Monday, 19 April 2021

AI’s Transport Assessment is riddled with errors and fatally flawed

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...
It’s a big claim. And a big lie. No agreement, legal or otherwise, has been presented in the Transport Assessment or elsewhere other than an email from the farmer’s land agent which finishes by saying "these movements would need to occur daily." This email was added in Revision D of the document, replacing an unsigned Joint Statement authored by Aggregate Industries. Why? Revision C tells us that "the Tenant Farmer has been advised by their Solicitor and Agent not to sign the document", which will sound to most normal people as not agreed

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... 
Of course not. Want to know why? Previously, Aggregate Industries had dismissed the very site access it is now promoting
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... 
That’s based on 5 years of data up to 31 December 2016. What about since then? Devon County's map is now "displaying collisions between 01/01/2016 and 31/12/2020"? 

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 regarding that business about "No collisions involving HGV’s", well that obviously overlooks this little incident in April 2016


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.