Three farms wanted to build a lake to irrigate their crops

What could possibly be wrong with that? Well, Essex County Council (ECC) turned the planning application down, and earlier this month the subsequent appeal was also dismissed. Why? The small matter of 300,000 tonnes of sand and gravel 'spoils' that the farmers planned to send to a local quarry over the three to four year 'construction' period. Why is it relevant? The case has many similarities to here: need, farmland, alternatives, groundwater, ancient woodland.

ECC was concerned that the development would involve mineral extraction "from a non-preferred site and as the landbank in Essex is greater than seven years there is no identified national, regional or local need". The council was also concerned that it would "impact upon groundwater levels which could in turn harm a number of water features and private water abstractions", and that since the site was next to ancient woodland, designated a County Wildlife Site - as Cadhay Bog and Cadhay Wood - it could also "result in damage to European Protected Species".

At the appeal, the Planning Inspector seemed to think that the mineral extraction was not quite as ancillary as the farms claimed, since the minerals were to be extracted at a rate the local quarry could accept them. Even so, there's no crime in that - quarrying companies do that all the time. The Environment Agency had no objection, and the Inspector accepted that once the reservoir was built there was unlikely to be an impact on groundwater levels. There were HGV movements, but mainly along an internal haul road to minimise use of public roads. The proposal was not against local and national policies which encourage sustainable development, including the conservation of natural resources such as storing water in reservoirs and making good use of the mineral spoil rather than just dumping it. The impact on the landscape during construction would be set against the wildlife benefits of the scheme afterwards, and the Inspector conceded that the reservoir, were it not for the exportation of the minerals from the site, would in any case be permitted development "reasonably necessary for the purposes of agriculture".

Despite all that, however, the appeal was still dismissed. The Inspector concluded, and this bit should ring bells, that there was no overriding need for the minerals, valuable farmland would be lost, biodiversity in neighbouring ancient woodland may be impacted, and - this should sound familiar too - alternative sites had not been properly explored. And despite the quarrying operation being relatively minor in nature and only for a defined period, the Inspector also concluded that the proposal would bring an unacceptable impact on health, noise, visual intrusion and traffic.

Goodness knows then what this particular Inspector would make of the plans being explored for Straitgate - with Aggregate Industries hoping for 10 times the 'spoils' of the Essex farmers. On the same basis, how could AI possibly demonstrate to a planning inspector that its 'need' for sand and gravel - not Devon's since the county already has 16 years' supply - could outweigh the long list of objections and constraints highlighted by statutory consultees and local people alike? AI no doubt has a plan, and an accompanying band of highly-paid consultants and barristers to argue its case too. Time will, of course, tell all.

Natural England's concerns not addressed

Natural England has now responded to Aggregate Industries' latest plans and reports, but complains that none of its previous concerns have been answered: "The Hydrological Position Statement… makes no reference to the Natural England response [to the June 2012 consultation]". NE's previous concerns were that:

...dewatering would create an unacceptable impact on the waterways leading to Cadhay Bog ancient woodland. Mitigation in the form of recharge ponds… appeared not to be viable; the Airport Authorities require no ponds in the vicinity or continued pond maintenance to ensure that they are biodiversity free to avoid the significant potential impact of bird-strike. Such water features, devoid of biodiversity, due to chemical in-balances, are unlikely to be suitable to recharge a wetland and moreover continued permanent maintenance long after extraction ceases, does not seem viable as would be required for a permanent recharge pond.

Natural England comments that whilst AI's Hydrological Position Statement does recognise the need to maintain groundwater flows it is unsure how this would be achieved, and, as with the Environment Agency, it has been left looking for further answers.

Action Group photos in an official AI report - whatever next?!

Someone said "Plagiarism is the sincerest form of flattery". Perhaps that's going a bit far, but imagine our surprise when an official Aggregate Industries Report: Test Pitting & Plant Trial Summary, supplied to a local councillor, contained our photographs.

We always try to make it a habit of attributing our sources, and of asking permission before publishing any of AI's reports and drawings; a number of AI items have been held back accordingly. The photographs AI pass off as their own do appear on our website, but that's the website with © Straitgate Action Group at the bottom.

And it's not the first time either. Consultants have been found using our maps, again with copies finding their way into official reports. Are we making life easier for AI? This is not our intention. Our intention is to get the facts about the area into the wider domain, to show the raft of constraints to a quarrying operation, to make sure - if a quarry should ever transpire - it would be done properly… and with sensitivity - if that were ever possible - to the surroundings.

Our intention is not to make life easier for a global cement conglomerate. Use your own pictures and maps! Or at the very least ask permission.

The dangers of messing with groundwater

This article - Left without safe water for year ‘due to quarry’ - in the Northumberland Gazette is simply staggering. It is a sobering reminder of why you don't quarry below the water table in an area where people are reliant on groundwater for their drinking water supplies.

Aggregate Industries is, however, planning to quarry below the water table at Straitgate. The land here supplies water, not for two properties as in Northumberland, but for ONE HUNDRED people.

Blaxter Quarry - Les Hull [CC-BY-SA-2.0], via Wikimedia Commons

The story is also reproduced below:

Is a Minerals Plan worth the paper it's written on?

Is it any wonder that Aggregate Industries wasn't in a hurry to provide supporting documents for Straitgate Farm's inclusion in Devon's Minerals Plan? If what happened in Staffordshire is anything to go by, AI probably doesn't care too much what's contained in the new Minerals Plan.

