reduce vehicle mileage by 50,000 kms and this would lead to a reduction in fuel consumption and carbon emissions over the short life of the scheme. The bulk of the figure arises from no longer hauling silt from Wolston to Bubbenhall for processing and the remainder from shorter trips to the company’s markets in Rugby and Coventry east areas. The claim appears reasonable and would demonstrate the reductions policies DM 5 and DM11 are seeking to achieve and a commitment to adapting to climate change.
Developers must demonstrate that a proposal facilitates sustainable transportation by: a. considering alternatives to road transport; b. minimising transportation distances; c. minimising the production of carbon emissions; and d. Where road is the only viable method of transportation, demonstrating that there is no unacceptable adverse impact on the safety, capacity and use of the highway network.
DM11 Carbon Emissions and Resource Efficiency:
Mineral development that reduces overall carbon emissions and improves resource efficiency during construction, operation and restoration will be supported subject to compliance with other policies in the development plan.
One day, Devon County Council might have to determine Aggregate Industries' proposal for Straitgate Farm. It would be an indication of how seriously the Council takes its declaration of a climate emergency, because rather than reducing haulage distances by 50,000 kms, Aggregate Industries' application is all about increasing haulage distances by 4,000,000 kms.
Last year, we posted about Aggregate Industries’ plans for a new asphalt plant at Hillhead, how planning application DCC/4189/2020 sought permission to build a 27m high asphalt plant – taller than 6 double decker buses – in an elevated position overlooking the Culm Valley, and how Devon County Council’s Landscape Officer concluded the application was "contrary to relevant landscape policies [providing] grounds for refusal".
This conclusion was based on Aggregate Industries’ Landscape and Visual Impact Assessment. The Landscape Officer had suggested:
The applicant should be given opportunity to provide... additional views and visualisations as a LVIA addendum for the benefit of decision-makers.
Photos should be taken in winter when trees are bare - to show worst case visibility.
An addendum of additional views was subsequently provided. Aggregate Industries’ consultant argued:
Whilst there would undoubtedly be adverse effects on the quality of some rural views, these will be not so great as to cause unacceptable levels of harm on visual amenity or landscape character.
Devon County Council’s Landscape Officer has now responded to this document, saying:
It is not appropriate for the LVIA assessor to state whether the effects are acceptable - this is a matter for decision makers when weighing the benefits against the harm in the planning balance.
The Landscape Officer concludes that the proposal is still contrary to local plan policies:
the development could not be fully integrated into the landscape without the upper parts of the development, including the stack and plume emissions, presenting an incongruous industrial intrusion onto rural skylines rising above surrounding mature woodland as perceived in numerous views within the Culm Valley Lowlands. Such effects are understated in the LVIA and would, in my opinion be significant as the development would extend the visual influence of industrial development at the site to a far greater area than is the case with the existing development, and would detract from, rather than conserve and enhance, the rural agricultural character of the Culm Valley Lowlands and its valued scenic quality as a gateway into Devon. The proposals would not make a positive contribution to the local landscape character. I therefore consider that the proposals are contrary to policy M18 and M20 of the Devon Minerals Plan and Policy DM1 of the Mid Devon Local Plan. Whether the proposed mitigation reduces adverse effects to acceptable levels as required through policy M18 is a matter for decision-makers.
A very important ‘gateway’ into Devon for people arriving by car on the M5 and A38, and also by train.
The DLCA should:
Protect and enhance the characteristic ‘patchwork’ landscape, particularly where it forms a ‘gateway’ into Devon from the M5, A38 and railway line.
The Landscape Officer says:
In my opinion, the proposals are inconsistent with these LCA guidelines and could not be accommodated without harming or eroding the special qualities and distinctive characteristics and valued features of the landscape influenced by the proposals.
The application will come before Devon County Council’s DMC on 21 April, after Aggregate Industries – in contrast to its 6-year application for Straitgate Farm – sought an early determination:
A delay beyond April could result in us losing the opportunity of securing this site from Viridor which, being located adjacent to existing mineral workings and future allocations in the Devon Minerals Plan with excellent access onto the A38 and M5, we believe to be an excellent long-term location for a new asphalt plant to serve this part of Devon...
We consider that the opportunity to acquire the Broadpath Site for a replacement asphalt plant is of strategic importance both to Aggregate Industries and the local community as it will enable existing asphalt production to be relocated from Westleigh Quarry and therefore respectfully request that this application is determined as soon as possible.
Aggregate Industries has a history of failing to control dust. This is apparent not only at its Bardon Hill quarry in Leicestershire, but also at its Westleigh quarry in Devon – as we have previously posted.
But it turns out another Aggregate Industries quarry in Devon – Moorcroft Quarry in Plymstock near Plymouth – is "causing health worries amongst its neighbours", reports PlymouthLive:
Plymouth residents are 'fed up' with the seemingly endless dust, noise and fumes which they say comes from a nearby working quarry. https://t.co/bv3Pf2aBDJ
Councillor Nigel Churchill, who represents the ward where the residents and quarry is situated, said he has had calls about Moorcroft quarry "all year round".
We care about the environment and communities around our sites...
Has Aggregate Industries given up caring "all year round"? Or was that claim never meant to be taken seriously, no more seriously than this claim:
As a forerunner in its commitment to the sustainability plight, Aggregate Industries continues to apply an increasingly eco-friendly approach to all business areas
One resident said:
Over the last three or four years the dust and noise has got worse, not to mention the fumes. I've spoken to the manager there I don't know how many times.
Another:
… as for the dust - it's hardly worth cleaning the car or the windows because as soon as you do, 12 hours later there's a thick layer on them…. There's definitely been an increase in the amount of noise and dust in recent years.
Yet another:
I've been complaining for ages about the smell and noise. They say the dust levels are within the limits but when you look at your car windows each day, covered in it, your letter box has got a thick layer, your outdoor table is thick with it - you wonder what is happening to your lungs.
They say they have water bowsers to damp down the large heaps of dust but I question as to whether they are using them. I've got neighbours around me who have complained about suffering from the dust, some of them have asthma. There's others who have contracted lung cancer who have never smoked. I can't say it's related - but I want to know what it is we're breathing in every day and what can it do to us? That's the biggest thing, more than anything - what is it doing to our health?
A spokesperson at Aggregate Industries is quoted as saying:
We are currently looking into some recent complaints in relation to our Moorcroft Quarry. As a responsible supplier within the area, we take all complaints very seriously and have therefore launched an investigation into this. We will look to deploy mitigation measures if necessary, to ensure we can reduce any future disruptions to the local community.
No other quarry of our 87 across the UK needs to have active and effective community engagement more than Moorcroft.
"In our situation we wouldn’t be here if we didn’t listen to our neighbours. Community engagement is a long process of talking, listening and presenting a known face. Even if it’s bad news, we tell them because, if we don’t, they’ll just make up their own stories."
So how’s that going, Aggregate Industries? Are local residents just making up their own stories?
