In a letter of 7 April 2021, Aggregate Industries wrote:
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.
Has the company given up caring whether its application to quarry Straitgate Farm makes any sense?
As we’ve posted, major fundamental issues have still not been resolved, not least on the issue of surface water and how a scheme could be produced that satisfies the interconnected issues of flooding, stream flow, groundwater recharge, and airport safeguarding – without losing even more resource.
But it’s not just that. The documentation is a shambles. It’s difficult to see how any consultation could be valid given the quagmire of contradictions. It’s difficult to see how any subsequent decision taken at committee could be robust.
For example: The Supporting Statement for the Straitgate Farm application should be one document that can be relied upon – but not so. The document reminds us that:
8.2. This application is inextricably linked to another planning application to import the sand and gravel from Straitgate Farm into Hillhead Quarry.
The Hillhead Supporting Statement echoes that:
1.1.2. This planning application is inextricably linked to another separate planning application to win and work 1.5 million tonnes of sand and gravel at Straitgate Farm. Both this application and the Straitgate Farm application are supported by a common Environmental Statement.
And a common Environmental Statement may be how things this started, but matters have moved on.
Aggregate Industries says the July 2018 Transport Assessment – the one now being consulted on – "supersedes previous assessments", but it makes no assessment of the impacts of the multi-million mile haulage plan to Hillhead. That job falls to the previous, superseded TA, the one still live for the Hillhead application. Confused? That TA is now seriously out of date: the traffic count for Clay Lane is from 2016, the count for the M5 from 2015; the collision data up to the end of 2015. However, it does claim:
7.5 Processed material will be sold into the local aggregates market. Approximately 90% of material will be sold into the Exeter market travelling via the A38 and M5. Approximately 10% will be sold into markets adjacent to Hillhead accessed via the A38.
This is in clear disagreement with the new Greenwash Report which assumes – in order to show that hauling material 46 miles for each load is magically the most sustainable option – that only 34% heads to the Exeter/M5 market.
The Straitgate Supporting Statement cites the widening of Clay Lane to be "of great benefit to residential amenity and carry significant weight in the decision making process" and furthermore that:
5.4.8 Critics will, no doubt, point to the distance which the Straitgate Farm minerals will need to travel to Hillhead for processing and, if current market conditions prevail, the distance those processed minerals will have to travel to their end destination. 5.4.11 The Applicant considers that the highway infrastructure improvement measures included in both planning applications are sufficient to outweigh the negative impact of transporting the Straitgate minerals to Hillhead Quarry for processing and, therefore, overcome the apparent conflict with Policy M22.
The application was originally advertised and consulted on that basis. Indeed, the Hillhead Supporting Statement crows:
7.12. The planning application to import Straitgate Farm mineral into Hillhead Quarry for processing was generally very well received, particularly the proposal to widen a 400 metre section of Clay Lane to accommodate two way traffic.
Even the planning red line boundary for the Hillhead application still includes:
The problem? The application to widen Clay Lane was approved separately in 2018. The stated benefits can no longer support the Straitgate application, to "overcome the apparent conflict with Policy M22". So why has the Supporting Statement not been updated to spell out the correct situation?
Clearly the public have been consulted on incorrect information, clearly councillors risk being misled.
It doesn’t stop there. Straitgate’s Supporting Statement claims:
8.7. The maximum number of vehicle movements generated as a result of this proposal is 86 loads per day, or 172 movements per day.
This is mirrored in Hillhead’s Supporting Statement which says:
3.4.2. The maximum number of loads from Straitgate Farm to Hillhead Quarry is 86 per day.
Does Aggregate Industries know what maximum means? The TA that "supersedes previous assessments" claims:
6.1.2 During intensive periods of working this would have the potential to increase to 216 HGV trips per day...
And what about the poor pedestrians? Straitgate’s Supporting Statement claims:
3.4.5 In order to allow pedestrians using Birdcage Lane a route which avoids any interaction with lorries accessing the site, it is proposed to install a permissive footpath running parallel with Birdcage Lane just inside the tree belt around the periphery of the fields from the Exeter Road junction northwards...
The new draft S106 formalises this:
i) AIUK shall create a new permissive footpath adjacent to Birdcage Lane as shown on plan referenced SF/2 Rev B prior to the commencement of quarrying operations and maintain such permissive public footpath for the duration of the permitted development.
Brilliant. But quite how a new permissive footpath opening up near the site entrance – an entrance with up to 216 HGV movements per day – and connecting with OSM Footpath 87 to the south and east, OSM Footpath 88 to the north and WH Footpath 1 to the south, "avoids any interaction with lorries accessing the site" is anybody’s guess.
And then there’s the orchard. Aggregate Industries has taken an unnaturally keen interest in the Straitgate Farm Orchard. Straitgate’s Supporting Statement claims:
3.8.14 Immediately to the south of Straitgate farmhouse is a dilapidated orchard. The orchard is shown on Ordnance Survey Maps dating back to the late 19th century and could be considered as an important part of the setting of the grade II listed farmhouse. 3.8.15 The Applicant recognises the value of the orchard both to biodiversity and to the heritage asset and proposes to restore the orchard to its former glory by propagation from existing apple trees, growing them on and replanting in a grid pattern. Cuttings will ensure local providence and the restored orchard will provide an attractive feature.
How many cuttings would be taken to restore the orchard? "Cuttings will be taken from 10 trees as agreed with the nursery."
Fab. So, why does the new Greenwash Report assume that "17,200m2 of restored orchard" would be planted "at a density of 2,250 trees/Ha" – a staggering 3,870 trees that would supposedly sequester annually an impossible "9.3 tCO2e"?
The problem doesn’t stop at the orchard. Straitgate’s Supporting Statement claims:
3.8.18 Consultation with the CAA ecological advisers has indicated that satisfactory mitigation will be achieved to negate the potential for bird strike if the proposed vegetation height can be restricted to 4-5m which is the height typically attained after some years by the shrub species proposed for the planting scheme. Additionally, they recommend restricting the spatial extent of tree planting to copses, hedgerows and shelterbelts as opposed to extensive woodland planting, and the proposed restoration planting scheme follows this advice.
So again, given those restrictions, why does the Greenwash Report assume a planting density of 2,250 trees/Ha, a stocking density typically employed for conifer forests? Clearly the report’s author knows as much about tree planting as he does about the available gravel at Hillhead.
All in all, the whole thing's a mess.