We have responded to more DCC mineral-related consultations over the years than we care to remember. It was perhaps naive to think we might in some infinitesimally small way shape Devon's future minerals policy, but respond we did, as the council asked, and as many others did too. In the Big Minerals Debate DCC asked people to "Have your say on future mineral extraction in YOUR local area". Last year DCC said "Have your say on Future Quarrying in East and Mid Devon". Hundreds did.

But what was the point? DCC promises that "The Devon Minerals Plan will provide the long term, strategic planning policy direction for mineral development in Devon, informing decisions on mineral planning applications." But can we rely on that? It's not what happened in Staffordshire. Its Minerals Plan did not inform decisions.

In 2012, AI applied for planning permission for a 400 acre extension to a sand and gravel quarry in Staffordshire - 13.5 million tonnes to be extracted over some 15 to 20 years. Was this site allocated in Staffordshire's Mineral Plan? No - the plan allocated another area. Was Staffordshire running short of minerals? No - the county had over 13 years of reserves already. Did it get approved? Yes - earlier this month.

There may always be a case for deviating from a plan, but a 400 acre deviation? AI, and other mineral companies, must surely think that a Minerals Plan is now an irrelevance. Plead that jobs are at risk. Plead that £6m was invested in plant just 8 years before the existing permission was due to expire. Bingo. Approval. Easy.

So what is the purpose of a Minerals Plan? Why bother to consult local people? What's the point of a landbank? Or the method used to calculate it? If a 400 acre, 13.5 million tonne quarry - that's not aligned to the strategic and democratically approved vision of a county, and not needed to meet a county's shortfall in reserves - can be rubber stamped, local people will rightly think that a Minerals Plan is of no relevance to them, not worth commenting on, not worth the paper it's written on.

Indeed, irrespective of whether Straitgate is in Devon's Minerals Plan or not, AI will be applying for planning permission next year. In Staffordshire the council may have been mindful that the 400 acre extension received little objection from the statutory bodies or others. In Devon, the council is acutely aware that for Straitgate this is not the case.

Were we guilty of ‘cyber-bullying’ Aggregate Industries? #FreeSpeech

Straitgate Action Group's Twitter account has been suspended. 

In our view we have not breached any Twitter Rules. Has something more sinister taken place?

Listed below is the last batch of Tweets we made before Twitter suspended our account. Do they amount to cyber-bullying a Swiss multinational, or do they highlight legitimate concerns that people across the country have with quarrying and the minerals industry? Each Tweet is linked to its source. 

RT @nice1cyril Here's the Hawk that suffered a #birdstrike at Mona. Outcome could have been much worse. Glad crew ok 

CDP Climate Change Report 2013. 50 top emitters responsible for 73% of total CO2 from Global 500. #Holcim in top 50 

Decision delayed on plans for construction, demolition & excavation waste transfer station at disused quarry in #AONB 

Finally, a plan for a quarry last worked in the 1940s. Currently used "illegally by people on motorbikes"

Cllrs delay #Calne quarry plan vote: "We want to protect" locals. Officers asked to mediate with Aggregate Industries  

It is perhaps ironic that the very last tweet made - innocuous looking enough, but the one that appeared to trigger the suspension a minute or two after it was tweeted - contained both the phrase We want to protect locals and the name Aggregate Industries...

We have appealed against the suspension.

‘Protect it from further quarrying’, says Aggregate Industries

A new tactic from Aggregate Industries - the tacit threat of a further 30 years of quarrying on one hand or a 7MW solar park on the other. Who could refuse AI's solar proposals near Penryn in Cornwall when faced with that 'choice'?

As part of the solar park application, Aggregate Industries is willing to relinquish the mineral extraction permission at the site and therefore protect it from further quarrying. Subject to securing planning permission for the solar farm, the company is willing to make this commitment to the Council and local community in the form of a binding legal agreement. There are significant permitted mineral reserves at the quarry which could last up to 30 years and the current planning permissions run until 2042.

What else does this reveal? Beyond the fact that AI has more quarrying permissions than it needs, in Cornwall at least, is the admission - "protect it from further quarrying" - of the inherent destructiveness of quarrying, by an aggregates company of all people. For all the song and dance mineral companies make about restoration and biodiversity improvements, even this land - which AI claims is "low-quality agricultural land" - would still, in AI's opinion, benefit if it was  "protect[ed] from further quarrying".

And if low quality agricultural land should be protected, what of high quality agricultural land? And if that high quality land was responsible for supplying drinking water to 100 people and water for wetland habitats in ancient woodland thousands of years old, wouldn't that land need protecting even more?

Exeter Airport calls for meeting with Aggregate Industries

Exeter Airport has responded to Aggregate Industries' latest plans by reiterating its earlier advice:

To ensure aviation safety it is suggested that no ponds or body of water be allowed as part of this development.

This is plainly at odds with AI's hydrological report which makes clear that:

The contours along north-eastern, eastern and south-eastern boundaries of the site should encourage groundwater and surface water to pond along these boundaries to replicate the storage that has been lost due to the removal of the unsaturated and saturated zones at the site. 

The provision of water storage along the [eastern] boundaries of the site, to mitigate flooding and maintain groundwater flow, also offers the opportunity to create a priority wetland habitat and therefore enhance the ecology of the area.

This stretch of proposed ponding and wetland, along boundaries over 1300m in length, is NOT shown on AI's working or restoration drawings, NOR indicated in AI's landscape proposal, which misleadingly describes "light agricultural grazing" and only a 0.1ha "attenuation feature"/"ephemeral water body". The stretch of ponding and wetland would NOT just be during the working life of any quarry, but, in order to mitigate for the permanent loss of groundwater storage, would be for ever after - directly under Exeter's flightpath for planes landing on runway 26. As Safeguarding of Aerodromes Advice Note 6 says:

Permanent wetlands attract a variety of hazardous birds such as waterfowl, gulls, herons etc, and any surrounding trees may attract corvids pigeons or Starlings. Birds moving from one wetland site to another may cross aircraft flight paths and thus create a birdstrike risk. Even if a wetland or pond is proofed to prevent bird access, birds will continue to visit the site to check if feeding or other resources are available and then move on to another wetland when they find that they cannot reach the water.

