If 1.2 million tonnes seemed a small 'benefit' for so much harm, what about 875,000?

Aggregate Industries' application for Straitgate talks about the extraction area containing "in the order of 1.2Mt of saleable sand and gravel" with further saleable mineral "anticipated" in the overburden 3.8; "the proposed ‘dry working option’ would avoid the need to excavate below the groundwater table" 3.37. 

After the Environment Agency confirmed that "Aggregate Industries have proposed to stop quarrying a metre above the water-table", a revised resource figure would have been expected, but a company spokesperson has claimed that this metre had already been factored in to its calculations and therefore it still has 1.2 million tonnes.

Whatever you believe, nowhere in AI’s application did it talk about leaving 1m of sand and gravel to safeguard groundwater. And AI would surely have broadcast the matter of charitably forsaking 500k tonnes gross, 400k saleable, to protect water supplies for people and ancient woodland; after all, it found space to talk about cutting back its own trees to mitigate 1.2 million HGV miles! Besides, if AI had factored in leaving 1m above the water table, it’s a mystery why statements like this were made:

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… 4.2

Fortunately, because we have the 1990 borehole data on which AI’s resource calculations are based, and because "an area of uniform shallow simple geology [covers] the western part of the site" 4.1, it’s relatively easy to estimate the available resource.

By combining AI’s geological map and AMEC’s groundwater map, with surface elevations (brown contours) overlaying maximum groundwater levels (blue contours), and taking a series of differences at 55 equally-spaced points across the site, the average depth over maximum groundwater was calculated to be 5.53m. Subtract from this, 2.28m (the average depth of topsoil/overburden - AI's figure) and 1m (the depth above the water table to be maintained), multiply the result across the 25.6ha (256,000m2 - AI's figure), and, assuming a density of 1.9 tonnes/m3 and 20% waste (AI's figures), we are left with about 875,000 tonnes, before any of the unproven "workable overburden".

The map of the combined contours is below; here’s the calculation:

(5.53-2.28-1.0)m x 256,000m2 x 1.9tonnes/m3 x 80% = 875,000 tonnes (saleable) 

Even assuming a margin of error of +/- 0.5m on each of the 55 differences, the resource figure falls in the range of +/-195k tonnes, or 680-1070k; i.e. still short of AI's '1.2 million'.

And of course, there won’t be 25.6ha by the time face angles, proper standoffs from the A30 - see Highways England’s response - and listed buildings are factored in; an area of 23ha, for example, could yield less than 800k tonnes. Bear in mind too, this submission in 2012 to the Competition Commission by Wardell Armstrong, ‘one of the largest teams of Chartered Minerals Surveyors in the UK’:

... no aggregates operator would consider (for example) trying to develop a sand and gravel deposit of less than one million tonnes. We have clients who have sites which have been turned down on this basis.

In 2012, DCC went to public consultation with an incorrect resource figure of 3.6 million tonnes for Straitgate Farm. This week, DCC's DMC committee will be asked to endorse the Pre-submission Draft of the new Devon Minerals Plan, before the start of a 12 week public consultation. This plan seeks to identify Straitgate Farm as a "specific site" for the future supply of sand and gravel, because there is "1.2 million tonnes of proven resource"; yet again, that so-called 'proven' figure looks incorrect before consultation even starts.

Given the ever declining and consistently overestimated resource, it’s time for AI to show exactly how it has calculated the recoverable resource at Straitgate, and exactly what assumptions have been made, so that we all know exactly what the damage to an East Devon farm and a site of European importance to nature is all for.

Clarification from the EA

Local people relying on the Straitgate aquifer for their drinking water will have read that AI’s planning application proposes to quarry down to the maximum winter water table level, not 1m above which has been typical at other nearby sites. AMEC's Hydrogeological Assessment says:

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... 4.2

Whilst the Environment Agency’s response to the application recommended that "a Section 106 agreement is put in place prior to the commencement of the works [requiring] the 'making good' of any derogation to an agreed list of water supplies by the provision of alternative supplies", the agency made no reference to AI maintaining 1m of unsaturated material to safeguard supplies.

We have since asked the EA for clarification, and have been advised that:

Aggregate Industries have proposed to stop quarrying a metre above the water-table. We expect DCC to make this a condition of any permission that is granted.

In which case, AI should now tell us the size of resource left at Straitgate - the size of the 'benefit' that should be weighed against the proposal's considerable harm. According to AI, the site contained "in the order of 1.2Mt of saleable sand and gravel" 3.8 with mineral extraction to the high groundwater level; a 1m depth of sand and gravel across a 25.6ha extraction area equates to about 0.5 million tonnes.

