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?

DCC Minerals Plan - Straitgate Farm update for Town and Parish Councils

DCC has released an update on Straitgate Farm:

This note is intended to provide an explanation to representatives of the local communities of the work undertaken by Devon County Council to address the issues raised through the 2012 consultation on preferred sites, and to outline how those proposals are being taken forward through the emerging Minerals Plan.

On Transport, DCC says:

Given the availability of an alternative location for processing at Rockbeare Hill Quarry (3.5km from Straitgate Farm) with the opportunity to also consider a range of alternative processing locations, it may be difficult for the site promoter to demonstrate the ‘exceptional circumstances’ required for development in the AONB. While this represents a risk to the deliverability of Straitgate Farm, this is a matter that can be tested through a future planning application and should not preclude allocation of the site in the Devon Minerals Plan.

On Landscape impact on AONB:

The Devon Minerals Plan is not making provision for the processing of material from Straitgate at Blackhill.

On Land and Soil:

...sites can often be reclaimed to their original agricultural land quality if appropriate techniques are used throughout the life of the site. This is a factor in determining the acceptability of temporary mineral extraction at this site.

[AI's planning application: "For areas of the site that are to be developed as species rich grassland, then topsoil will not be used in the restoration soil profile and the subsoil would be placed more thinly on the overburden to create the less fertile growing conditions required for establishing this type of plant community." 3.42 "The long term after-use would be light intensity agricultural grazing." 3.47.]

On Water and Biodiversity:

The Devon Minerals Plan therefore will contain a limitation on this site allocation to only allow dry working on site, above the maximum winter (wet) level of groundwater with an unsaturated zone of at least 1m maintained across the site.

[AI's planning application: "The quarry would be excavated no deeper than the maximum groundwater level..." 3.24 "The side batters and floor of the quarry would be progressively restored with materials..." 3.25 "The base of the extraction area will be restored by placement of 1m combined thickness of topsoil and subsoil over the quarry floor to replicate current ground conditions." 3.42 "Mineral extraction to the high groundwater level surface contoured from maximum groundwater levels from all data would be dry for the vast majority of time..." 7.89]

10,547m2 of missing trees

Consultees will read the ecology chapter of Aggregate Industries’ planning application to quarry Straitgate Farm, and will perhaps be reassured by the statements:

4000m2 of new woodland habitat was advance-planted using native stock in January 2014, and a further 10,547m2 will be planted between January and March 2015. The new woodlands will be primarily managed for dormice. 8.257 Two further, short sections of hedgerow c. 25m and 35m will be laid from January to March 2015 8.264

However, for the record, no such planting has been undertaken this year. 

Together with claims about denied access to survey for great crested newts, how many other false statements has SLR made?

Who would be in charge of the birdstrike risk?

A Wildlife Habitat Management Plan has been commissioned by SLR, Aggregate Industries' consultants, for the application to quarry Straitgate Farm and to 'answer' the birdstrike question for planes flying 195m above the site on their approach to Exeter Airport. But according to a birdstrike expert:

[These plans] are not a means by which otherwise unacceptably hazardous developments can be transformed into acceptable ones... 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.

So who would be responsible for implementing the Wildlife Habitat Management Plan at Straitgate?

Aggregate Industries will be responsible for the implementation of all safeguarding within the site boundaries, monitoring bird numbers and activities and ensuring Exeter Airport is informed if any significant changes to ground and habitat occur and reviewing the performance of the plan... Avian Safe will also be responsible for all lethal control...

But here's a photo of AI’s Blackhill Quarry - also within Exeter Airport's 13km safeguarding zone. Gulls are classed as high risk. How is AI managing this risk - at 'Seagull Pond'? Would Straitgate be different?

AI doesn’t illustrate ponding on its plans for Straitgate any more. What it says now is that an "attenuation feature" would result in "seasonally wet grassland". CAA Advice Note 3 says "a wet meadow would attract feeding ducks and nesting waders, and should be avoided".

AI has still to solve the catch-22 problem: how to mitigate for surface water and groundwater impacts, without introducing wetland features and increasing the risk of birdstrike. 

Is this an indication of the care SLR has taken in putting together AI’s application?

In May 2013, we walked the surrounding woodland with an SLR Technical Director who was an expert in ecology. He said that a number of the small woodland ponds in the locality had ideal conditions for great crested newts, particularly the one in Cadhay Wood that is fed by water directly from Straitgate Farm. He said these sites would be surveyed in due course, but he left the company a short time later.