DCC has asked AI on several occasions to make contact with Exeter Airport and explain how it proposes to overcome such a conflict. AI has not yet done so. Now Exeter Airport wishes to meet with AI "so that our concerns [can] be fully understood". As far as DCC is concerned there is no evidence yet on the table to show that the two opposing requirements - controlling flooding and maintaining groundwater flows without increasing the risk from birds - can coexist. For Devon to rely on such a site for its Minerals Plan would at this stage be foolhardy.

Why is all this so important? Exeter Airport has a duty "to ensure that the birdstrike risk is reduced to the lowest practicable level". Exeter, as at every other airport, has birdstrike incidents. Each birdstrike - beyond the issue of safety - costs airlines money, through delays, repairs or both.

What do they do in Essex?

Essex County Council (ECC) is at a more advanced stage with its Replacement Minerals Local Plan than Devon, with public examination due later this year. It has allocated more than 40 million tonnes of new provision for sand and gravel in its plan. Here's what ECC said in its Pre-Submission Draft:

On sustainability and conserving minerals:

The Council promotes sustainable procurement and construction techniques and the use of alternative building materials in accordance with national and local policies.

The minerals hierarchy sets out the different approaches to the supply of minerals... The most sustainable option is to reduce the amount of minerals used, followed by sourcing minerals from alternative sources including secondary and recycled materials, and finally through the primary extraction of minerals.

The role of the plan is to promote the development of a network of minerals recycling and processing facilities and to also control the amount of land allocated for primary extraction in order to promote the use of secondary materials.

With regards to people, it aims:

To ensure that the impacts on amenity of people living in proximity to minerals developments are rigorously controlled, minimised and mitigated.

To maintain and/or enhance landscape, biodiversity and residential amenity for people living in proximity to minerals development.

And on all these matters we would hope that DCC would echo something similar in its new plan. 

Where ECC and DCC will obviously differ is on how sites were selected for future quarrying. ECC says:

Sites have been chosen with regard to their environmental and social acceptability by avoiding imposing any unacceptable adverse impacts on public health and safety, amenity, the environment, local community or highways.

DCC, if it proceeded with the preferred sites so far put forward, would of course simply have to say:

Sites were chosen on the basis of surface and mineral rights being owned by AI.

Why so? Readers may remember that of the 21 sites DCC looked at, and despite a number of other landowners being agreeable in principle to extraction, only three sites were picked - those that had surface and mineral rights owned by AI. Just a coincidence? No, DCC was more focused on sites being 'deliverable' than on the environmental impacts. Some may have seen that as pragmatic. Others that DCC was too closely aligned to the wishes of a Swiss multinational cement conglomerate. Straitgate, as one of these sites, had, in fact, more constraints than almost any other site.

EA needs a lot more answers

The Environment Agency has responded to Aggregate Industries' latest plans and reports, and now seeks further answers from the company on a range of issues.

One matter that has been clarified by the EA is their newly delineated SPZ - groundwater source protection zone - that stretches well into the area AI wants to quarry. AI had complained that this had been wrongly calculated. The EA robustly refutes this and says:

[AI's] Hydrogeological Baseline Report states that the Cadhay Source SPZ 2 was delineated based on the assumption of a 1m thick saturated aquifer. However, just for information, the SPZ was delineated using a velocity calculation and the topographic contours, which means that saturated thickness did not actually come into any calculations.

Touché!

Us and them

Whatever the arguments about building single houses in the open countryside outside villages or built up areas, it is ironic that an application for a single dwelling on the perimeter of Straitgate Farm was recently refused by East Devon District Council, on the basis:

The proposed development would result in the introduction of [development] into an attractive rural environment with resulting harm to the visual appearance and appreciation of the countryside.

What did EDDC have to say in last year's consultation regarding a 10-year multi-million tonne sand and gravel quarry in the same location? Nothing. Absolutely nothing. One rule for some?

National Planning Practice Guidance

An online planning guidance resource has been issued in draft form from the Department for Communities and Local Government for public testing and comment. Here's the link to Minerals.

The existing guidance, says DCLG, "is almost impossible for residents and businesses to use effectively". The new and heavily cut-down version will "provide clearer protections for our natural and historic environment by giving power back to communities who are generally best placed to make local decisions". No really, that's what it says.

Nick Boles, the Planning Minister, hopes the new "national planning guidance will give much needed simplicity and clarity to the planning system and bring about better community involvement" because, after all, "planning shouldn’t just be the preserve of technocrats, lawyers and council officers".

Another round of drilling at Straitgate over

There were interesting scenes on the B3174 out of Ottery St Mary this morning, when the rig contracted to Aggregate Industries headed back to Straitgate to await removal after two weeks of drilling in and around the farm. Locals, tourists, farmers and borehole-drillers all vied to use the road at the same time; no prizes for guessing which one doesn't belong here.

The groundwater levels in the five new boreholes, in addition to the earlier ones, will be monitored over at least 12 months to determine seasonal variations and the impact of rainfall. Such data will either support or undermine AI's mitigation plans. The picture below shows one of the holes being drilled. There was no shortage of water, as the drillers will attest.

