1. Do you support or object to N6 and N8 as potential sites for sand and gravel extraction?
Support

2. What is the reason for supporting or objecting to the proposal?
The areas N6 and N8 are next to an existing quarry and landfill site and therefore extraction would be in line with guidance from Mineral Planning Policy Statement 1 (MPS1) “consider the benefits…of extensions to existing mineral workings rather than new sites”.

Hillhead in Uffculme already has millions of tonnes of sand and gravel with planning permission, but the site has been mothballed for several years while AI work at Venn Ottery and Blackhill. In the interests of sustainable development existing quarries should be worked out, together with sites next to them, before identifying new greenfield sites. N6 and N8 have good links to the road network via the A38 and M5, and the sites have less environmental difficulties than the southern sites. Processing plant can be put on site, therefore avoiding the need to transport as-dug material between sites. Again from MPS1: “take account of the benefit, including the reduction in carbon emissions, which local supplies of minerals would make in reducing the impact of transporting them over long distances by road”. The sites are ideally situated for both the Exeter and Taunton areas of growth.

3. Once mineral extraction is complete, it is suggested the site is used for agriculture, nature conservation habitats, woodland and recreation land. Is this proposed after-use acceptable to you?
Yes

4. Do you support or object to the western part of S7 as a potential site for aggregate extraction?
Object

5. What is the reason for supporting or objecting to the proposal? If you object, what is your greatest concern?
Here are what we consider to be the main reasons for objecting to a quarry on this site:

Water impact:
Flooding: The land at Straitgate is at the top of a hill and is an aquifer, acting like a sponge soaking up and storing rain which later comes out slowly (normally) into one of the three streams that run off the site. If the aquifer were removed by quarrying then the water would run off the site faster during heavy rain and slower during drier periods. Climate change predicts more changeable and extreme weather, and removal of the ground at Straitgate would exacerbate the situation.

The new A30 has already caused increased run-off into one of the streams. Everybody knows Ottery has a history of flooding, and the three streams from Straitgate flow directly down to Cadhay, Coombelake, and Thorne Farm Estate, areas where The Environment Agency map already shows a “significant” flood-risk status http://www.environment-agency.gov.uk/homeandleisure/floods/31650.aspx. A flood defence scheme is being built at Thorne Farm after the 2008 floods, but this makes no allowance for quarrying at Straitgate. If quarrying were to take place here the mineral operator would probably be told to build controls to minimise this flood risk, but this would have to be robust enough to last forever, and cope with whatever climate change brings. MPS1: “Operators should demonstrate that mineral working should not materially increase the risk of flooding at other properties or locations and, where practicable, should increase flood storage capacity”.

Groundwater: Again, because Straitgate is an aquifer storing water, it provides the drinking water for around 100 people, through wells, catchpits and boreholes around the site, and at Cadhay by way of a pipe from the springs in Cadhay Wood with water originating at Straitgate. It also provides water for three farms and one business, and one of the streams feeds the mediaeval fish-ponds at Cadhay that pre-date the 15th century grade I listed house. Removing the sand and gravel would reduce the amount of water that could be stored. In addition, quarrying brings the risk that pollution from fuel spillages etc. could enter the groundwater supply.

Visual impact: The site is prominently located on top of a hill and is overlooked from East Hill AONB and parts of Ottery. Traffic on the new A30 looks into the site, and any earth-mounds or stock piles would restrict the views of East Hill from the road.

Historic impact: Straitgate Farm is a dairy farm with a grade II listed thatched Devon longhouse built c.1580. If the site were to be quarried, the listed farmhouse would lose its agricultural setting for ever and would be left standing isolated on some plinth. Straitgate was previously known as Great Street Gate Farm, and Street Gate is mentioned in a Charter of 1061. This was the main access point to the Ottery parish. It was an important junction, where the old Roman road the Fosse Way (old A30) crossed the Saxon road (B3180) running from the Blackdown Hills to Exmouth, and would have been the most important or easily recognised point near Ottery. There is also a strong possibility of a prehistoric track/boundary running north south down the centre of the site. An archaeology survey would need to be completed before any quarrying took place.

Nature Impact: There are two County Wildlife Sites (CWS), Cadhay Bog and Cadhay Wood, with areas of ancient woodland and wetland habitats that are reliant on streams originating from Straitgate. Under Planning Policy Statement 9 (PPS9) authorities “..should not grant planning permission for any development that would result in its [ancient woodland] loss or deterioration unless the need for, and benefits of, the development in that location outweigh the loss of the woodland habitat”.