We now find that "the majority of ponds within 500m of the site boundary were not surveyed due to lack of access permission" 2.3.1.

Neither the landowners at Cadhay and Escot, nor we acting as coordinators, denied access to anyone at any time. In fact, the pond in Cadhay Wood, some 500m away from the site, is not even indicated on SLR's map, whilst the pond indicated at location 7, an arable field, does not exist.

SLR won’t find protected species if it doesn’t look for them. Or is that the idea?

This is just the start of the inconsistencies, errors and omissions that have jumped out of Aggregate Industries' applications to quarry Straitgate and process the as-dug material on Woodbury Common.

Purple orchids in Cadhay Wood

AI’s applications to quarry Straitgate and process on Woodbury Common go ‘live’

Aggregate Industries’ planning applications for Straitgate Farm [DCC/3774/2015] and Blackhill, Woodbury Common [DCC/3775/2015] have been validated and a 21 day public consultation will now begin.

Finally, people have a chance to respond to AI's proposals and to tell Devon County Council about the concerns they have: whether it’s the 5 years of HGVs and related safety and pollution impacts along the B3180, the risk to drinking water supplies and flooding, the loss of ancient hedgerows and risk to protected dormice, the visual impact, the risk to ancient woodland habitats, or the continued effects on the East Devon Pebblebed Heaths. We have written a summary of our concerns on the ISSUES page, and would encourage as many people as possible to respond with what matters to them.

Responses can be sent either by email to planning@devon.gov.uk or to Devon County Council, Development Management, Room AB2, Lucombe House, County Hall, Exeter EX2 4QD. Respondents should give their name and address, and quote the planning application reference. These CPRE guidelines may be helpful.

Other hauliers are told to go the long way round

Regional freight maps are produced to ensure that hauliers use the most appropriate route to minimise the impact of HGVs on other road users and on local residents. Wherever possible, truck drivers are expected to use these designated networks to access freight destinations. Advisory HGV signs are used to deter the use of unsuitable routes.

Indeed, HGVs approaching the Daisymount junction from Honiton are directed to stay on the A30 in order to reach Exmouth, rather than turn off onto the B3180 which is the shorter route.

Aggregate Industries' 1.2 million HGV mile haulage scheme proposes to use the Daisymount junction too. But AI doesn’t think this sign applies to its 44-tonne vehicles; the 'haul road' it proposes to use between Straitgate Farm and Blackhill for 5 years is the same B road that other HGV drivers are told to avoid.

AI's ridiculously unsustainable plans should never have seen the light of day; processing plants should be as close to the quarry face as possible, not 8.2 miles away, nor 14.4 miles the long way round.

1.2 million HGV miles - and ‘no adverse effect’??

People were shocked when we posted that Aggregate Industries' plans to haul as-dug sand and gravel from Straitgate to Woodbury Common totalled a million miles. It now turns out to be worse than that, closer to 1.2 million (up to 200, but typically 140 movements x 4 days x 50 weeks x 5 years x 8.2 miles).

An AI Estates Manager told a local paper that the Straitgate application "is the culmination of three years of careful planning and the proposal has been subject to a thorough environmental impact assessment".

But this is the same environmental assessment that concludes that the air pollution generated from these 1.2 million HGV miles on an East Devon B-road would be "negligible"77,78  and would have "no adverse effect" on either the humans or the sensitive European-protected habitats along the route.

Naturally, AI will look to belittle its potential impact. But, as we have already posted, in one traffic survey in Exeter "HGVs make up approximately 5% of traffic flow and yet contribute more than 38% of the total NO2 emissions", and "according to the EEA, HGVs are responsible for 40-50% of nitrogen oxide (NOX) pollution from road transport in EEA member countries". Air pollution is said to be responsible for 600,000 premature deaths in Europe each year, and many other health impacts too.

AI's consultants SLR will produce their own figures, but whatever the spin, HGVs pollute - burning one litre of diesel produces 2.63kg of carbon dioxide, about 14g of NOX and 0.14g PM10. On the basis that a 44-tonne laden HGV produces 2.23kg CO2/mile, unladen 1.34kg CO2/mile, AI’s 1.2 million mile scheme would not only produce over 2000 tonnes of CO2, 2 tonnes every day, but would also put around 14 tonnes of NOX and 225kg of PM10 into the air for local people and local sensitive habitats to suffer.