Further ten years allowed for quarry in Cairngorms national park

That's the headline in Minerals Planning. What a disgrace you might think? How could they? However, compare and contrast this last paragraph of the article with the plans for Straitgate:

The authority noted that the proposals were small scale and the impacts were local and temporary. In addition, the site was relatively remote and there would be no loss of amenity for residents. Extending an existing quarry was more sustainable than opening a new site and the restoration had the potential to enhance the natural heritage of the area by restoring agricultural land and improving the appearance of the site. The development would also support the local economy.

Does any of that apply here? No. OK, East Devon's not a national park, but the article highlights that there are ways that quarrying can cause less impact on people and people's lives, and there are places where quarrying can cause less impact on people and people's lives. Straitgate Farm, Ottery St Mary, is not one of those places; Aggregate Industries' proposal is not one of those ways.

Not fracking, but a precursor to something potentially as harmful to local water users

No, not fracking or hunting for shale gas in East Devon. But it is exploration of a sort. Aggregate Industries today started drilling additional boreholes at Straitgate Farm, to set up further groundwater monitoring points in an attempt to understand the area's hydrogeology to support its mitigation plans.

The requirement to drill these extra boreholes is an indication of how important the area is in terms of groundwater. AI's proposal - excavating a huge pit right in the middle of this area, removing millions of tonnes of groundwater-bearing sand and gravel both above and below the water table - could result in irreparable damage to the local water regime, causing loss to the people, the agricultural land and the ancient woodland that rely upon it. AI's mitigation proposal is based on limited information at this stage - in other words, it's a hypothesis, or conjecture. Such a proposal is in any case, as we have outlined before, contrary to airport safeguarding requirements.

Birdstrike quotes - a top 10

Now that Aggregate Industries' "wetland and open water habitats" mitigation plans are on the table - with their inherent risk of attracting birds and conflicting with the safeguarding of Exeter Airport - here's a timely reminder of why such 'watery' proposals are unacceptable. Below are 10 quotes on the subject of birdstrike that we have previously posted over the last year or so:

1. Under the Air Navigation Law, it is a criminal offence to endanger an aircraft or its occupants by any means. Exeter Airport 

2. To ensure aviation safety it is suggested that no ponds or body of water be allowed as part of this development. Exeter Airport 

3. Almost without exception, water developments increase the bird hazard in ways that cannot be adequately controlled. CAA

4. It must be recognised that it is not possible for an aerodrome or aircraft operator to mitigate the hazard caused by water bodies and watercourses, or to prevent birds using areas of open water in the vicinity of the aerodrome. CAA 

5. The exact position of a site within the safeguarding zone is another important factor. If an extraction operation is located directly under the take-off and landing approaches, then this is going to be far more critical than a location 12km out on the runway flanks. Surrey County Council

6. With the move away from infilling sites, those within safeguarding zones worked below the water table and with wet restorations will provide a particular challenge. SCC 

7. Wetland creation is one of the most problematic development types in terms of birdstrike prevention at aerodromes. Wherever possible developers should seek to keep proposals as far from aerodromes as possible and outside the 13km safeguarded zone of major civil and all military aerodromes. Birdstrike Avoidance Team

8. Bird management plans should thus be regarded as an additional measure to give aerodrome managers confidence that no additional risk will result after location and design modification measures have already been used to minimise any additional risk from a wetland development. They are not a means by which otherwise unacceptably hazardous developments can be transformed into acceptable ones. BAT 

9. Whatever the actual increase in risk, the key test that an aerodrome manager applies is one that asks the question ‘if there was an accident involving loss of life at my aerodrome could I defend allowing this development to proceed without objection when I believed that it would cause an increase in the birdstrike risk, however small?’ A planning inspector is likely to ask him/herself the same question. BAT 

10. The aviation industry, be it the airport itself, the MOD or CAA, has never lost a public enquiry regarding an objection if an unacceptable birdstrike risk has been predicted from a development. BAT

And finally, a reminder of what a planning inspector said, in connection with a farmer appealing for permission to keep a 40x25m pond:

...because of [the pond's] critical location so close to the main flight path of the aerodrome at a point where aircraft are on their final approach to the runway, aircraft safety must be paramount. I consider that this development feature which has the potential to attract birds in increasing numbers at this location poses a serous risk to aircraft safety. I find this unacceptable. I conclude that the undoubted ecological benefits of the development cannot outweigh the safety needs of the aerodrome.

It all seems clear to us, but is it causing any head-scratching at AI yet? One might imagine a scene at AI HQ: "To mitigate we need ponds and wetlands, to safeguard aircraft we can't have ponds and wetlands. To mitigate we need ponds and wetlands, to safeguard aircraft we can't have ponds and wetlands. To mitigate... ah, for goodness sake, how difficult can this be?" Or perhaps we underestimate, perhaps AI has a cunning plan...

The elephant in the room

Reports written, plans supplied. Can DCC now rely on Straitgate Farm for its Minerals Plan?