Although current guidelines recommend that the compensation for any loss of ancient woodland should be 30 times the area lost of new tree planting, as DCC recognise this does not suitably replace a habitat that has evolved over 100s of years. The CWSs are valuable biodiversity resources that if lost cannot be replaced and must be protected. Quarrying Straitgate and removing the aquifer may lead to changes in the water flow to these sites, more in winter less in summer, that would lead to irreparable harm. The other impact on nature would be the loss of hedgerows – often 100s of years old – and of mature trees.

Environmental impact: Quarrying at Straigate would have all the normal environmental impacts a quarry brings. In this case it would be worse because AI want to transport the material dug at Straitgate to Blackhill Quarry on Woodbury Common to be processed.

There has been quarrying at Blackhill since the 1930s, but in 1999 AI were warned that quarrying would need to stop after Woodbury Common was recognised to be of European importance for nature conservation, and they were later paid £5 million compensation. Woodbury Common, with over 800,000 visitors a year, has a list of designations protecting it: AONB, Sites of Special Scientific Interest, Special Protection Areas and Special Areas of Conservation, but after several planning extensions AI is still working there today, now processing material dug out at Venn Ottery. Quarrying at Straitgate would further delay the restoration of this site, potentially for many years.

DCC could make a real difference if they were to finally restrict quarrying and enforce restoration at Blackhill, thereby also significantly reducing the number of HGVs on Woodbury Common and the local area. Otherwise there would be 100x 44 tonne lorry movements a day along the Exmouth Road, B3180 – one truck every 5 minutes, 200,000 miles each year at 8mpg, bringing both pollution and traffic risk to local people, for many years. Furthermore, the additional distance of transporting aggregate from Straitgate to Blackhill to end-use, eg east of Exeter, negates the benefit of maintaining both north and south sites to minimise transportation – Hillhead to the same point is only one mile more and is via main roads, unlike the south.

The other environmental impact worth mentioning is dust blowing onto surrounding agricultural land or County Wildlife Sites. When the new A30 was built the dust from earthmoving reduced the milk yield from local dairy farms and the growth rates of surrounding crops. The impact of any dust on local agriculture from a quarry would obviously last longer.

Need: DCC’s latest figures for the end of 2010 show there are sand and gravel reserves with planning permission of 15.6 years. Assuming production stays level – in actual fact the useage of sand and gravel has been declining for the last 20 years, then in 2013, because the average used to calculate the figure will have fallen, there will be about 18 years of reserves remaining, which would give DCC provision until the end of their Plan in 2031. The argument could be made that DCC don’t need to make any plans at all for new quarries.

Viability: The Preferred Site being proposed is about 81 acres and, according to AI, there are about 3.6 million tonnes of sand and gravel. However AI’s statement makes no allowance for protective distances from houses, which DCC would have to insist on, or leaving a suitable distance from the A30 to avoid dust or restrict the view from the road, or leaving an area around the listed farmhouse and buildings. Neither do AI make allowance for only being able to quarry down to the water table, which DCC would insist on as at Venn Ottery, which reduces the materials available by about 40%. It is the pebbles that AI are interested in, not the sand for which there’s an excess of supply, and these pebbles form only around 40% of the total sand and gravel seam. When you allow for all these factors, and using borehole data, there is only an estimated one million tonnes of gravel at Straitgate. Is it right that so much harm can be done to the local area, for ever, for the sake of relatively so little material?

Are there any changes that could be made to this proposal that would make it more acceptable?
No

6. Once mineral extraction is complete, it is suggested the site is used for agriculture, nature conservation habitats and woodland. Is this proposed after-use acceptable to you?
Yes or N/A

7. Do you agree or disagree with our intention to exclude these sites from further consideration?
Agree

8. What is your reason for agreeing or disagreeing with our intention to exclude the sites?
The southern area has too many problems with water-related issues, flooding and groundwater, and the impact on wildlife sites.

Don’t forget! 

Tuesday 27 March, 4.30-7pm – drop-in session at West Hill Village Hall – Devon County Council Minerals consultation event
Monday 2 April, 7pm, Ottery St Mary Town Council Meeting, The Football Club (off Butts Road) presentation from Devon County Council officer, Andy Hill on the Straitgate Quarry consultation

The deadline for consultation responses is Monday 30 April.  Please include your name and address with any objection you make.