AI fails to appease DCC’s landscape officer over plans for 27m high asphalt plant

Last year, we posted about Aggregate Industries’ plans for a new asphalt plant at Hillhead, how planning application DCC/4189/2020 sought permission to build a 27m high asphalt plant – taller than 6 double decker buses – in an elevated position overlooking the Culm Valley, and how Devon County Council’s Landscape Officer concluded the application was "contrary to relevant landscape policies [providing] grounds for refusal". 

This conclusion was based on Aggregate Industries’ Landscape and Visual Impact Assessment. The Landscape Officer had suggested:

The applicant should be given opportunity to provide... additional views and visualisations as a LVIA addendum for the benefit of decision-makers.

Photos should be taken in winter when trees are bare - to show worst case visibility. 

An addendum of additional views was subsequently provided. Aggregate Industries’ consultant argued: 

Whilst there would undoubtedly be adverse effects on the quality of some rural views, these will be not so great as to cause unacceptable levels of harm on visual amenity or landscape character.  

Devon County Council’s Landscape Officer has now responded to this document, saying:

It is not appropriate for the LVIA assessor to state whether the effects are acceptable - this is a matter for decision makers when weighing the benefits against the harm in the planning balance.

The Landscape Officer concludes that the proposal is still contrary to local plan policies: 

the development could not be fully integrated into the landscape without the upper parts of the development, including the stack and plume emissions, presenting an incongruous industrial intrusion onto rural skylines rising above surrounding mature woodland as perceived in numerous views within the Culm Valley Lowlands. Such effects are understated in the LVIA and would, in my opinion be significant as the development would extend the visual influence of industrial development at the site to a far greater area than is the case with the existing development, and would detract from, rather than conserve and enhance, the rural agricultural character of the Culm Valley Lowlands and its valued scenic quality as a gateway into Devon. The proposals would not make a positive contribution to the local landscape character. I therefore consider that the proposals are contrary to policy M18 and M20 of the Devon Minerals Plan and Policy DM1 of the Mid Devon Local Plan. Whether the proposed mitigation reduces adverse effects to acceptable levels as required through policy M18 is a matter for decision-makers.

  

The Officer references Devon’s Landscape Character Assessment, which describes the Culm Valley Lowlands as:

A very important ‘gateway’ into Devon for people arriving by car on the M5 and A38, and also by train. 

The DLCA should: 

Protect and enhance the characteristic ‘patchwork’ landscape, particularly where it forms a ‘gateway’ into Devon from the M5, A38 and railway line.

The Landscape Officer says: 

In my opinion, the proposals are inconsistent with these LCA guidelines and could not be accommodated without harming or eroding the special qualities and distinctive characteristics and valued features of the landscape influenced by the proposals. 

The application will come before Devon County Council’s DMC on 21 April, after Aggregate Industries – in contrast to its 6-year application for Straitgate Farm – sought an early determination:  

A delay beyond April could result in us losing the opportunity of securing this site from Viridor which, being located adjacent to existing mineral workings and future allocations in the Devon Minerals Plan with excellent access onto the A38 and M5, we believe to be an excellent long-term location for a new asphalt plant to serve this part of Devon... 

We consider that the opportunity to acquire the Broadpath Site for a replacement asphalt plant is of strategic importance both to Aggregate Industries and the local community as it will enable existing asphalt production to be relocated from Westleigh Quarry and therefore respectfully request that this application is determined as soon as possible.

AI’s proposed 27m high asphalt plant at Hillhead is ‘contrary to landscape policies & grounds for refusal’

Earlier this year, we posted how Aggregate Industries proposed a new asphalt plant at Hillhead, how planning application DCC/4189/2020 sought to build a 24m high asphalt plant with a 27m high exhaust stack at an elevated position of 141m AOD. The plant and exhaust stack would be visible for miles around; 27m is more than the combined height of 6 double decker buses.

Here’s the predicted Zone of Significant Visibility; brown denotes areas of High Visibility.

