Mineral extraction scheme causes birdstrike concerns at RAF Fairford

We have previously posted about RAF Fairford and the threat of birdstrikes from nearby mineral works.

French Air Force Mirage 2000 makes emergency landing at #RIAT15 #RAF Fairford after a bird strike. Landed safely pic.twitter.com/BB0n0b0pob

— Røbbø 🇬🇧🇨🇦 (@Ravenser) July 19, 2015

No wonder the MOD expressed concern over a nearby quarry proposal 21/0032/CWMAJM at the former RAF airfield at Down Ampney in the Cotswolds, 3 miles south west of RAF Fairford. 

Bid for new quarry raises concern for RAF Fairfoldhttps://t.co/Egx6Okarua

— Greatest Hits Radio Gloucester (@GHRGloucester) September 23, 2023

The MOD wrote: 

The development proposed entails the stripping of topsoil, the extraction, working and storage of minerals, and the phased restoration of the site. 

Each of these activities have the potential to create an environment that would be attractive to those large and/or flocking bird species hazardous to aviation safety. 

The applicant has acknowledged that aircraft passing close to the application site, approaching or departing RAF Fairford, are likely to be at altitudes of less than 1,000ft above ground level and would be within the range of altitudes where 90% of birdstrike events take place. 

The applicant and the MOD have conducted pre-application discussions. Through these discussions the MOD has made clear that restoration of the site which results in the creation of open water would be unacceptable as those waterbodies would likely provide an environment attractive to those large and/or flocking bird species hazardous to aviation.

Despite the MOD's concerns, officers recommended approving the scheme, to extract 6.5 million tonnes of sand and gravel over 13 years with a phased restoration scheme using imported infill, and, last month, the proposal was given the green light by Gloucestershire County Council, 9 votes for, 2 against – subject to the prior completion of a S106 planning obligation to secure the implementation of a Wildlife Hazard Management Plan. 

Here in East Devon, aircraft also fly less than 1000 ft above Straitgate Farm on their landing descent to Exeter Airport.

For Aggregate Industries' scheme at Straitgate, a Wildlife Hazard Management Plan was also stipulated, with planning inspectors conditioning that: 

No water body shall be created within the site

Of course, where Straitgate differs to the Cotswolds scheme is that restoration will not involve imported infill; Aggregate Industries will just dig a hole, and leave it. 

We have previously posted – given that water bodies are intended at Straitgate – that Aggregate Industries’ plans for the site are incompatible with the Inspectors’ planning conditions. 

This is even more concerning given the scale of Aggregate Industries’ (unintended) ponding problem at the company's nearby quarry at Hillhead.

Highways England to revisit Straitgate application

After Has Highways 'thrown a curve ball'? back in 2015, Aggregate Industries produced some cross sections - see below - so that Highways England could "fully understand" the impact of any quarrying directly next to the A30. Highways England originally wanted to see "that the full depth of the quarry excavation would not be lower than the A30 carriageway", but settled for a series of planning conditions, which were repeated in the most recent response:

The maximum extent of quarry workings adjacent to the A30 trunk road boundary shall not exceed that shown on drawing SF HWYS/1 and at all times a minimum buffer zone of 10m shall be maintained between the application boundary and the quarry workings.... Buttressing of extraction slopes shall be undertaken in line with the submitted plans with an agreed slope profile as shown on drawing SF HWYS/1... Reason: ...to protect the highway structural integrity and in the interest of the safe and efficient operation of the trunk road.

Last week, however, Highways England said they would revisit the application.

There have been quarry face slippages at AI's Manor Farm sand and gravel quarry in Kempsford, Gloucestershire. In an application to extend the quarry, the MOD was concerned about nearby landing lights for RAF Fairford. AI's consultants had said:

A 20m stand off to each lighting column will allow for a worst case situation where the quarry face could fail and cut back to an angle below the natural angle of repose (a gradient of approximately 1 in 3) and the face failure would not reach the base of the closest lighting pole. 1 in 3 is considered to be a stable slope in this type of material and 20m should therefore give the lights the protection required plus a safety margin beyond that. 10

The MOD was still concerned:

Although the extraction proposals incorporate stand-off zones to protect boundaries there are concerns that in some instances that these might not be adequate. A request to review these limits to prevent site stability problems during and post extraction is strongly recommended to avoid slippage problems already experienced from the current quarrying works. 6.29

and recommended the following condition:

Prior to the commencement of works the applicant shall submit a plan for the approval of the Mineral Planning Authority detailing how the adjoining MOD land and the retained land on which aircraft landing lights are located will be protected from collapse or slippage whilst extraction operations are undertaken and until restoration has been completed.