And why? In 2010, AI said it was for financial reasons that it couldn’t put processing plant at nearby Rockbeare. It knows that won’t wash this time, so has come up with some new reasons - "lack of space especially for stockpiles and silt storage; and non-availability of process water". AI could employ mobile plant, or a silt press if it wanted to; in fact, Rockbeare had processing plant until 2000. But AI will say whatever it thinks is needed in order to win permission for its more profitable Blackhill extension.

But what of the longer term? What will AI do in 5 years time, when it looks to quarry other fields near Straitgate? Will it then look to move its isolated factory to an appropriate industrial location? Or will it just seek another extension on Woodbury Common as in 2002, 2008, 2010, and now 2015 - and put another 140,000 HGV movements past people's front doors, and through an AONB, SSSI, SPA, SAC? 

AI or DCC need to resolve this ludicrous situation once and for all, and the sooner the better.

One of AI's HGVs causes near miss on B3180

Another one struggles to pass an HGV on B3180 near Tipton Cross

AI's planning application - preview of non-technical summary report

Aggregate Industries’ planning applications are still not ‘live’, but the non-technical summary accompanying the Environmental Statement is embedded below, split into parts for convenience.

The application is to extract 1.66 million tonnes, including workable overburden, over a period of 5 years - 40% more than the 1.2 million tonnes AI's glossy brochure and public exhibition wanted people to believe. Up to 200 HGV movements a day would be created, trucking material along the B3180 to Blackhill.

We have put the Summary of Effects and Mitigation Measures part of the report first - local people will find many of its conclusions laughable, with the phrases No adverse effect, Negligible effect, Minor adverse effect (not significant), Slight adverse effect, littering its pages.

AI's consultants SLR consider that up to 200 extra HGV movements through West Hill "would have no significant impact on the operation and safety of the local road network, and the amenity of local residents"68. It considers that up to 200 HGV movements a day through Woodbury Common SSSI, SAC, SPA would be "negligible and the impact of the quarry development on sensitive habitats would not be significant"78; this despite the Heaths already suffering the effects of traffic pollution. Some of the statements seem so divorced from reality, you wonder about the integrity of any of it.

AI would have us believe that it can't process at Rockbeare any more "due to lack of space especially for stockpiles and silt storage; and non-availability of process water"36. Yet as recently as January, AI's Scoping Report said: "Sand and gravel which may then be potentially worked from the “wet working option” would be processed at Rockbeare". In fact, AI staff have assured us for years that they could process material at Rockbeare, 'the old block works is just sitting there waiting'.

To cap it all, AI/SLR think they can get away with saying that we should expect this sort of development:

Quarries have been worked within 2km of the Application Site and in East Devon setting a precedent for this type of development. The proposed development is appropriate given the long history of extractive industry in the area demonstrated by historic quarries recorded on the heritage record.83

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

Utter madness - AI's derelict industrial site is 6 miles closer than Woodbury Common

Two planning applications from Aggregate Industries, one to quarry Straitgate Farm, one to process the material on Woodbury Common, are now being checked by DCC and should be uploaded here in the next few days. In summary:

Aggregate Industries wants to to quarry a greenfield site - a productive dairy farm hosting miles of ancient hedgerows, dormice, and spring water for ancient woodland and 100 people - at a time when the county already has millions of tonnes of sand and gravel with planning permission.

Aggregate Industries wants to process this material in the middle of an AONB, in a Natura 2000 site that is threatened by traffic pollution - when the company's old block works site at Rockbeare, shown below, lies empty, derelict and two miles by road from Straitgate, not eight.

It is shameful that Woodbury Common still forms part of AI’s misguided plans for Straitgate. AI should work out its existing reserves, clear up its existing mess and use its existing industrial sites - before being permitted to despoil any more of our precious farmland and internationally designated wildlife sites.

But it’s not just us saying that the alternatives must be properly assessed. Since Woodbury Common is an SPA/SAC, a Natura 2000 site, the EC Habitats Directive 92/43/EEC Article 6.4, enshrined in the Conservation of Habitats and Species Regulations 2010, has something to say about it too:

If, in spite of a negative assessment of the implications for the site and in the absence of alternative solutions, a plan or project must nevertheless be carried out for imperative reasons of overriding public interest, including those of social or economic nature, the Member State shall take all compensatory measures necessary to ensure that the overall coherence of Natura 2000 is protected. It shall inform the Commission of the compensatory measures adopted. 

