It really is shocking – embarrassing even – that after all these years, the Environment Agency plainly still can’t get its head around Aggregate Industries’ plans to quarry Straitgate Farm.
In its latest response, which continues to offer no objection, the Environment Agency seeks clarification on the central and most fundamental aspect of the proposal:
we request clarification as to whether the February 2021 Maximum Winter Water Table (MWWT) contours are the same as the contours of the intended quarry base.
Firstly, many will wonder how, without knowing the elevation of the base of the proposed quarry, the Agency could possibly be in a position to produce a reliable response on the impact to groundwater.
Secondly, by seeking such clarification, the Environment Agency provides ample evidence to show it isn’t fully familiar with Aggregate Industries' planning application, because such information is already contained in a number of documents, such as:
In the Non-Technical Summary, 3.8: "The depth of working is set by the level of the maximum winter water table."In the Supporting Statement, 2.4.7: "The resource declared assumes a working base that coincides with, and never drops below the Maximum Winter Water Table (MWWT) modelled by hydrogeological specialists AMEC Foster Wheeler following extensive monitoring and analysis since January 2013."In the Hydrogeology Assessment, 1.1.3: "Mineral will be worked down to a level defined by the maximum winter water level and then a layer of overburden replaced."In the Hydrogeology/Drainage Reg 22 responses, 2.2.1: "...the Maximum Winter Water Table (MWWT) used as the basis of extraction models,..."; 2.2.8: “... derived from the MWWT (i.e. the final proposed depth of working)..."; 2.4.6: "The quarry will be worked dry and down to a level defined by the maximum winter water level...".In the Hydrogeology/Drainage Reg 22 response, Appendix C: "... will be extracted to the MWWT."In the Resource Assessment, February 2021, 2.1, "The MWWT will ultimately form the base of the workable deposit, and any variation will impact the potential resource."In Aggregate Industries' letter, April 2021: "In respect of the revised Mineral Resource Assessment based on the latest modelling of the Maximum Winter Water Table the revised figure of the reserve is still over 1 Million saleable tonnes...".
But it’s not only the depth of the proposed quarry that the Environment Agency isn’t clear on, it’s also the extent – advising Devon County Council:
we suggest that your authority may wish to consider whether you want to see an updated plan of the extent of the extraction area (taking into account the near-surface MWWT contours in the north- east part of the proposed excavation area) prior to determination.
However, if the Environment Agency had been up to speed, they would know that Devon County Council had already asked Aggregate Industries this very question, and the company argued that despite such near-surface MWWT contours "The extraction area... remains unchanged."
The Environment Agency isn’t clear on the "workability" of the S106 either, happy to continue to offer Aggregate Industries "no objection" whilst not knowing how or even if alternative water supplies could be provided – to more than 100 people, livestock farms, businesses, Grade I listed Cadhay and its mediaeval fishponds, wetland habitats in ancient woodlands – advising the Council:
We recommend that your authority obtains legal opinion on the workability of the proposed S106 agreement.
The Environment Agency was also told about the threat to groundwater in the proposed overburden areas, but, despite being the guardians of our precious groundwater, not a mention in the response.
And yet, despite these failings, and despite still seeking clarification on the extent and depth of the proposed quarry, the Environment Agency feels sufficiently competent to entirely dismiss all the warnings from Professor Brassington, an eminent authority in the field.
How on earth could Devon County Council possibly rely on the Environment Agency’s conclusions when they are so clearly flawed?