Not in our view. There's a huge conflict that Aggregate Industries has not even attempted to resolve: the conflict between water, birds and aircraft. The plans and mitigation measures put forward outline wetland and water features being created. In fact the consultants say that, for mitigation attempts to work, it is a requirement:

The contours along north-eastern, eastern and south-eastern boundaries of the site should encouraged [sic] groundwater and surface water to pond along these boundaries to replicate the storage that has been lost due to the removal of the unsaturated and saturated zones at the site. (3.3)

But this brings its own complications:

The provision of water storage along the north-eastern, eastern and south eastern boundaries of the site, to mitigate flooding and maintain groundwater flow, also offers the opportunity to create a priority wetland habitat and therefore enhance the ecology of the area. (3.3)

Actually, more than "offers the opportunity" - it will create wetland habitats. And this is where the problem lies, where AI remains completely silent: If an operator wants to quarry under a flight path, it is all about creating and leaving areas unattractive to birds - obviously not like Blackhill Quarry, or Hillhead Quarry, or 100s of other quarries. It's not about "ecological enhancement by the formation of wetland and open water habitats (3.4)" - exactly the reverse in fact. Guidance is given on the matter. Exeter Airport sent DCC a copy. Exeter Airport sent us a copy. And it's not that we haven't said anything about it either - click on "birdstrike" on the side of this blog. AI is either choosing to ignore the issue, or just can't find a way to accommodate it. Here's a reminder from the CAA:

Where water features are absolutely necessary, measures to reduce the ecological diversity of water features and minimise their usefulness to waterfowl should be adopted and should include all of the following, where applicable:

(i) Depth: water should be as at least 4m deep with steeply shelving (preferably vertical) margins, to minimise or eliminate bottom-growing vegetation.
(ii) Perimeter: banks and edges are a source of ecological diversity and important for feeding, loafing and nesting. Their extent should be minimised by the shape being as close as possible to circular, without bays, promontories and islands
(iii) Banks: as in (ii) above, banks should be steeply shelving with minimal vegetation and cover. If possible, there should be a vertical lip or fence to prevent birds from walking in and out of the water.
(vi) ... a wet meadow would attract feeding ducks and nesting waders, and should be avoided.

In summary, follow all CAA guidance to "reduce the ecological diversity of water features". There are other measures too - for example on tree planting. Oh, we can leave all that until the airport make a fuss, AI might say. We'll buy a bird management plan. But for perpetuity? In any case, Exeter Airport may take a different view with aircraft flying directly over the site many times a day at low altitude. And DCC must be confident that the site is deliverable in the face of a seemingly catch-22 situation - can't mitigate without such water features, can't have aircraft safeguarding with such wetland habitats.

This is not some after-thought, some planning condition footnote. It's important and should have been covered in AI's submission. In fact, if you were AI, wouldn't you have knocked the issue on the head once and for all - if you could? AI was aware that the airport was not happy with water. Why did it not deal with it? But not a single sentence, on potentially one of the biggest and most intractable issues on whether Straitgate is suitable for quarrying. Wetland habitats all along the eastern boundary of the site - and not a single word on the safeguarding of aircraft. Amazing. The elephant in the room.

SLR's water report - Hydrological Position Statement

Can DCC rely on Straitgate Farm for its Minerals Plan? A lot hinges on SLR's report which outlines the impact a quarry would have on water - to people, to ancient woodland and on flooding. SLR has put forward a hydrological model and various mitigation measures. It will be up to the Environment Agency to decide whether it all makes sense or not.

The report is a more thorough affair than the last one, the Hydrological Baseline Report of 2012 - it had to be. That report was scant and inaccurate on detail, concluding there were no "significant constraints to site development", that "any encountered groundwater would be pumped and discharged to the local watercourses" and "local water supplies would be monitored and mitigation in the form of an alternative supply would be available if required". That's all changed.

SLR recognises that there are now constraints to development. "Additional monitoring data have been collected and revisions made to the working proposals to limit the potential constraints to development and to answer the concerns and comments raised by the Environment Agency. An updated hydrological impact assessment has been undertaken in light of the additional data and revised working proposals".

SLR recognises that "the ecological site most at risk from the proposals is Cadhay Bog, as it includes significant water dependant habitats" and that "such woods are now scarce nationally and this is a good example of wet woodland". SLR also recognises that there are a large number of properties and farms at risk, and that a detailed field survey is required over an area to be agreed with the Environment Agency. On the positive side, SLR is of the view that "the development offers the opportunity to reduce the current flood risk downstream of the site by the provision of areas within the quarry that can be designed to hold back flood waters during a storm event".

SLR considers that mitigation of the negative impacts may be possible. This would rely on "maintaining the current groundwater flow regime" by leaving 1m of pebble bed on the base of any quarry, creating cut gradients on the eastern side to promote infiltration, and operating no "active dewatering". However, working below the water table is still proposed - "extraction in the more saturated eastern areas of the site takes place when groundwater levels are at their lowest (in the late summer to autumn) and that winter working is restricted to the relatively dry eastern part of the site". It will of course be the EA and DCC who decide on the wisdom of such a measure with 100 people dependent on the area for their drinking water supplies, not AI or SLR.

SLR is of the view - and bear in mind who its customer is - that although Straitgate Farm is a "hydrologically sensitive" site, it "can be worked so that the current groundwater infiltration and flow directions are maintained and storage is provided to mitigate the loss of storage in the aquifer".

The EA will now need to decide whether the mitigation measures put forward stand a chance of working. DCC will need to decide on whether to rely on a report where, as SLR emphasises, "a definitive assessment of the impacts cannot be provided [until] further data is collected on the seasonal variation of groundwater levels and surface water discharge rates".

And finally, what can be said about AI's plans and drawings

Well, Aggregate Industries has made a few changes since its last plans - and remember, these are just concept drawings at this stage to satisfy DCC's Minerals Plan - moving the access from the west to the north for example, bringing the extraction boundaries further from homes, leaving some material on the base in an attempt to mitigate water impacts.

But AI is still claiming it has 3.1 million tonnes of recoverable and saleable sand and gravel at Straitgate - down from 3.6 Mt. This is of course totally dependent on AI being permitted to extract sand and gravel below the water table, and with so many people reliant on water from the site, it is unclear whether the Environment Agency would sanction that. AI was only permitted to quarry down to one metre above, above not below, the water table at Thorn Tree Plantation, Blackhill.