Where the site concerned hosts a priority natural habitat type and/or a priority species the only considerations which may be raised are those relating to human health or public safety, to beneficial consequences of primary importance for the environment or, further to an opinion from the Commission, to other imperative reasons of overriding public interest. 

In other words, if the planning authority decides there is no alternative to Blackhill - and plainly these photographs show otherwise - then plans, such as AI’s heavy polluting HGVs, that impact a Natura 2000 site, can only proceed for imperative reasons of overriding public interest; "projects or plans that serve only the interests of companies or individuals are not covered by the [imperative reasons of overriding public interest] test". No allowance should be made for excuses such as the one used in 2010 to justify the decision to process Venn Ottery material at Blackhill:

The option to provide fixed plant at Rockbeare has the advantage of the site being outside of the AONB. However, [AI] considered that this would be uneconomical in terms of the investment required due to the limited permitted reserves at Venn Ottery and Marshbroadmoor. [6.17]

DCC must remember that profits of a multinational cement giant are not supposed to enter the equation.

AI's planning application set in motion

Aggregate Industries has now given formal notice and details of its planning application to quarry Straitgate Farm to directly affected landowners. A public consultation period is expected in due course. We will post again when we have more information. DCC has yet to upload any details.

In the meantime, it will be Devon Minerals Local Plan 2004 that will provide the planning policy framework for assessing AI’s applications for quarrying and processing; DCC's new Minerals Plan has suffered repeated delays over a period of three years because of AI’s inability to demonstrate that quarrying Straitgate would be possible without unacceptable environmental harm.

Let's therefore look at some of the policies from the current Minerals Plan, with Straitgate Farm in mind.

First of all, and unlike Penslade at Uffculme, Straitgate Farm is NOT in the Devon Minerals Local Plan - not as an Area of Mineral Resource, not as a Mineral Consultation Area. AI’s application is therefore not in line with any development plan. It could even be argued that the resource is not important enough to be identified or safeguarded by the County. Emerging policy, that looked to make Straitgate a Preferred Site, provoked such strong opposition from local people and statutory bodies alike that it should not be relied upon as having any weight. The NPPF says "Proposed development that accords with an up-to-date Local Plan should be approved, and proposed development that conflicts should be refused unless other material considerations indicate otherwise".[12]

AI’s application immediately appears to fail against a number Devon Minerals Local Plan policies:

MP 2 Proposals for mineral development within an Area of Outstanding Natural Beauty will not be permitted if they would conflict with the objective of preserving and enhancing its natural beauty. Proposals for mineral development which would harm the natural beauty, character and special qualities of a nearby Area of Outstanding Natural Beauty or National Park will not be permitted.

MP 5 Proposals for mineral development which would conflict with the objective to preserve Listed Buildings and their settings will not be permitted.

MP 24 Proposals for aggregate mineral development at new mineral sites will not be permitted if the mineral is available: (a) at Mineral Working Areas; or, (b) as extensions to Mineral Working Areas; or, (c) as extensions to existing mineral sites. Where the mineral is unavailable at such locations, development will only be permitted if: (i) such proposals would contribute to the maintenance of the landbank identified in Policy MP 20; or, (ii) the proposal would result in a reduction of the distance aggregates are transported; or, (iii) the mineral to be worked has particular qualities which can not be met from secondary or recycled materials, or which would override the overall landbank issue; or, (iv) the proposal would reduce adverse environmental effects of existing mineral development at the Mineral Site (including the potential adverse environmental impacts of reopening inactive or dormant planning permissions); and, (v) there is no demonstrable harm to interests of acknowledged importance, having regard to any proposed mitigation or compensatory factors. 

MP 43 Proposals for mineral development will not be permitted where the generation of heavy goods vehicle movements could not be satisfactorily accommodated on the existing local highway network and/or would cause demonstrable harm to noise sensitive properties in the vicinity of the route(s), unless appropriate highway improvements can be carried out which do not cause demonstrable harm to interests of acknowledged importance. 