And what has AI proposed next to the A30 dual carriageway? Not 20m standoffs, but 10m. Not 1 in 3 slopes, but as steep as 1 in 0.5.

Miscellaneous

1. In case people have forgotten what Aggregate Industries said about Venn Ottery Quarry back in 2010:

We shall be putting back a lot more than we're taking away.

Local people will watch with interest to see how AI might manage that. In the meantime, when a sand and gravel quarry extension was recently recommended for approval in Gloucestershire:

Officers acknowledged that there appeared to be a lack of progressive restoration in the existing site and a condition was recommended to prevent the commencement of a new phase of extraction until the preceding one was infilled.

No guesses for which company was responsible for this 'lack of progressive restoration'.

2. In case there's any doubt, AI's Blackhill application is not to process some unique material of national significance; the sand and gravel could be processed at any industrial setting, not one located in an AONB and next to an SAC/SPA/SSSI. The NPPF says:

Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty which have the highest status of protection in relation to landscape and scenic beauty. Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

A number of recent planning cases have been identified that exemplify this: here, here, here and here. Here are two more:

a) Waste transfer operation incompatible with national park designation

The use of land within the New Forest national park in Hampshire for the processing of up to 20,000 tonnes of waste would be inconsistent with the cultural heritage of the area, an inspector concluded.

b) Need for unique stone leads to grant of permission for extension to Peak District quarry

Given the uniqueness of the product, the authority concluded that there were exceptional circumstances to allow the quarry in the national park.

3. In case the significance of higher quality agricultural land, and the proper investigation of alternatives, has been overlooked, a recent appeal for a solar farm found that:

an inspector placed significant weight on the loss of up to 15ha of grade 3a agricultural land... In the absence of a rigorous and convincing process to demonstrate that the use of higher-quality land was necessary, he concluded that the scheme's benefits did not outweigh this loss, even for a temporary period.

4. In case the matter of birdstrike has slipped from the radar, here's some recent news from Twitter; we have referred to RAF Fairford before:

French Air Force Mirage 2000 makes emergency landing at #RIAT15 #RAF Fairford after a bird strike. Landed safely

Thomas Cook flight headed for Egypt diverted back to Manchester after 'bird strike'

Birdstrike passenger jet cleared for takeoff suffers immediate engine problems

178 Med Gulls (incl 45 juvs), 6 LRP + 1 Green Sand at a gravel pit in the Avon Valley earlier today

A disappointing year

It’s been a disappointing year for those who care about the future of this area;

for those that care that Devon County Council is conspiring with a Swiss multinational cement conglomerate to seal the fate of Ottery St Mary and the surrounding area for generations to come;

for those that care that, despite a multitude of material planning constraints, the Aggregate Industries machine continues to move relentlessly towards the gates of its first target, Straitgate Farm.

Here are a few things we posted over the course of 2014:

AI is already marking out its quarry

Exeter Airport’s response on birdstrike fails to consider the complete picture
Hedgerows provide a natural flood defence
AI plans to grub up almost two miles of ancient hedgerows at Straitgate
Spot the difference - 49 acre lake vs. ephemeral pond?
Devon Minerals Plan delayed again
Devon sand and gravel production for 2013, down on 2012

AI's answer for the dormice - an 'escape route'

Now it's our turn to lobby Government - ‘there's no need for any more new quarries’

If Exeter Airport isn’t concerned about a quarry beneath its flightpath, it should be

Borehole central to proposed site sees 6 metre rise in groundwater levels during winter months

Devon Minerals Plan delayed again

The £6 million question

RAF Fairford... revisited

AI's 'confidential' meeting with DCC to discuss the future of Straitgate Farm

AI makes plans to process at Rockbeare

55 archaeology trenches confirm AI’s plans to limit quarrying to the western side of Straitgate

Archaeological evaluation begins... without a metal detector

Dormice and hedgerows - so where’s the enhanced compensatory habitat?

Settlement of Iron Age roundhouses at Straitgate Farm

List of issues for DCC's 'only showstopper-free site in East Devon' has only grown since 2012

And now signs of Roman settlement and ancient earthworks too

How much Roman archaeology has AI already destroyed at Straitgate Farm?

Straitgate planning application "in due course", confirms AI

Devon Minerals Plan delayed again

Straitgate’s not enough - AI wants more

More Straitgate Farm history comes to light...

2015 is likely to be a year when more help will be needed; AI is likely to be submitting its planning application, and DCC is likely to be consulting on, and formally submitting, its long-delayed Minerals Plan. Please spread the word to all those who may be able to assist in any way they can.