AI has given "categorical" assurances that there will not be processing plant at Straitgate - it doesn't have the water resources to do so anyway. This will therefore mean the transportation of as-dug material on public highways - for the lifetime of any quarry, which AI estimates to be 10 years or more. At Venn Ottery, this equated to an average of 110 HGV movements a day or 10-12 per hour - according to AI's own Haulage Statement, October 2010, payload 29 tonnes, gross vehicle weight 44 tonnes. How sustainable, ethical or environmental is that? And AI has still not given up hope of processing the material at Blackhill either. Of course, DCC and Natural England will obviously have something to say on that matter.

And there's another issue. AI's plans now rely on the use of third party land - namely for site access, the storage of overburden amongst the line of veteran oaks, and for advanced planting "for visual mitigation measures". AI does own the mineral rights in these fields. However, it is unclear whether AI has the rights to anything more. Advice is being sought. What can be said for certain is that no rights have been agreed from the different owners of the fields. DCC will need to assure itself of the merits of relying on a site where AI does not have surface ownership of the access route.

There are a number of other points: Grandiose plans can be made for tree planting and aftercare, yet AI's existing woodland around the site has had no management in many years; an attempt at underplanting 10 or more years ago completely failed through lack of light and ivy encroachment. AI plans bunds of earth next to A30, changing the aspect for users, for which advice will need to be sought from the Highways Agency. AI plainly accepts that the quality of the farmland will be lost, with the "long term afteruse being light agricultural grazing" - in other words, adequate for sheep and little else. And where's the silt going - back to Straitgate for restoration? Or to Rockbeare or Blackhill?

And what do the restoration plans offer to the community. Much has been said on this blog about companies giving back - leaving something worthwhile as recompense for the loss of amenity, the dust, the noise, from 10 years of quarrying and 100 HGV movements a day - something to win over local opposition. So, if it was to ever get as far as restoration, what does this community get left with? A footpath around the void. An interpretation board. We're overwhelmed.

AI's submissions to DCC

Below are the documents that Aggregate Industries has supplied to DCC for the purposes of showing that Straitgate Farm can be relied upon as a Preferred Site for the new Minerals Plan. The documents raise questions and we will make comments in due course.

Hydrological Position Statement
Overview of Landscape Proposals and Aftercare
Letter to DCC from AI

AI reports on Straitgate Farm

For the purposes of Devon's new Minerals Plan, Aggregate Industries has finally supplied DCC with two reports, a Hydrological Position Statement and an Overview of Landscape Proposals and Aftercare, to show that, in its view, Straitgate Farm is workable and that DCC can rely on it as a Preferred Site for sand and gravel extraction. DCC will send the reports to consultees for scrutiny, including the Environment Agency, Natural England and Exeter Airport. AI has sent copies of the reports to us, and we will provide an update in due course.

The hydrological report will obviously be preliminary in nature since detailed and long-term water measurements have yet to be taken, and some piezometers yet to be installed. Without such data, it is unclear how the report can be relied upon to demonstrate that private water supplies will be protected or stream flows to ancient woodland maintained.

‘development with care’

Alongside sustaining a considerable amount of local employment, [the site] also provides an opportunity to add new and improved community and tourism resources to the local area, both during mining operations as part of [the company's] ‘restoration first’ approach to its surface mining schemes and as part of the site’s final restoration. 

Our planned investment has the potential to offer so much to both local people and visitors to the area, and we are therefore announcing our intentions at the earliest possible opportunity to start a dialogue with local residents, businesses, tourism bodies and visitors, so that we can understand their views better and enable them to have a direct influence on the site’s design and the benefits it will bring to the area. 

We want [the site] to set a new benchmark for modern minerals developments, delivering significant economic input alongside substantial benefits for the local community and wildlife alike, and our absolute priority is to design a scheme that delivers tangible, long-term local and regional economic, environmental and social benefits from day one of the project.

Sorry - this is Banks Mining, not Aggregate Industries. Open cast coal mining, not sand and gravel. Are these just words? Maybe not. The company created the giant Northumberlandia ("Lady of the North") earth sculpture near Cramlington as part of its Shotton surface mine. If a quarry should transpire at Straitgate Farm, local people should expect more.

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.

Second quarter sand and gravel figures

Show a 9% increase nationally on the same period in 2012. However, according to the MPA, the underlying annual trend for the year to June is still showing a decline of 6% compared with the previous year. The MPA considers that "construction activity may be close to the bottom of the decline which started in mid 2011" and says that although “private housebuilding has improved, [ ] this sector represents only 14% of construction and it is sobering to see the latest GDP figures showing that construction output in the first half year was 4% lower than the same period of 2012". So, with housebuilding representing only a small part of the construction market, when the Express & Echo report "Big leap in new homes starts in Devon and Cornwall" it does not therefore follow that there will be a comparable 'leap' in overall aggregates supply or production.

Tesco and Aggregate Industries - what on earth could they have in common?

Are all big companies the same? What for example do Aggregate Industries and Tesco have in common? Well, more than you would think.

We have already established that AI takes - from the ground and communities, but does not give anything meaningful back. Donations of 0.02% of sales mathematically rounds to zero. Meanwhile Tesco's boss, Philip Clarke, was recently quoted as saying "We were hearing that Tesco has got to put in more [to society] because people think that all we do is take out". Tesco claims it wants to change, and has a new "core purpose" added to the list on its boardroom wall - "We use our scale for good". AI on the other hand thinks it is just a matter of presentation, promotion, marketing, spin - its Chairman recently calling for the quarrying industry to do more to promote itself to the public.