MP 44 Proposals for mineral development affecting the best and most versatile agricultural land (Grades 1, 2 and 3a) will not be permitted if: (i) there is land of lower agricultural quality available (providing that this does not harm features of landscape character, nature conservation or historic significance); and, (ii) in cases where an agricultural after-use is proposed, the land cannot be restored to its former, or if possible, improved condition. 

MP 52 Proposals for the importation of materials to a minerals extraction site where minerals processing takes place will be permitted where increased lorry movements to and from the site would not give rise to unacceptable impacts on the environment or on local communities and: (i) importing materials enhances the use that can be made of existing processing and/or manufacturing plant without creating excessive demands on storage capacity within the site; or, (ii) importing materials promotes the use of secondary minerals and of recycled aggregate. Conditions will be imposed to limit the duration of the permission to ensure that continued minerals processing on the site does not interfere with any programme for site restoration.

If AI’s proposal is judged acceptable against these policies, then quite frankly what is the point of a Minerals Local Plan, the Public Inquiry and all the associated expense entailed?

And if all this isn’t enough, let’s not forget Devon Minerals Core Strategy Options Consultation Paper February 2011:

5.1.4 For as long as adequate sand and gravel reserves (i.e. a minimum of seven years’ supply) continue to be present at the existing quarries, there are no grounds to allow their further extension or new quarries. However, when the remaining reserves at the existing quarries decline to the point where further resources need to be identified to maintain the county’s landbank of sand and gravel reserves, choices are available on where those new resources should be worked.

‘HGVs make up approximately 5% of traffic flow and yet contribute more than 38% of the total NO2 emissions’

That’s what one survey found in Exeter. It’s something to remember when Aggregate Industries tells us that its HGVs would only make up a small proportion of traffic on the B3180 over the next 5 years.

Air pollution is in the news at the moment. The Supreme Court has ordered the UK government to take immediate action to cut NO2 air pollution - "the Government must prepare and consult on new air quality plans for submission to the European Commission... no later than December 31 2015". Air pollution is responsible for some 600,000 premature deaths in Europe each year; "29,000 early deaths a year in the UK - more than obesity and alcohol combined".

But air pollution does not just affect our biggest cities. Exeter City Council says that air pollution "may contribute to the deaths of 42 people in the city this year alone":

Exeter is one of the greenest and most beautiful places to live in the country. But no matter how good the air quality may appear, air pollution is an invisible potential health threat to everyone that lives and works here. Particularly vulnerable groups are children, pregnant women, the elderly and patients with pre-existing respiratory diseases.

DCC may not care about the adverse health impacts of air pollution on people living along the B3180, when it assesses AI’s application to haul as-dug sand and gravel from Straitgate Farm to Woodbury Common, 8 miles away for processing; DCC may not care about the impact of all the other associated heavy traffic a processing plant brings; however, what DCC will be required to assess is AI's air pollution impact on a site of European importance to nature. Planning guidance on air quality says:

When deciding whether air quality is relevant to a planning application, considerations could include whether the development would: Affect biodiversity. In particular, is it likely to result in deposition or concentration of pollutants that significantly affect a European-designated wildlife site, and is not directly connected with or necessary to the management of the site, or does it otherwise affect biodiversity, particularly designated wildlife sites. [5]

Natural England has already said that NOX pollution is impacting the East Devon Heaths. AI’s polluting million-mile haulage scheme, and the related HGV onward distribution traffic, would only cause more problems - for people and for nature.

Air pollution impacting integrity of East Devon Pebblebed Heaths

Natural England has identified that air pollution is adversely impacting the integrity of the East Devon Pebblebed Heaths. Pollution from extensive HGV traffic to, from and within Aggregate Industries' processing plant at Blackhill will be exacerbating this problem.

The Heaths are an internationally important site, and NE has produced a Site Improvement Plan:

Air Pollution: impact of atmospheric nitrogen deposition - Nitrogen deposition exceeds site relevant critical loads. Exceedance of threshold levels may affect heathland features by the transition of heather to grass dominance and the southern damselfly through changes to the vegetation mosaics. Action - Control, reduce and ameliorate atmospheric nitrogen impacts. Timescale 2014-20.

The Heaths are also protected under the Conservation of Habitats and Species Regulations 2010:

The Regulations require competent authorities to consider or review planning permission, applied for or granted, affecting a European site, and, subject to certain exceptions, restrict or revoke permission where the integrity of the site would be adversely affected.

