Applications DCC/3774/2015 – Quarry development for the extraction of sand and gravel at Straitgate and processing at Blackhill quarry

Policy implications
The planning applications from Aggregate Industries to quarry at Straitgate Farm and process at Blackhill Quarry on Woodbury Common are contrary to planning policy for the following reasons:

– The application is contrary to the adopted minerals plan, which does not have Straitgate listed as a quarrying site.  Although the adopted minerals plan is technically out of date, the secretary of state has instructed that existing policies are saved until replaced by the new minerals plan.

– Although the emerging minerals plan prefers Straitgate Farm as a site for quarrying, it has been demonstrated in 2012 that there is significant public opposition to this. The emerging minerals plan is not yet approved for public consultation.

– Devon County Council has instructed Aggregate Industries, in accordance with national and international guidance and EU legislation under the habitats regulations, to cease its processing operation at Blackhill Quarry by December 2016.

– Allowing processing at Blackhill Quarry to continue for a further five years would delay its restoration for at least five years, with adverse ecological implications, which would be contrary to local, national and international guidance.

– Blackhill Quarry is in a location designated an area outstanding natural beauty (aonb).  Par 117 of the national planning policy framework (nppf) states that development should only take place in an aonb if it is in the public interest AND there are exceptional circumstances.

– Paragraph 119 of the nppf states that the presumption in favour of sustainable development DOES NOT APPLY where development requiring appropriate assessment under the birds or habitats directives is being considered, planned or determined.

EU legislation
– Paragraph 118 of the nppf states that proposed development on land within a site of special scientific interest should not normally be permitted.  However, Blackhill quarry is in a special area of conservation and special protection area, providing vital habitat for rare birds such as the nightjar and dartford warbler. The scarce southern damselfly also thrives there.

Trees and hedgerows
– Dozens of veteran, possibly ancient deciduous trees are set to be felled to accommodate the quarry at Straitgate Farm.  Over one mile of ancient hedgerow is set to be lost, resulting in a significant loss of habitat.  Paragraph 118 of the nppf states that planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees, found outside ancient woodland.

– Lack of justification
Par 145 of the nppf states that councils must hold only a seven year sand and gravel landbank.  Devon has 18 years worth of supply, with just over 8m tonnes in reserve.  The demand for sand and gravel has declined steadily over many years with the introduction of the landfill and aggregates taxes, which means far more recycling than before. There is NO NEED to quarry at Straitgate Farm.

Major underground water course
Aggregate Industries now state that they will not quarry as far down as the water table. Although it should be noted that this was most certainly the original plan put forward in 2012 as a proposal for the emerging minerals plan. 

Aggregate Industries tests have found that to quarry into the aquifer would be unacceptably environmentally damaging, as the major aquifer concerned feeds ancient woodland (wildwood perhaps dating back to the ice-age) at Cadhay Bog, in particular and also Cadhay Wood.

The revised plan to quarry less deeply, should still be of serious concern because the water table height varies and so the possibility of irreparably damaging the aquifer (recognised as vital by the Environment Agency as a major underground watercourse) remains a significant worry.

Transport
Up to 200 lorry movements a day would take place between Straitgate Farm and Blackhill Quarry, if the development was approved. This is considerably more AI related heavy goods traffic than currently travels the B3180 and there would a serious adverse impact on people living along the B3180 and travellers who already get stuck behind the existing quarry traffic.  There are particular concerns about more articulated lorries crossing the junction at the Halfway House.

It is very important to note that there has been one death in the past five years at Tipton Cross on the B3180. Par 32 of the nppf states that where the transport impacts are severe, an application can be refused.  I would argue that up to 200 articulated lorries a day travelling along this narrow road and the Halfway House junction, along with its accident history, can be described as severe.

Aviation safety
Exeter Airport has long raised concerns about the danger of birdstrike, resulting from birds gathering at the quarry ponds.  This is an issue which must be given very serious consideration.

Economic impact
Stratigate Farm is currently a successful and working dairy and beef farm – and has been for probably centuries. Ripping up 100 acres of prime agricultural land for quarrying could mean that a farm business, perhaps many centuries old, could be destroyed, which would be bound to have a negative impact on the local economy with the ceasing of local trading with suppliers and buyers.

Listed building
Straitgate Farm is a grade II listed building. A quarry would have a significant adverse impact on the setting of the farmhouse, which would be left standing on an isolated plinth, if the application is approved. Par 134 of the nppf states that where a proposed development would lead to substantial harm or total loss of significance of a heritage asset, consent should be REFUSED unless it can be demonstrated that the development is in the public interest.

Agricultural land
Straitgate Farm is on grade 3a land, which is classed as best and most versatile agricultural land in the nppf.  Par 112 of the nppf states that local authorities should take into account the economic benefits of best and most versatile agricultural land.  Where such development is deemed to be necessary, authorities should seek to use poorer quality land.  The economic benefits of farmland remaining as it is, is clearly necessary for the future of Straitgate Farm.

Visual intrusion
A 100 acre quarry at Straitgate Farm would be clearly viewed from East Hill – an area of outstanding natural beauty.  It would therefore, cause damage to the setting and character of Ottery St Mary.

There are overwhelming reasons to refuse this application. I trust that it will be.