Devon County Council’s Landscape Officer has now concluded that the application is "contrary to relevant landscape policies" providing "grounds for refusal": 

The proposed asphalt building, stack and plume of emissions together with the lighting and noise emissions from 24-hour operation are likely to erode the tranquillity and distinctive rural agricultural character of the Lower rolling farmed and settled valley slopes (LCT3B) of the Culm Valley Lowlands (DCA). The proposed taller elements would interrupt the undeveloped skyline in many rural views, introducing an incongruous industrial element that would extend the visual influence of modern development at the site to a far greater area than is the case with the existing development. The nature and operation of the proposed development would not enhance or complement the character of the area and would detract from the quality of rural views enjoyed by a considerable number of people in the area as indicated by the ‘Zones of Significant Visibility’ in the LVIA… I therefore consider that the proposals would have a significant and adverse effect on the special qualities, distinctive characteristics of the landscape, and visual impacts could not be mitigated to acceptable levels within a reasonable period, therefore contrary to Policy M18 of the Devon Minerals Plan.

AI proposes new asphalt plant at Hillhead – with 27m hilltop smokestack

Whilst the application to quarry Straitgate Farm has been fast asleep in the 'too difficult tray' this year, Aggregate Industries has deemed some planning applications worthy of attention.

One that the company has been busy with during lockdown is DCC/4189/2020 for a new asphalt plant at Hillhead Quarry, near Uffculme, at the former In-vessel Composting facility near the Broadpath landfill site. This would replace the asphalt plant at Westleigh Quarry near Burlescombe, which would in time be decommissioned. The application was submitted to Devon County Council this month, and is open for comments until 4 September.

We have posted about Westleigh Quarry before. This is what the site looks like in 2020.

Westleigh Quarry has attracted a multitude of complaints in the past: of HGVs speeding past the primary school, of a failure to control dust emissions, of bully-boy tactics, of non-compliance with planning conditions and Section 106 agreements, and of night-time HGV movements.

The site was the subject of a Devon County Council consultation, Responding to community concerns, following the findings of a community survey in 2014, with "movement of the asphalt production plant" the top suggestion.

Aggregate Industries now proposes to close the asphalt plant at Westleigh and build a replacement at Hillhead. However, as the Supporting Statement makes clear, this is not because of some new found concern for the well-being of local residents:

The existing Westleigh Asphalt Plant is coming to the end of its operational life and is located on top of permitted reserves within the quarry. It therefore needs to be replaced and a new site found as there is no alternative location available within the quarry. 3.3

...the proposed development at Broadpath prevents a significant amount of mineral being sterilised at Westleigh Quarry. 4.19

It is a development that would however be welcomed by many:

A significant benefit of relocating the asphalt plant from Westleigh is that it will remove the need for night-time vehicle movements through the villages of Canonsleigh and Burlescombe. 3.3

As for a ready supply of material:

The application site is located in close proximity to the active Hillhead sand and gravel quarry which means there is a long term supply of suitable sand for the asphalt process on its doorstep. 1.4

The plant would operate 24 hours a day, seven days a week, and "generate approximately 108 HGV movements per day". There would however be another cost. The main asphalt plant tower would be 24m high and the exhaust stack 27m:

Given the site’s elevated position of 141m AOD, there would be a visual impact on the surrounding landscape; 27m is more than the combined height of 6 double decker buses.

Aggregate Industries' consultants concede:

The most significant components of proposed development in terms of landscape and visual effects relate to the massing and height of plant. 6.46

Here’s the predicted Zone of Significant Visibility; brown denotes areas of High Visibility.

It’s a shocker. The plant and exhaust stack would be visible for miles around.