But there are other similarities. Both have been no good for farming - an industry in crisis, with 30 dairy farmers quitting in April alone. Invariably, any new quarrying application has the word "Farm" in there somewhere - and let nobody claim that soils will be better following any restoration that may or may not happen. Tesco and other major supermarkets have also been devastating for farms, with tough contracts forcing many to quit and moving the UK's food self-sufficiency from 70% in the early 1990s to nearer 50% now. Tesco again wants to correct this, Philip Clarke saying "We've got to produce more food at home and we've got to make better deals with producers". That won't be easy with AI and friends digging up farmland everywhere.

Closer to home, both companies have also been accused of "sharp practices". AI by flouting planning conditions at Hillhead, and Tesco only yesterday by setting up a marquee selling "summer essentials" in its car park in Ilfracombe, without planning permission, angering local shopkeepers. Tesco too has applied for retrospective permission, but can carry on in the meantime, says North Devon Council, until permission is either granted or refused.

No doubt people can think of other similarities. Pile it high, sell it cheap etc. But it can be different. Companies can do good. Companies can give back. The application by Sirius Minerals for the York Potash Project in the North York Moors National Park has been mired in controversy and debate about its economic merits and environmental impact, and has been delayed yet again. But whatever the arguments, or maybe because of the arguments, the company is pledging to give back. Not AI's 0.02% of sales but 0.5% of sales - 25 times more. And it doesn't stop there. A Section 106 agreement would see £13m put into a range of community measures - tree planting, promoting tourism, road improvements and educational projects. Sirius Minerals is even paying for three displays from the Red Arrows for the annual Whitby Regatta whilst construction takes place.

Whether Sirius Minerals is buying off the community or making a serious effort to do the right thing, something would at least be flowing back to the North York Moors and the region suffering most impact - not least by creating about 1,000 jobs and paying tens of millions of pounds in royalties to landowners. At a market capitalisation of £270m the company is not small, but Holcim, AI's parent, is almost 60x bigger. AI gave back just £164k in 2011 - it's most recent figures - 5% of the figure paid to Holcim's boss in 2012. It needs to think about giving back something more significant to the communities it affects. AI would surely have more chance of persuading people of the merits of quarrying by doing so, than by any amount of spin and self-promotion.

How it should be done

Aggregate Industries et al. take note. Some of the content here might cause readers to double-take. We had to read it twice, and check the date. Rest assured the story is real, and a model of how developers can work with the community when restoring an old quarry to some practical and acceptable use. For background, Coles Quarry - a limestone quarry that opened in 1867 and ceased production in 1999 owing to "inherent environmental problems" - is located in Backwell, just south of Bristol. Here are a few lines from an article that appeared yesterday in the Weston Mercury:

The owner of Coles Quarry in Backwell has submitted the first phase of a planning application to turn the site into a business park, school car park and recreation ground.

Villagers will be able to determine what happens to the rest of the land and the owners are appealing for residents to send in their ideas.

“Phase three is what to do with the quarry itself. Whether that’s rolling grasslands or a recreation ground, it will be down to the village to decide.”

“We are very pleased with the support we’ve had from the village. We are doing our best to work with the community.”

Once the plans have been completed, 89 acres of woodland on the site will be given to Backwell Environment Trust for use as a nature reserve.

The development could create up to 250 new jobs in the area as well as much-needed facilities for the school and villagers.

And from an earlier article:

Existing dilapidated buildings, which used to be the bagging works but have more recently become a target for vandals, will be replaced by business units for village firms.
“It is quite exciting because we are taking an old quarry and doing something useful and creative with it, which will then be given to the people of Backwell.”

There are some additional photos at Angus Meek Architects. You have to pinch yourself.

AI's bagging plant application for Uffculme gets nodded through by DCC

Staff at Aggregate Industries must be smiling. They must think DCC is a pushover, following the council's approval of its bagging plant application this afternoon. Robert Westell, AI's Senior Estates Manager, gave a faltering defence of his company's retrospective application, noted by a DCC officer as being "fairly disastrous" from a public relations point of view, seemingly unaware of one of the basic planning conditions - that there were to be no retail sales from the site.

Cllr. Bob Evans wanted the planning committee to remember one number - 55,000 - the number of HGVs local residents would have to put up with every year. But, bar the local councillor, the committee gave its unanimous support - members worried that the council would be taken to appeal if they rejected it. In one baffling comment, the chairman reminded local residents that they were "getting quite a lot out of this" [53:36]. With no new jobs, it's quite unclear what he meant. If he meant the slightly modified working hours 0600 to 1900 hours Mondays to Fridays and 0700 to 1300 hours on Saturdays - big deal. If that many HGVs went past his front door he might feel differently.

When ancient woodland becomes the price for crushed aggregate

Woodland Trust

Following a public inquiry, permission has been given for an extension of Gallagher Aggregates' Hermitage Quarry in Kent which will lead to the loss of 32 hectares (80 acres) of ancient woodland at Oaken Wood. A statement from the Secretary of State said:

The very considerable need for both crushed rock aggregates and dimension stone, together with the eventual biodiversity improvements, and the ongoing socioeconomic benefits, would clearly outweigh the loss of the ancient woodland and the other adverse effects of the development in this case.

Is there no limit to the quality of landscape quarrying operators destroy for basic aggregate? Do they have no moral compass? No appreciation of the natural world? A little closer to home, how many people have gazed down at the beauty of Cheddar Gorge when flying into Bristol Airport, only to be shocked moments later by the scars of Hanson and Aggregate Industries quarries next door? Eric Pickles' decision shows continuing wanton destruction of irreplaceable parts of the landscape.

