Since submitting its first planning application to quarry Straitgate Farm back in 2015, Aggregate Industries has been granted 6 years by Devon County Council to resolve the various problems that have arisen.
And yet, there are still a multitude of substantive issues the company must resolve. Would it ever be able to resolve them? Are the complexities of Straitgate Farm simply beyond the capabilities of Aggregate Industries and its paid-up army of consultants?
What hope is there to resolve the complicated issues, when it can’t even get the basics right? Take soils.
Straitgate Farm comprises best and most versatile agricultural land. The Devon Minerals Plan says:
The site should be restored to enable resumption of agricultural use. To ensure the site is restored to an appropriate grade of agricultural land quality, proposals should assess the Agricultural Land Classification and detail proposed soil management techniques should be used throughout the site working and restoration stages. The working and restoration phasing should minimise the area of land not in cultivation, as soil is best conserved by being farmed rather than stored where some deterioration may occur.
Restoration back to BMV would obviously be a tall order, given that topsoils would be stored 3m deep for up to 12 years. The company's supporting statement claims "The long term after-use would be light intensity agricultural grazing." Land that could only support "light intensity agricultural grazing" is by definition not BMV. Soils suffer significant deterioration when stockpiled in piles more than 1m deep for long periods of time. They suffer rapid loss in organic carbon levels and soil organisms. Earthworms are key for soil quality but do not survive at depths greater than 1m. Soils stored in bunds become anaerobic within a few weeks. Soils stored for longer than a year suffer irreversible impacts.
Natural England has now responded again to the application. It is the fifth time this statutory agency – the one charged with protecting our natural environment and the one now "cut to the bone" – has had to deal with the proposal – excluding the multitude of responses in relation to the site's inclusion in the Minerals Plan, and Aggregate Industries' in-tandem applications to import material to Blackhill and Hillhead. Previous Natural England responses for Straitgate can be found here, here, here and here.
Natural England first warned Aggregate Industries about soils back in 2015:
as the site is BMV, the same area of BMV land should be restored. If there is no topsoil in an area it cannot be returned to grade 3a.
Details are needed on the restored profile. Para 3.42 refers to a restored profile of 1m, whereas the usual target profile would be 1.2m. The MAFF ALC survey shows that there are two distinct subsoils, which should be stripped and stored separately ready for replacement, however there is only reference to a single subsoil in the supporting documents.
Given the nature and extent of the comments and requirements from Natural England regarding soil storage it would be helpful if you could update the soils management strategy to include the comments made by NE. Additionally, I would wish AI to comment on the relationship between the NE requested condition that soils should not be stripped in the winter months, the ongoing farm management and soils storage methodology.
A soils management report was duly produced – the one recently consulted on – claiming "no loss of best and most versatile land." It was a big claim, and a questionable one, particularly given all the material needed to buttress the A30.
But nothing was written about soil movements during the winter, or – remembering the Mineral Plan's advice that "soil is best conserved by being farmed rather than stored" – how soil storage would work with ongoing farm management. Nothing was written about separately storing the "two distinct subsoils" that Natural England had referenced in 2015.
So here we are, in 2021, with Aggregate Industries still not having worked out something as basic as how and where it will store all the soils. Is the company just incompetent? Natural England now says:
As submitted, the application could have potential significant effects on soils. Natural England requires further information in order to determine the significance of these impacts and the scope for mitigation. The following information is required: • The degree to which the best and most versatile land should be capable of being reclaimed without loss of quality. Without this information, Natural England may need to object to the proposal.
The Soil Management Scheme and the detailed area plans submitted do not clearly identify the origin, intermediate and final locations of soils for use in the restoration, as defined by soil units (topsoil T1 and subsoils S1 and S2), together with details balancing the quantities (demonstrating the site has storage capacity), depths, and areas involved. We would expect restored soil profile to resemble pre working soil profile … if the grade is to be maintained.
...the Soils and Agricultural Land Classification Report (ES Ch 14) states that there is Grade 2, 3a and 3b soils present on site…. reports should detail how it is intended to restore an equivalent area of Grade 2 and 3a of the soils on site being disturbed by these proposed works, specifically with soil volumes and restoration profiles provided.
Without the separate stripping and storage of the subsoil S1 and S2, the accurate detailing of their storage location, and the restoration as described in the ES Ch 14 above it is our advice that this would [compromise] the ability to achieve high standards of restoration and to restore the land to agricultural best and most versatile quality.
Aggregate Industries has had so much time – more than enough time, most reasonable people would think – to sort these things out. What is the point of statutory consultees providing response after response if Aggregate Industries just ignores them?