There is, of course, no historical precedent for putting smokestacks on hilltop positions in Devon, as Aggregate Industries' consultants also concede:

The site falls within the County ‘Culm Valley Lowlands County Character Area’ and landscape character type 3B: ‘Lower Rolling Farmed and Settled Valley Slopes.’ This is a well-wooded landscape with a pastoral character and distant views with no or little development on top of hills. 7.2

The proposal is another example of land not being restored as originally intended:

In the absence of proposed development and under the existing consent the existing facility will be restored to agricultural use on the final restoration of the Broadpath landfill operation, anticipated to occur at the end of 2027. 6.44

Emissions from the 27m smokestack have yet to be addressed:

The assessment excludes potential effects associated with emissions from the proposed exhaust stack. The nature of the emissions and the climatic conditions where they may become visually significant are not known at the time of writing. 6.27

Should planning permission be granted, the asphalt plant will require an Environmental Permit issued by the Environment Agency. The permit covers emissions and odour. Conditions in the permit also control particulate emission from stockpiles, conveyor belts and hard surfaced roads, and puts in place controls which must be complied with by the site. 5.22

On "Climate Change and Sustainability", consultants claim:

The proposed plant will offer improved environmental performance and energy efficiency compared to the Westleigh Quarry plant which is circa 45 years in age. 5.29

Operational constraints at Westleigh Quarry currently prevent the use of Liquefied Natural Gas (LNG) in the asphalt plant and therefore kerosene is used. LNG is considered a cleaner fuel in terms of CO2 emissions. There are no such constraints with the proposed plant at Broadpath and therefore cleaner fuels could be used subject to a further planning application for the necessary infrastructure. 5.30

But what chance – "subject to a further planning application" – is there of Aggregate Industries employing these cleaner fuels? Is it just something to put against the climate change heading, to tick a box, to make it look as though you care?

Because in 2013, Aggregate Industries launched planning application DCC/3586/2013 for the "Installation of a Liquefied Natural Gas storage container and ancillary operating equipment associated with the existing asphalt coating plant at Westleigh Quarry." There were clearly no "operational constraints at Westleigh Quarry" then, and the company secured consent in 2014. At the time, Aggregate Industries claimed:

The planning application proposes a new lower carbon solution for the operation of the existing burner at the asphalt plant, and would be located in a well screened location adjacent to the existing asphalt plant.

For whatever reason, real or imagined, the planning application was not implemented, the carbon savings were not made, and the permission expired in 2017. This was despite all the back-slapping in 2015 when LNG was introduced at another site nearby:

Colemans Quarry becomes the first #asphalt plant in the UK to be powered by #LNG https://t.co/VBM1B21lpI pic.twitter.com/vPfyVjB3xi

— Aggregate Industries (@AggregateUK) December 7, 2015

The plant manager at Colemans Quarry said:

We made the switch to LNG because it is a cleaner source of energy.

We were previously using kerosene, but LNG is a more cost-effective product to burn. It also produces a lot less carbon, and reducing our carbon footprint is very important for Aggregate Industries.

Calor, the LNG supplier, claimed:

As well as substantially cutting fuel costs, the project has reduced the amount of CO2 emitted per tonne of asphalt produced at the site by 17%. This cuts Aggregate Industries’ annual emissions by 1,800 tonnes.

You would think that with such benefits Aggregate Industries would want to install LNG at its other asphalt plants. After all, we are in a climate emergency and the company claims:

We're determined to reduce our #emissions per tonne by improving the #energy efficiency of our production facilities. To view our 2020 #climate targets, head on over to our website 👉 https://t.co/zAqrcHgcwz pic.twitter.com/b0x0xTTmLO

— Aggregate Industries (@AggregateUK) January 11, 2019

But since 2015, Aggregate Industries has made no more announcements about switching to LNG. When the company opened its new £3.5m asphalt plant in Godmanchester in 2018 there was no mention of using a "cleaner source of energy".

We’ve opened a new £3.5 million #asphalt plant in #Godmanchester, exclusively dedicated to supplying the A14 #Cambridge to #Huntingdon improvement scheme, England’s largest road project 🛣 https://t.co/cShgQDKdTi pic.twitter.com/3cmJy9Osf0

— Aggregate Industries (@AggregateUK) August 23, 2018

Clearly, "reducing our carbon footprint" has become less important for Aggregate Industries.