What would be ‘exceptional circumstances’?

The NPPF makes it clear that:

Great weight should be given to conserving landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty. 115 Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest. 116

Last week, the North York Moors Park Authority backed plans for a "£1.7bn potash mine after locals were wooed with promises of more than 1,000 jobs". The Chief Executive of the NYMNPA said:

I appreciate that there will be many disappointed by today's decision but Members felt that the long term benefits for the local, regional and national economy were transformational. This truly exceptional nature plus the measures proposed by the company to mitigate harm and deliver widespread environmental benefits to the Park over a long period of time tipped the balance in favour of approval.

Whatever your view on the mine, compare and contrast it with the truly unexceptional nature of AI’s application to process material at Blackhill, in an AONB.

Blackhill is also bordered by an SPA, an EU designated Special Protection Area, through which AI's 44-tonne HGVs would have to travel.

Kent County Council recently permitted the importation and deposition of clay, chalk, sand and gravel from tunnelling projects in the London area to a former clay workings, part of which is designated an SPA.

The application 'would benefit the breeding and over wintering bird population', 'would assist in meeting the conservation aspirations of the SPA' and 'the need to transport materials by road was avoided and this was consistent with the principles of sustainable development'.

Again, compare and contrast this with AI’s Blackhill application, the potential to harm the East Devon Pebblebed Heaths SPA, the unsustainable million mile HGV haulage scheme, and the benefit to no-one but a Swiss multinational.

Do records indicate dormice or not?

Aggregate Industries’ applications are riddled with inconsistencies. After the great crested newts debacle, it seems SLR had problems with dormice too, another European Protected Species. SLR writes:

Devon Biodiversity Records Centre (DBRC) was contacted in 2011 for archive dormouse records within 2 km of the proposal site, as part of a full ecological desk study... In order to augment this distribution information, publically [sic] available ecological assessment reports from nearby proposed and consented developments were also reviewed during the period between 2000 and 2012 2.1.

Despite all this, "The desk study did not return any records of dormouse within 2km of the site boundary" 3.1 which isn’t all that surprising because dormice are rare, to the point that the species is on the edge of extinction. However, SLR mysteriously asserts in the 'Executive Summary' to the document:

Records indicate that the dormice at Straitgate Farm site are probably part of a large and wide ranging population which extends to the south and east.

Which begs the question, do records indicate or do records not indicate dormice extending beyond the site? Dormice are unlikely to be crossing the busy B3174 to the south of the site. In fact, with roads bounding all sides of the site, the population at Straitgate may not be well connected to a large and wide ranging population; SLR simply has no idea where dormice extend to, or in what numbers.

In 2013, out of 100 survey tubes, SLR ecologists found 25 dormouse nests and eight dormice at Straitgate Farm. AI’s proposal seeks to remove over 2km of hedgerows across the site. In 2008, the UK reported on the implementation of the Habitats Directive for the dormouse. It stated that "the continued loss of hedgerows, particularly species rich ones, is a real problem" and declared that the Overall Assessment of the species was "Unfavourable – Bad and deteriorating. The species is in serious danger of becoming extinct (at least locally)".

In mitigation, AI claims 568m of new hedgerow was planted in 2014, and 2,007m will be planted as part of the restoration scheme, which in total is substantially short of the 5,748m of new hedgerow that Defra suggests should be planted to offset the expected loss. AI contends that such shortfall "must be placed in the context of creating [14,547m2] of new woodland and tree belt habitat" 8.261-8.263.

But as we know, the 10,547m2 has not been planted and the 4,000m2 was planted in the wrong place; in any case, woodland planting does not adequately compensate for the loss of hedgerows and the support they provide to bats and dormice.

Why is all this so important? In the group's submission, Charlie Hopkins makes it clear that:

The ES acknowledges that EPS Licences will be required from Natural England (8.218 and 8.222) in respect of bats and dormice. One of the derogation tests for the grant of a licence is that there be “no satisfactory alternative” (to the destruction/disturbance of habitats of EPS). The ES fails to address the derogation tests, and draws no conclusions as to the likelihood of the tests being satisfied. It is clear that an alternative site where EPS were absent or would not suffer habitat loss or disturbance would be preferable to Straitgate Farm. No such comparison of alternatives has been undertaken by the applicants.

Devon Minerals Plan: Pre-submission Draft

A DMC meeting will be held at County Hall at 2pm on Wednesday 15 July to endorse the Pre-submission Draft of the new Devon Minerals Plan, before the start of a 12 week public consultation. 