In which case, how can a competent authority seriously entertain a million-mile HGV planning proposal for such an area - with the 5 years of significant nitrogen dioxide pollution it would bring?

NPPF: ‘The planning system should play an active role in guiding development to sustainable solutions’

Next week we will apparently find out exactly what Aggregate Industries' 'sustainable solution' is for East Devon - the one that involves hauling sand and gravel one million miles, through an area of European importance to nature conservation.

In the meantime, the issues page has been updated with relevant details, regulations and NPPF policies.

DCC has recently issued Devon Minerals Update No.10 - embedded here for convenience.

AI’s still not ready

People may remember how confident SLR’s Project Director for Straitgate was at the recent public exhibitions, saying that Aggregate Industries' planning application would be submitted by the end March - 'the first few days of April at the very latest'.

SLR has now advised DCC that the likely date for submission of AI's planning applications to quarry Straitgate Farm and to process the spoils on Woodbury Common will be 5 May. The formal consultation will begin shortly afterwards.

AI wants Straitgate - but not because of a lack of gravel at Uffculme

Apparently, there is still some confusion about the amount of gravel at AI's Uffculme sites.

Whilst it's true that Houndaller, which already has permission (to the west of Hillhead), is sandier - sand incidentally that AI is currently short of, Penslade (N6/N8) has a similar gravel component to Straitgate; at least it did in 2011, when AI’s Estates Manager confirmed to us that there was a "similar quality at Straitgate as at Uffculme".

As far as ownership, DCC has confirmed that "Aggregate Industries UK Ltd have mineral ownership rights over N6 and N8. They also have surface ownership of the majority of the sites". As far as quantities, DCC has said "Aggregate Industries have advised that the potential resource within that part of the Penslade site shown as a preferred site in our consultation document (i.e. most of N6 and N8) is 8.1 million tonnes".

HGVs thundering to and from Straitgate would be less than half the problem

Obviously, the sand and gravel from Venn Ottery currently going in to Blackhill to be processed has to come out again. The trucks taking the processed material out are on average smaller, meaning more movements out than in, many travelling on the B3179 through the middle of Woodbury.

It’s not quite clear after Aggregate Industries' exhibitions how many HGV movements would be generated specifically by Straitgate, before onward distribution to the wider market. Some people were left with the impression of 85 a day, others were left thinking it would be closer to 200. Enquires to AI have gone unanswered. In the past we have gone by AI’s Haulage Statement for Venn Ottery, which claims 110 movements a day for a 5-day working week, or 138 movements a day for a 4-day working week, 50 weeks a year, 400,000 tonnes pa, using 6-axle HGVs carrying up to 29 tonnes.

Whatever the claims, on 14 April for 4.5 hours the actual vehicle movements recorded going in and out of Blackhill were as follows:

Over the space of half a day, 97 truck movements were recorded going to and from Venn Ottery (equivalent to 194 for the day), with 230 vehicle movements recorded in total. This equates to approximately 115,000 annually.

This is a truly staggering figure. All the more so because the isolated factory that is generating all these HGV movements on our B-roads is sitting in the middle of an AONB, SSSI, SAC and SPA. All the more so because as recently as 2010 this arrangement received the blessing of DCC.

And AI will shortly be asking DCC again to rubber stamp a continuation of this situation - not to bring in material from a site 5 miles away this time, but to bring in material from Straitgate 8 miles away over a period of 4-5 years. When there’s an industrial site 2 miles away from Straitgate that could do the job, continuing to use Woodbury Common like this shouldn’t even be a question, let alone an answer.

Is this any way to treat ‘one of the most important conservation sites in Europe’?

Designated a Site of Special Scientific Interest, a Special Area of Conservation and a Special Protection Area, this area represents one of the most important conservation sites in Europe.

And yet these photographs show just what's happening on the East Devon Pebblebed Heaths. You would never know that Aggregate Industries had already been paid millions of pounds of public money to stop quarrying on the Common. Operations like this - especially without any adjoining active quarry to justify a continued presence - have no place in such important areas for nature, locals and visitors alike.

Why did DCC ever think that repeatedly allowing AI to carry on operating here was a good idea?

And what of Thorn Tree Plantation?

In 1999, Aggregate Industries was served with modification orders to stop quarrying at Blackhill. AI was later paid millions in compensation. Despite this, in 2002 AI won permission to quarry Thorn Tree Plantation, an adjacent area at Blackhill. AI worked this site until 2009.