So. What chance of employing LNG at Hillhead at a later date – if it's not being specified now?

Not very much. But when you want to win permission to put a smokestack almost the height of the The Kelpies in Falkirk on top of a Devon hill overlooking the beautiful Culm Valley, you’re obviously prepared to say anything.

‘Court of Appeal overturns green belt quarry extension approval’

... according to an article in Planning Resource:

A planning approval for the extension of a quarry in the North Yorkshire green belt has been overturned at the Court of Appeal, after a judge ruled that planners had misinterpreted green belt policy with regards to the scheme's visual impact.

At the Appeal Court, Lord Justice Lindblom, said a senior council officer had "misunderstood" national planning policies on the preservation of the green belt and given "defective" advice to the council's planning committee.

Lord Justice Lindblom said he had been left with the "troubling impression" that national policy had been misunderstood and misapplied. 

The officer had erred in concluding that, because the development would not involve construction of new buildings, the openness of the green belt would not be harmed. 

The visual impact of the scheme was as important as its "spatial" effects and the officer had failed to consider what the impact of the proposals would be "in the eyes of the viewer". 

The quarry extension would result in a "permanent change to the character of the landscape" and "long distance views would be cut off" by earth bunds put in place and trees planted to screen the site.

Revised junction plan put forward by Group eliminates pedestrian & HGV conflict

Whilst the Group maintains its objection to mineral development at Straitgate Farm, we are not averse to pointing out improvements in the proposals - where improvements can be seen; Aggregate Industries adopted a suggestion we proposed last year to modify the extraction boundary and reduce hedgerow loss by 500m.

The current site access plan can also be improved. That much is obvious. If the person who first put it together was subsequently found to have fabricated traffic numbers, then how much faith can local people have in his design?

AI's proposed access onto the B3174 Exeter Road for up to 200 HGVs a day centres on Birdcage Lane, the narrow lane on the right of the Street View above, much used by dog-walkers, joggers, ramblers and cyclists. The plans have been the subject of much concern and complaint - click site access label to see how much - particularly with regard to the potential impact on pedestrians and school children, particularly knowing that so many pedestrians are killed or injured in collisions with HGVs.

Many representations and objections have been made to DCC on this matter, including from solicitors Foot Anstey and the highways consultants Vectos. The proposal would also damage third party property. Solicitors warned DCC that:

any development which may cause such damage [to Tree H] will be resisted through available legal means, which may include an application for an injunction and/or an action for damages. Any such action would be brought against both the applicant and the Council (in its capacity as the local highways authority), and may also include a private prosecution for criminal damage.

The original design has since been passed to another set of consultants. It has been through a number of revisions - the latest revision of which has the inclusion of a narrow gravel path. AI proposed this path to be gravel in an effort to protect itself and the Council from the legal action above, but Vectos explained why such a path could not be implemented nor protect the tree. Solicitors warned DCC again:

In relation to the proposed drawing provided by the applicant, it is clear that it creates even more problems.

With each new attempt to address a problem, the applicant merely creates new ones, demonstrating that the scheme is inherently poorly conceived.

Despite this, DCC Highways appeared content with the gravel path proposal, and maintained in correspondence with a county councillor:

There are plenty of historical locations in Devon where a gravelled surfaces [sic] adjacent to the road are used and are safe for pedestrians.

When asked to provide examples of these locations, DCC Highways answered:

The Ex Estuary Trail [sic] and the Tarka Trail has areas where there is rolled stone finish to the surface.

It’s not clear if either of these locations have gravelled surfaces adjacent to the road - but hey, if Birdcage Lane could be viewed in the same light as the Exe Estuary and Tarka Trails, who cares? Local tourist businesses would surely welcome the area becoming a magnet for ramblers, cyclists and the like!