At Straitgate, the ancient woodlands in Cadhay Bog and Cadhay Wood are at risk from AI's proposals. A sand and gravel quarry would disturb the water supply to the woodlands, changing wet and boggy habitats, that, by the very nature of the topography, will have remained virtually undisturbed for possibly thousands of years.

The Oaken Wood decision will mean the direct loss of ancient woodland. Gallagher's boss dismisses any concern saying "everybody acknowledges that it is sweet chestnut coppice planted 150 years ago" and that "it will be replaced by native species woodland and there will be twice as much planted as lost". Which of course misses the point by a mile. The site has been wooded for more than 400 years. Ecosystems have developed in undisturbed soils over that time. Talk of "biodiversity improvements" is disingenuous. Ancient woodland is irreplaceable.

The Woodland Trust, which campaigned for two years with Kent Wildlife Trust and ‘Save Oaken Wood’, has called it "one of the UK's largest losses of ancient woodland in the last five years", and the "first real test of whether the Government’s recent planning reforms would offer sufficient protection to ancient woodland". The Trust's CE said:

This is a landmark decision, but for all the wrong reasons. This so-called ‘greenest Government ever’ stated that the new National Planning Policy Framework would give sufficient protection to irreplaceable habitats such as ancient woodland. It clearly does not – it seems no green space is safe.

How is it that quarries turn into industrial sites so easily?

At Oaken Wood, Gallagher Aggregates have said the ancient woodland destroyed will be eventually replaced by new planting covering twice the area lost. How can we be sure? How is it that quarries so easily turn into industrial sites? Quarry companies make a loud shout about nature sites and restoration. In practice, local people see things differently.

Even if restoration is a planning condition, companies apply for change of use - it's so much more profitable. Look at all the recent applications for wind turbines, solar panels, aggregate recycling, incinerator waste processing, etc. AI's retrospective planning application for an aggregate bagging plant at Uffculme - transferring from Bishops Court Quarry in Exeter, now to be developed for housing - is a case in point. And reading the recommendation from DCC's Head of Planning, it's easy to see how a quarry leads on to industrialisation rather than restoration:

6.20 Policy MP51 allows for industrial development within mineral sites if the operations have close links to the quarry on which the operations are sited. In this case the proposal does not have links with the adjacent mothballed quarry (although in the future it may have) but neither does the concrete products factory which has a full, free standing planning permission.

6.23 The adopted Mid Devon Local Plan policies S5 and DM7 seek to protect existing land use from inappropriate development, but in this case it is considered that the proposed development, because of its nature, links in well with the existing land use.

So with 6.20, the plant has no links with the quarry - but hey, so what. 6.23, however, is the crux of it because any industrial development always "links in well" with the despoilation of a worked-out quarry.

AI's bagging plant application will be decided by councillors this week, but officers have already made up their mind that "the site is appropriate for the development proposed". And according to AI, in its presentation to councillors, the people of Uffculme should be grateful:

[The bagging plant] demonstrates the Company's commitment to invest in the local area in a period of industry consolidation/site closures/job losses

Grateful for what? It's unclear whether a single new job - local or otherwise - will be created. So it can only be for the extra HGVs - traffic up 76% at one junction. The people of Uffculme must be thrilled.

‘Welcome to Quarryville’

Tarmac's Bayston Hill Quarry              © Copyright Richard Law and licensed for reuse under this Creative Commons Licence

People can make of this what they will. It may reassure some people. It may sound like mineral company propaganda to others. It's Tarmac's idea of dispelling the, what it would call, "myths" of the effects of a new hard rock quarry in the neighbourhood. "Tarmac’s Quarryville website is an education resource for schools that supports key content areas of the National Curriculum, Key Stages 2 and 3".

The Quarryville Rock Quarry has been operating for six years – quite a short time for a quarry. When it was first announced that Tarmac, the company that owns and operates the quarry was planning to start the quarry, there was quite a bit of local opposition. Now relations between Tarmac and the local community are excellent and everybody’s convinced the rock quarry is good news for Quarryville. What do you think happened to change people’s minds? Here are some of the bad things local residents thought might happen back in 1996 and the solutions provided.

Tarmac tackles a number of issues, but concludes by reassuring readers that:

So, as you can see, most of the original concerns about the rock quarry were nothing to worry about at all. Nowadays, most people in Quarryville can’t imagine what life would be like without their big, friendly neighbour. Tarmac even sponsor the local football team, Quarryville Falcons. What’s happening at Quarryville is a small example of what happens all over the country. The total area of land permitted for quarrying aggregate is about 45,000 hectares, that’s just 0.35% of the surface area of England. And only half of that area is being quarried at present – that’s 0.17%, or less than one-fifth of one percent. We’re sure you wouldn’t mind giving up one-fifth of one percent of your food – ie, a few crumbs off your plate - to stop another person going hungry. So why shouldn’t we all give up a few handfuls of earth to help build the houses, roads, hospitals, and millions of other things we all need?

Why not indeed, when put so simply? A few crumbs - 45,000 hectares, the area of 63,000 football pitches. A few crumbs - or an East Devon dairy farm, or the prospects of an East Devon town. A few crumbs - that would also, by the way, prop up the profitability of a Swiss aggregates giant. Why not?

But unfortunately for Tarmac, Aggregate Industries and others, it's not that simple. Quarrying may be important, and help build hospitals and "millions of other things", but it's an invasive and destructive operation. Not all sites are suitable. Different sites present different environmental and locational complications. So, however good the PR, however much the local football team is supported - some complications are surmountable, some are not.