At this meeting, an officer will no doubt provide a summary of the work undertaken for the new plan and the results of previous consultations, and, although the public will not be permitted to speak, Cllr Wright and Cllr Channon are expected to address members of the committee. Local people with an interest are encouraged to attend, particularly because:

5.4.9 Policy M12 therefore provides for the supply of sand and gravel at Straitgate Farm, near Ottery St Mary, subject to extraction being limited to dry working above the maximum water table to avoid potentially adverse impacts on private water supplies and water-sensitive habitats.

1968 revisited

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

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

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

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

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

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

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

Has Highways thrown a curve ball?

Highways England, with responsibility for the Strategic Road Network and the A30, has responded to Aggregate Industries' planning application to quarry Straitgate Farm by saying:

The Environment Statement... states that the quarry would be excavated no deeper than the maximum groundwater level... The cross sections A-A and B-B indicate that the full depth of the quarry excavation would not be lower than the A30 carriageway. However, Highways England would like to see further cross sections to ensure that this is the case throughout the site. Depending on what these additional cross sections indicate, a review by a Geotechnical Engineer may be required.

In view of the above Highways England recommends that application DCC/3774/2015 not be determined for a period of 6 months to allow the applicant time to submit the additional information needed to enable us to fully understand the impact on the SRN.

And the level of Straitgate Farm in relation to the A30?

Revised landbank

The last figures published by DCC showed that Devon had sand and gravel reserves of 8.535 million tonnes, which included a small reserve on the Somerset side of the Devon/Somerset border. DCC’s Minerals Officer has now advised that:

I’ve just heard from Somerset County Council that they now regard the planning permission for this reserve to have lapsed. The reserve in Somerset should therefore no longer be included, and the correct sand and gravel reserve figure (at the end of 2013) is 8.135 million tonnes. We’ll be using this amended figure for the purposes of the emerging Minerals Plan.

In other words, Devon still has 10 years more than the 7 required.

Group responses to AI’s planning applications

An objection has now been submitted by Charlie Hopkins, MA (Oxon) PG Dip Law Solicitor (non-practising) Planning & Environmental Consultant, on behalf of Straitgate Action Group, to DCC in relation to Aggregate Industries’ planning applications:

Whilst the primary focus of this objection has been on planning policy issues, further detailed objections have been submitted addressing other matters beyond the scope of this objection. This document should be read in that context and in conjunction with those other objections.

A further objection from members of the group addressing these other matters can be found here.

An objection from West Hill Residents Association can be found here, and responses from various statutory consultees can be found at the end of the planning application documents here.

We know of many other people who have submitted substantive objections. We have been encouraged by these, and also to see Hugo Swire MP voicing his concerns again.

The formal consultation period finished yesterday. For those, however, still finding out about these damaging, unsustainable and controversial planning applications, DCC should consider any comments up until the date of determination.

AI wants to quarry down to the water table - of the aquifer that supplies 106 people

Which might not be so laughable - if AMEC knew exactly where the maximum water table was, and AI could be trusted not to quarry beyond it.

But after two years of groundwater monitoring, this is what AMEC says on the maximum groundwater levels - "there is uncertainty about how smooth the transition is because there is no piezometer in the centre of the Site and there is the possibility for steps in the water table related to faulting" 2.4 and "the two [maximum water table grids] therefore represent just two of the many possible interpretations of the data which themselves are based on an incomplete parameterization of the detailed groundwater dynamics of the site" 4.2.

And on the matter of trust, AI also made assurances to the Environment Agency not to quarry below the water table at Venn Ottery Quarry, and this is what it looked like a few weeks ago.

DCC and the EA will stipulate that "an unsaturated zone of at least 1m [be] maintained across the site", but as it stands, AI’s application is to quarry down to the maximum level and then backfill "by placement of 1m combined thickness of topsoil and subsoil over the quarry floor to replicate current ground conditions" 3.42. So AI already wants to play fast and loose with people’s drinking water.

And for the 106 people reliant on the Straitgate aquifer, who is to effectively monitor what goes on if AI is let loose with its excavators and dumper trucks, with all that sand and gravel and no-one looking? Who was monitoring Venn Ottery? The first that local people would know is when their drinking water supply fails or becomes polluted. And then what? Would AI connect people to the mains and pay their water bills in perpetuity, or would AI say 'the borehole readings seem fine - it can’t be anything to do with us'?

Human receptors - and the numbers you won’t find in AI’s application

SLR claims to have counted the bats and dormice, not the great crested newts, but there’s no mention anywhere in Aggregate Industries' planning application of the number of people that could be affected.