Nevertheless, with all the inherent problems in the existing access scheme, a number of proposals have been made to the Group, including one to the west of Birdcage Lane (i.e. to the left of the lane in the Street View above), that was then put to Vectos for scrutiny. Highways consultants verified that the proposal was feasible, had the required visibility, and offered safety advantages over the existing plan. Specifically it would:

• eliminate all interaction between HGVs and pedestrians (including school children)

• make it easier for vehicles exiting Toadpit Lane onto the B3174 by avoiding conflict with HGVs

• save three veteran oak trees and a length of ancient hedgerow

• reduce the visual impact - including from the AONB - by retaining more site screening

Furthermore, the area would also be easier to restore post extraction, and remove any conflict with PROWs and third party farm gateways. As an aside, it would also protect DCC from any legal action in relation to Tree H, and even be cheaper for AI.

Vectos’s letter has been sent to DCC. It looks like a no-brainer.

Both DCC and AI would obviously be open to criticism - or worse - if this alternative were not properly considered, and a serious accident were to result from the current design and/or the failure to separate HGVs and pedestrians.

And the impact on the AONB - if all these trees were removed?

This is the view from Little Straitgate; the East Devon AONB can be glimpsed in the background.

Aggregate Industries' site access plans cut through the middle of the trees shown in the photo. It is likely that the majority of trees seen here would be felled, including those three tall oaks. AI calls these trees F, G and H; Tree H belongs to a third party who objects to the proposal:

The “no dig” construction means that the works will potentially interfere with the root protection areas of Trees F, G and H and some of G15A as illustrated by Drawing R22/L/3-3-005 and it is likely they will be damaged by the development and need to be felled. 4.1

Whilst AI’s plans would afford beautiful unobstructed views towards the East Hill strips, they would also afford less welcome unobstructed views into Straitgate - and the 5m high storage mounds detailed on the plans below - from the AONB.

The visual impact of these trees coming down on views from the AONB has not been assessed.

EDDC’s landscape response recommends refusal

EDDC’s Landscape Architect has recommended that Aggregate Industries’ planning application to quarry Straitgate Farm be refused.

...the site helps to shape the setting of the East Devon AONB... the development would permanently alter the landform of a locally distinctive ridge... the proposals for how the site will be worked offer little mitigation for impacts on the long distance views from East Hill.

EDDC also points out that "topsoil should not be stored in mounds greater than 2m otherwise the chemical composition of the soil will alter". AI wants to store top soil in mounds 3m high; although, even at this height, the company has not allowed enough land to do this, as back-of-the-envelope calculations for our submission show.

EDDC concludes:

Currently the submitted LVIA as part of the Environmental Statement does not sufficiently address... How the site helps to create the setting of the East Devon AONB [etc]... it is recommended that planning permission is refused.

1968 revisited

A reminder of some of the statements that came out of the public inquiry in 1968, following the first application to quarry Straitgate Farm, which are as pertinent today as they were then:

The county surveyor raises no objection to the proposals in principle, but on planning grounds the scenic B3180 is envisaged as being unsuitable for industrial traffic… 232

The existing Blackhill quarry workings are a disfigurement, making a prominent scar when seen from vantage points across the open land... 259 The National Parks Commission

The quarry represents an ugly feature in the panoramic view from the most popular part of the commons area, at Woodbury Castle… 283 Exmouth Urban District Council

Once it is admitted that the damage caused by the proposed development is likely to be substantial, permission should only be granted if the need cannot be met elsewhere, where less damage would be caused… 351 Devon River Authority

The Minister is anxious to safeguard such valuable agricultural land so far as possible and I am directed to advise that in his opinion there is the strongest possible objection to the proposed development on agricultural grounds. 359 Ministry of Agriculture, Fisheries & Food

A MAFF representative said "The quality of the land is such that in a rapidly expanding urban society its retention is more than ever necessary to maintain production from a fast contracting acreage", and that the application affecting this farm gave every indication of being only the "thin edge of the wedge". Express & Echo, 18 July 1968.

Is SLR asking local people to suspend all rational thought?