It is at least pleasing that readership of this blog and Twitter continues to grow. To all who read this, friend or foe, we wish you a Happy Christmas and Peaceful New Year.

RAF Fairford... revisited

We wrote about RAF Fairford last year. We said:

Aggregate Industries has assured us in the past that it's quite used to running quarry operations where there are airport safeguarding and birdstrike considerations. "Just look at RAF Fairford" we were told, where AI has nearby sand and gravel operations, as an example of how the company manages quarrying, water, aircraft and birds.

AI wanted to extend its Manor Farm Quarry near RAF Fairford, but stressed that:

due to the proximity of Fairford Airfield, water based restoration/after-use is not appropriate,

contrary to its plans for Straitgate Farm under Exeter Airport's flightpath, where it thinks water-based restoration would be appropriate.

Events at RAF Fairford this week, when a B2 Stealth Bomber hit a buzzard during its landing approach, underline just what's at stake and why the CAA and the MOD take the issue of birdstrike so seriously. The plane survived; the buzzard didn't. Cost of a B2? US$737 million - at 1997 prices.

RT @Sadlybrokeboy B2 #birdstrike taken at RAF Fairford yesterday, the moment a Buzzard and Stealth Bomber 'conflict' https://t.co/ogzq2vGD0O
— Straitgate Action Gp (@straitgateactgp) June 13, 2014

RAF Fairford

Aggregate Industries has assured us in the past that it's quite used to running quarry operations where there are airport safeguarding and birdstrike considerations. "Just look at RAF Fairford" we were told, where AI has nearby sand and gravel operations, as an example of how the company manages quarrying, water, aircraft and birds.

So we looked at RAF Fairford. Did AI have a point? If AI can quarry near RAF Fairford, surely it must be ok - at least on the birdstrike front - for it to quarry at Straitgate, under Exeter Airport's flightpath?

However, Fairford - home to the annual Royal International Air Tattoo but "currently a standby airfield and therefore not in everyday use" - does have its share of birdstrike concerns, made worse by Cotswold Water Park. Studies have been undertaken and "concerns by the MOD over bird strike at RAF Fairford have lead to the creation of a bird strike working group". Moreover, Wiltshire County Council, in proposing three sites for future sand and gravel quarrying around RAF Fairford, has birdstrike figuring highly, e.g. Cox's Farm "The critical need to reduce the risk of bird strike associated with air traffic at RAF Fairford is a key consideration for the working and restoration of the site".

So, the issue of birdstrike is not as benign for AI in the Cotswolds as we were lead to believe. More importantly, the AI spokesman had failed to tell the whole story about how AI works its Manor Farm Quarry, Kempsford, near RAF Fairford. This 2003 article, however, does:

In response to the RAF’s concerns over the possibility of birdstrikes, the quarry will be worked dry to minimize the amount of standing water and hence reduce the site’s attraction to waterfowl. With the water table lying just below ground surface, this involves perpetual pumping and the licensed discharge of around 7,000m³ of water a day from a newly created perimeter drainage ditch into the local Dudgrove brook. 

Final restoration at Manor Farm Quarry will be to agriculture utilizing a mix of backfilling to existing levels using silt and clay from the extraction process, together with low-level restoration for the remainder of the site. Low-level restoration will be achieved using the underlying Oxford Clay to create a sealed drainage basin which will be surcharged with site-generated subsoils and topsoils. A small pumping facility will be required to remove excessive rainfall from this basin.

In other words, to avoid creating new bird flight lines, Manor Farm will be worked dry and restored back to remain dry, in contrast with AI plans supplied for Straitgate that involve digging below the water table, and restoration that encourages water to pond along the eastern boundary.

Now AI wants to extend Manor Farm Quarry, but again, as this recent article makes clear, AI

will be restoring both quarry sites to agricultural land after work has taken place. If the land was left as a pool of water, the birds attracted to the area would affect the flight paths of the nearby RAF base.

So when, in AI's own words, "due to the proximity of Fairford Airfield, water based restoration/after-use is not appropriate", why does Aggregate Industries think that for Exeter Airport, an international airport carrying hundreds of thousands of passengers a year, water based restoration would be appropriate? Why does it think Exeter Airport would welcome ponding, "a priority wetland habitat" and an inherent increase in birdstrike risk directly under its flight path, for ever after?

That's simply reckless, and shows a complete absence of respect for Exeter Airport's safeguarding aspirations and the carriers and passengers who fly in and out every day.