Devon County Council has now started another public consultation on Aggregate Industries’ planning application to quarry Straitgate Farm, this time on the company’s "final response" submitted last week. This follows the consultation in April on the company’s "final submission of additional information".
This latest consultation runs until 31 July for those wishing to make "any additional comment" – particularly on the "final response", supplied in relation to hydrogeology, flooding and soils. This means the application will not now be determined before the next DMC meeting of 22 September 2021.
Devon County Council has termed this latest response as providing clarification. In reality, it clarifies nothing, except to demonstrate that Aggregate Industries still hasn’t got a clue what it’s doing.
We have recently posted about its contents, here, here and here. The response to concerns raised by the Devon Flood Risk Team and Natural England, on flooding and soils, is frankly laughable; a derisory, dismissive letter written by the company’s planning manager, not the relevant experts – which clearly fails to address the concerns that have been raised by these statutory consultees.
Specifically, Aggregate Industries refused to show how infiltration basins could be accommodated within the extraction site – taking into account the elevated groundwater levels recorded. Aggregate Industries refused to show how the separate subsoils could be stored, and further chose to forget all about the topsoils and subsoils under the storage piles, for which space must also be found.
The hydrogeology response to Professor Brassington following this meeting was little better, failing to provide any references – other than to its own – to back up its assertions that groundwater speeds through the unsaturated zone in a matter of days having little time for rock/water interactions. Prof Brassington – who has provided multiple independent references to substantiate his claims – says movement of water through the unsaturated zone is likely to take years, and permanently removing the unsaturated zone would have an irreversible impact on the pH of surrounding water supplies:
According to Wang et al (2012) the unsaturated zone velocity for the Sherwood Sandstone Group falls in the range 0.6 – 2.3 m/year with a mean of 1.06 m/year (these values were summarized by Chilton and Foster (1991)). The values for unsaturated zone flow rates are several orders of magnitude (three to five) lower than flow velocities in the saturated zone.
What evidence do Aggregate Industries' consultants have? Apparently, Straitgate is riddled with fractures and fissures. The problem? Test pits didn’t reveal any. Nor do the cliffs showing the same geology at Budleigh Salterton. Consultants have therefore resorted to the old adage "absence of evidence is not equal to evidence of absence". It’s a phrase that’s often wheeled out "to silence doubters and critics":
The "absence of evidence..." argument in itself is fine; in the hands of promoters of nonsense, however, it all too often turns into a prime example of apparently plausible yet fundamentally flawed logic which can mislead us all.
There’s no evidence that little green men are absent from Straitgate either, but that does not mean we should seriously consider their existence. As Prof Brassington says:
The lack of cement means that the rock cannot be fractured as the adjacent uncemented particles would fall into any fractures present.
Here’s one of the test pits that Aggregate Industries’ consultants claim is only 2-3m deep. It was in fact used to recover BSPB material for testing, so had to be 6-7m deep. Can anybody see any fractures? No, neither could Prof Brassington.
In Amec Foster Wheeler (2017b) a series of photographs are published of the trial pits... I have examined them most carefully and find no evidence for any fractures or fissures.
What else? Where do we start? Many of Aggregate Industries' documents are now obviously out of date. The Transport Assessment will be more than 3 years old, and is riddled with errors. The Flood Risk Assessment is more than 4 years old, and has not been informed by the elevated groundwater levels recorded. The wildlife surveys are older than that. The cattle crossing issue has not been resolved; EDDC has now lodged an objection based on that issue. Highways England is still awaiting clarification and assurances. Devon Garden Trust, a statutory consultee, has objected. It is unknown how alternative water supplies would be provided – including to the listed mediaeval fishponds at Cadhay – in the event of problems. There’s no recoverable resource in parts of the site, and insufficient groundwater movement to allow the company’s untested seasonal working scheme to work. The list goes on. Have you ever seen such a mess?
And yet there are fundamental issues that would need to be resolved, not least on the model of the water table, on flooding, infiltration areas, on inadequate culverts, post restoration drainage patterns, drinking water supplies, on the safe functioning of the B3174, the unsustainable haulage emissions, the restoration of best and most versatile agricultural land, the working drawings that don’t work, even the schoolchildren waiting for buses and the unenforceable, unworkable HGV embargo.
Comments on this final final submission, or any other part of the application, should be made to Devon County Council, either online or by email to planning@devon.gov.uk including name, address and the reference number DCC/3944/2017.