SLR, Aggregate Industries' consultants, tells DCC, statutory consultees and local people that:

The [Environmental Statement] demonstrates that there would be no unacceptable adverse impacts on the natural and historic environment, local amenity or human health 4.18

[The] review of national and local planning policy has demonstrated that the proposed development broadly accords with and supports planning policy and sustainable development. It has not identified any instances where planning policy is not complied with... planning balance is therefore weighted in favour of a positive determination 4.101

... incredible and delusory statements for a 100 acre greenfield quarry and unsustainable 1.2 million mile HGV haulage operation through an AONB and internationally designated wildlife conservation site. It even has the nerve to say:

Arguably some aspects of the application site would be improved as a result of the proposed development 6.102

... when Aggregate Industries is unable to demonstrate a successfully finished and restored quarry anywhere in East or Mid Devon.

There are a multitude of misrepresentations in AI's applications; here's just one:

Views from within this part of the AONB [East Hill] are actually quite restricted... illustrated by Reference Photograph ‘R3’ 6.189 ...the colour of exposed soils / overburden would not be dissimilar to the muted brown tone seen over other field compartments within the view 6.193

... 'forgetting', of course, the view points from car parks and picnic spots at White Cross on East Hill, and the impact that AI's quarry at Venn Ottery is already making. 

And on 'need', SLR would rather we went back in time:

The annual production of sand and gravel in the period from 2001 to 2009 averaged 0.8 million tonnes. 5.23 There is an identified shortfall in supply of sand and gravel of some 6 million tonnes, minimum, and an ongoing need for 0.8 million tonnes per year to meet current, established demand. 5.33

But it's not 2009, it's 2015 and DCC has production figures up to the end of 2013, figures that show that the last 10 years averaged 0.61 million tonnes per year, and the last 5 years (the method directed in the existing Minerals Plan MP20) averaged 0.47 million tonnes. Devon has a sand and gravel landbank of 8.53 million tonnes that would last almost 14 years at the 10 year rate, over 18 years at the 5 year rate.

SLR's claim for an 'ongoing need for 0.8 million tonnes' has about as much integrity as its claims on tree-planting or great crested newts. Does SLR think we were all born yesterday?

Straitgate Farm - and the visual impact from East Hill AONB

Does AONB mean anything?

This is the view that visitors to East Devon's AONB currently enjoy, looking from East Hill - AONB - towards Aggregate Industries' workings at Venn Ottery - AONB - with Tipton St John in the foreground.

More delays

Aggregate Industries' planning applications to quarry Straitgate Farm and process the as-dug sand and gravel eight miles away on Woodbury Common will not now be validated and advertised until week commencing 25 May at the earliest; DCC has had to request that consultants SLR amend significant amounts of documentation and supply additional plans in the interests of clarity.

Visual impact of AI's Woodbury Common factory at Blackhill from Woodbury Castle

And while we’re on the subject of assurances made by AI

Apart from the impact of 44-tonne HGVs pounding up and down the B3180, one of the main issues of contention in Aggregate Industries' 2010 application to process Venn Ottery material at Blackhill Quarry was the height and extent of its stockpiles - the ones sitting in the middle of an AONB, SPA, SAC, SSSI.

We have already established that although DCC recognised that "mineral developments in AONBs must demonstrate that they are in the public interest, and that there is an overriding national need for the development which cannot be reasonably met in some other way”, it chose to ignore an undesignated industrial site two miles closer, for no reason other than the profits of a Swiss multinational.

But it was East Devon AONB that raised the issue of Blackhill's stockpiles, and DCC admitted:

The major impact of the proposal is the visibility of the stockpile areas, particularly for viewpoints from the East Devon Way and other public rights of way. Currently Blackhill Quarry is required to be restored by March 2012, and this proposal would effectively delay the restoration of this part of the site by up to 6 years. 6.13

AI assured the Council that it had a plan:

In terms of the visual impact, the Applicant has agreed to produce an annual stocking plan for Blackhill, with an aim to reducing the stocking areas and hence the visual impacts. In the event that planning permission is granted this could be secured by planning condition. 6.19

A planning condition was indeed added and formed part of the proposal that councillors voted upon:

9. Prior to the commencement of the development the operator shall submit a detailed stocking plan that shall include measures to reduce the quantities of stock held on the site and provide a height limit to the stockpiles. The stocking plan shall be reviewed annually and the development should be carried out in strict accordance with the agreed details, or such alternative details that may and subsequently be agreed in writing by the Mineral Planning Authority. REASON: In the interests of the visual amenity of the area.