In 2000, in documents approved for court purposes, AI's Divisional Estates Manager (Southern) put the company's chances of securing permission at Thorn Tree at 50:50, and said "if planning permission was turned down on that area it was doubtful in view of the small size of the site that an appeal would be considered". But DCC granted AI permission anyway, as DCC invariably does, and AI is still there today - now looking to stay until 2021, and no doubt beyond.

More than 5 years after quarrying ceased, this is what the site looks like today. How well does it sit in this important landscape? How is restoration progressing? People can make up their own mind.

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.

AI made assurances about ‘dry working’ at Venn Ottery too

To get some idea of what quarrying 100 acres of "best and most versatile agricultural land" at Straitgate Farm would look like on Ottery St Mary's doorstep - if Aggregate Industries were to get its way - here's a photograph of the company’s operation at Venn Ottery.

For Straitgate, AI has made assurances that "extraction would be restricted to a dry working option" - at least for Phase 1 - but for those 100 people reliant on the wells surrounding the farm for their drinking water, for those concerned about streams flowing to wetland habitats in ancient woodland, and for those worried about birds and airport safeguarding issues, this photograph won’t bring any comfort. Because AI made similar assurances to the Environment Agency back in 1998*, saying that Venn Ottery "does not involve working below the water table" - and look at it now.

* [Development Control Committee 4.3.98, 97/P1588, ROMP Conditions 10/09/98]

Pilot's-eye view

Amazingly, Aggregate Industries hasn’t yet ruled out Phase 2 - “wet working” below the water table - at Straitgate. This would involve another 6 years beyond the 4-5 already indicated; risking drinking water supplies and, based on AI's track record, another 6 years of wanting to haul material along the B3180.

AI’s aerial photograph of Straitgate Farm is, ironically, exactly the view that pilots and passengers have as they fly into Exeter Airport from the east. It should therefore be immediately obvious to anyone why the issue of water, habitat changes and increased bird numbers are so important in any quarry application:

Wetland creation is one of the most problematic development types in terms of birdstrike prevention at aerodromes.

Because if a population of seagulls, like those at AI's Blackhill and Hillhead Quarries for example, were to subsequently become an aviation hazard directly under a flight path, it's not always a straightforward issue to fix; in Lancashire for example, a controversial cull of seagulls to lower the risk of bird strike to aircraft has been blocked by the Court of Appeal.

If AI was more committed to doing green rather than promoting green...

Aggregate Industries' million-mile haulage plan across Woodbury Common is as far from green and sustainable as a quarry operation can be, and yet in a new report backed by the company, it proclaims its support for green infrastructure, saying "involvement in the report from the UK-GBC was very important for our business as we continue to search for ways to promote the importance of green credentials across the construction industry…".

One of Aggregate Industries’ commitments towards sustainability includes listening and responding to local communities and other key stakeholders. The report from the UK-GBC explains how adopting a green approach helps prepare businesses for climate change adaptation, as well as promoting biodiversity, human health and wellbeing… Involvement in the UK-GBC report continues Aggregate Industries’ commitment to promote greener business, with the company currently working with the Wildlife Trust in London to create a tool to calculate the value of green space.

Local people won’t recognise it as the same company.

Of course, if AI was more committed to doing green rather than promoting green, it would never have arrived at this ridiculous, polluting and unsustainable haulage plan for East Devon in the first place.

Aggregates Levy exemptions for Devon & Cornwall china clay waste ruled lawful

One 'uncertainty' in planning Devon’s future provision of sand and gravel was removed last week, as the European Commission reaffirmed that the Aggregates Levy exemption for secondary aggregates derived from china and ball clay operations in Devon and Cornwall is lawful and can be reinstated.

DCC had said: "...the removal of the Aggregates Levy exemptions for secondary aggregates introduces significant uncertainty into the prediction of future requirements for land-won aggregates".

But whilst public services are hit by spending cuts, the Government has bowed to industry lobbying by freezing the Levy at £2/tonne for the sixth year running. This is despite soaring profits at Aggregate Industries et al. The Aggregates Levy, which raises c.£300m pa, was introduced in recognition of the environmental cost of quarrying, and to encourage the use of secondary and recycled materials. Calls have been made for the Levy to be significantly increased to promote the use of waste materials in place of newly quarried aggregate; to clear up existing scars on our landscape before creating new ones.