Besides all those who live along the B3180, who would have to put up with some 140,000 HGV movements over 5 years, SLR says: "Excepting a limited number of isolated farms and residential properties there are no other human receptors close to the site" 2.27.

What SLR should have said was within 200m of the site there are 61 properties with 146 permanent residents; furthermore planning permission currently exists for a further 17 properties (up to 50 further residents); furthermore Long Range Hotel has staff of 6, regularly 28 guests and daily swimming classes of up to 30; furthermore Kings School (1150 students) and Ottery Hospital are both within 2km, in relation to PM10 and PM2.5 carcinogenic dust particles.

On the subject of water, AMEC says: "Some of the springs as well as some of the wells are used for private water supplies" 6.

What AMEC should have said was that most recent figures show 106 people rely on the spring water from Straitgate for their drinking water supplies, together with 3 farms, and 2000 visitors to Cadhay's tearooms each year.

Did SLR and AMEC not know these numbers? Of course they did - they just didn’t want to say.

One map edited out of AMEC’s flood risk assessment

The Environment Agency expressed concern that Aggregate Industries’ plans for Straitgate could mean:

A possible change in recharge and runoff patterns (e.g. an increase in runoff and decrease in aquifer recharge during high intensity rainfall events ) as a result of removal of part of the unsaturated zone, with the potential to impact on: eastward flowing groundwater; the flow of springs; local private water supplies; the volume of groundwater draining to Cadhay Wood CWS and Cadhay Bog CWS. 7.104

AMEC has prepared a Flood Risk Assessment, and accepts that "the four watercourses which rise from springs and seepages at the margins of the BSPB around the site pose a flood risk to localised areas downstream from the site" 3.4.2. Amazingly, however, the only reference to the extreme flooding of 2008 in AMEC’s report says:

In [DCC’s Strategic Flood Risk Assessment], several significant flooding events in the East Devon Catchment are noted, of special significance to the Site was the flooding that occurred at Ottery St Mary (3km east of the Site) in October 2008; "This resulted in an estimated 350 properties flooding from main rivers, ordinary watercourses and surface water, with 25 people requiring assistance from the fire service. The incident is considered to be the worst flood event to have occurred in Devon in the past 25 years." 2.3.7

No mention of 2008 in Section 3.3 "Historic flooding". Which is odd, because the company was fully aware of the facts in 2013 - here’s AMEC’s report from that time, which included some of our photos and the map above. All traces of the impacts of 2008 have now been edited out. How can a comprehensive flood risk assessment ignore such an important event? After all, it was in 2008 that the Cadhay Bog watercourse flooded 50 properties at Thorne Farm Way, prompting the EA to build a flood defence scheme there.

Editing out this flooding event surely undermines the whole integrity of AMEC's Flood Risk Assessment.

But whilst AMEC and SLR happily write-off the flood risk to local people, tellingly, it warns AI workers:

Access points to the quarry should be clear of the four watercourses near the Site so that safe access and egress can be maintained during extreme rainfall. 5.1.1 A formal Site evacuation/risk management plan should be drawn up and staff briefed with regards to procedures if flooding affects parts of the quarry or one or all quarry access/exit routes. 5.1.2

The EA map shows all four watercourses from the site have a high risk of causing surface water flooding:

AMEC says that surface water runoff during any quarrying would be captured by "infiltration ponds... supported by the construction of an impermeable bund", such that "23% of working areas [would] be reserved for infiltration... 6.2 ha [15.3 acres] of infiltration area is required for every 26.4 ha of working area" 4.1.14. It’s anybody's guess what would happen after quarry operations have ceased, when the impermeable bunds and unsaturated sponge-like sand and gravel layer have gone, because "arrangements for the collection and disposal of surface water arising from the restored site" have not even been designed. 3.57

Here are photos of the damage that flooding immediately downstream of the site can do, in 2008 and in 2012; the two on the left appeared in AMEC's first report, but, unsurprisingly, not the report that supports AI's planning application. 

The EnviroCheck maps are copyright © 2012 Landmark Information Group drawing from sources which themselves are protected under Crown Copyright (Ordnance Survey, Environment Agency, British Geological Survey, and other public authorities) or under copyrights owned by private enterprises. You are kindly requested to use these maps solely for activities relating to the Straitgate Action Group, as other uses may not fall under the licence granted.

What maximum number of HGVs would SLR have quoted if we hadn’t counted them?

AI’s planning application for Venn Ottery in 2010 talked about an average of 138 HGV movements a day over a 4 day week, yet, on the one random day we checked, it was 194.