Which all sounds well and good. But no "detailed stocking plan" was ever submitted by AI, or asked for by DCC. The development was not carried out "in strict accordance" with any agreed stocking details. The "visual amenity" of the AONB continued to be impacted.

DCC forgot to put Condition 9 on the formal notice. And AI conveniently 'forgot' all about it too.

Something to bear in mind when AI tells people "...we’ve been operating quarries in East Devon for over half a century and working in partnership with the surrounding communities every step of the way." Something to bear in mind when AI says it has a plan. Something to bear in mind when AI asks people later this year to trust it again, with 5 more years of delayed restoration for Woodbury Common.

Us and them… continued

The decision by EDDC to refuse planning permission for a single dwelling on a site bordering the land at Straitgate Farm last year, referred to in the post titled "Us and them", was recently appealed.

There’s a shortage of housing, so much so that the government is even thinking of loosening planning rules for building in our National Parks. And yet, even though there had previously been a house on the site, the Planning Inspector agreed with EDDC and refused the appeal.

Let’s remind ourselves that it is here that Aggregate Industries expect to get planning permission for a multi-million tonne sand and gravel quarry - one of the more damaging developments open countryside can face.

What message does this send? The application for a traditional single dwelling wasn’t turned down because it would sterilise any mineral reserves. The appeal was refused because a) it was not considered sustainable development, and b) due to the impact on the countryside location. In fact, the dwelling would introduce:

a bulk of built form that would harm views of the surrounding open countryside [that would have] an adverse effect on the character and appearance of the countryside location

How would AI’s application for a quarry in the same location be judged by this planning inspector? On sustainable development - with each load of as-dug material being processed seven miles away on Woodbury Common SSSI, SPA & SAC? On impact on countryside - in full glare of East Devon AONB?

On top of a hill overlooking Ottery St Mary... tree planting around a potential quarry

If Aggregate Industries had no intention of waiting for Devon’s new Minerals Plan before deciding where to put its latest quarry, no intention of waiting for planning permission before deciding the boundaries, then why on earth did it not plant these saplings 20 years ago, when they might have made some difference to the people living a short distance away, some difference to the hedgerow wildlife it plans to displace or destroy? Or is this 'readying of the site' just a form of intimidation, a big quarry foot in the door - "we’re on our way, and no-one's going to stop us"?

Many local people might rightly wonder what the point of Devon's Minerals Plan is - to them it all looks like a done deal; that it's the minerals company that decides where to dig, not the Council, not the Environment Agency, not Natural England and definitely not local people.

For the avoidance of doubt, it's the green agricultural land - about 86 acres - on the left of the fencing in the photograph and beyond, on the slopes overlooking Ottery, that AI wants to take for quarrying; a more visually intrusive position, opposite East Hill AONB, would be hard to find.

From one side of the Otter Valley to the other

Or from one part of the East Devon AONB towards another. It is a captivating sight - looking from White Cross on East Hill out across the Otter Valley. This view is towards Venn Ottery Common, with Tipton St John and its church in the foreground. The photograph is only taken with a phone, but, even 5km away, Aggregate Industries' contribution to the scene is clear to see. AI (or English China Clays as then) was given permission to quarry on Venn Ottery Hill in 1965, two years after the AONB was first designated. The company is only now fully working the deposit, and this is the scar being created. It is what AI would call a small quarry. Any quarry at Straitgate Farm would be bigger, and therefore even more visible from East Hill and the AONB.