SLR’s Transport Assessment claims that this figure we chanced to count also happens to be the maximum number of HGV movements, and that there were only 3 days in the last 12 months like this:

Over the previous three years an average of 398,000 tonnes of material per year has been extracted and transported to Blackhill Quarry. This is equivalent to a daily average of 67 HGV trips each way, or a total of 134 movements each day, with a maximum number of movements up to 194 seen on occasion. 2.3.1 …in the past 12 months there have been three days during which HGV trip generation exceeded 90 trips per day (180 movements). 5.2

What's the chance of that??

AI's proposals for Straitgate Farm entail some 140,000 HGV movements over 5 years, but SLR writes this off and says "the increased flows along [the B3180] are insignificant to cause a noticeable impact to road users" 4.3. There are likely to be many statements in SLR’s transport reports that will anger local people; here’s one that might - it’s the last paragraph of the Transport Assessment:

Based on the findings of this assessment it can be concluded that the proposed development will have no material adverse impact on the operation or safety of the local road network. The proposed mitigation measures would offset any adverse impact generated by the proposed development. The benefits of any mitigation would be extensive, improving operation and safety beyond that experienced in the existing situation. 8.0

And the almighty mitigation measures that would offset the 1.2 million HGV miles, the impacts on road safety, air pollution and climate change? AI offers to cut back the trees on its own property, and change the Old A30/B3174 road junction to facilitate its own trucks 7.0. Local people will be thrilled.

In our view, SLR's transport reports for the Straitgate proposal are as far removed from reality as any we have seen. We suggest local people read these sections, here and here, and then tell DCC what really goes on along the B3180.

Homes 70m away, retirement homes 100m away... and AI says 'trust us on dust'

A dust assessment forms part of Aggregate Industries’ planning application for Straitgate. It claims:

The potential for fugitive dust emissions from the proposed excavation of sand and gravel at Straitgate Farm is minimal due to the inherently high moisture content of the ‘as dug’ material. 1.2 Notwithstanding this and in order to ensure that the mitigation measures are appropriately adhered to, it is recommended that a detailed scheme of dust management and monitoring be prepared pursuant to a condition for approval by the local planning authority. This will be prepared by the applicant… 1.4

Furthermore, for properties (including "high sensitivity" retirement homes) where "there is the potential for an intermediate dust impact… the operator will ensure the diligent application of appropriate mitigation measures as outlined in section 8.0. This will ensure an insignificant impact from fugitive dust." 6.4

But AI employs the same mitigation measures at Blackhill - and this is what it can look like:

Would this be AI's idea of insignificant? 

Some homes are as close as 70m to the edge of the proposed workings at Straitgate. The company has reneged on an assurance made by AI’s Head of Geological Services in 2013, that future plans would "incorporate a 100m standoff from properties along [Rhubarb] lane (... at some points our extraction boundary came to within 65m...)".

We have written about the health impacts of dust before. Even a 100m standoff from excavators and dumper trucks would not be enough with dust emissions like the ones above. We all know AI is desperate to maximise its recovery of Straitgate's ever shrinking resource, but any permission must have appropriate standoffs to protect the health and amenity of local people; 70m is absurd.

Can AI demonstrate ‘exceptional circumstances’ to justify the use of an AONB to process sand and gravel, and not Rockbeare or another industrial location?

Aggregate Industries wants to haul as-dug sand and gravel from Straitgate across Woodbury Common, an area of international importance to nature in an AONB - 1.2 million HGV miles over 5 years - because, it says, it is not able to process the material at Rockbeare, one quarter the distance away.

In recent advice, DCC said:

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.

We have written about what might represent 'exceptional circumstances' before, but AI claims it has to use the AONB because its derelict industrial site at Rockbeare is too small:

Although the processing plant at Blackhill occupies just over 1 ha in area, and could therefore be accommodated within the Charcon Concrete plant area which is now closed, there is insufficient space elsewhere on the site for the finished product stockpiles. At present AI uses 3.85 ha of land at Blackhill Quarry for stockpiles, an area that would be increased if some stockpiles could not use the old quarry faces to reduce their land take. This area of land is not available at Rockbeare Quarry. 5.35

Which seems odd, because this tool measures the site at over 16 ha:

There are, of course, no 'exceptional circumstances' why AI has to process material in an AONB; in fact, SLR confirms that Blackhill is "the applicant’s preferred option" 5.39, not the applicant’s only option.

What's driving these unsustainable plans is AI's bottom line, and that of its Swiss multinational parent; again, SLR helpfully confirms this by telling us that staying at Blackhill "would enable best use to be made of the investment that has already been made" 5.39, which is no reason at all to continue to impact a Natura 2000 site or the East Devon AONB.

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