Greytops West Hill Road West Hill Ottery St Mary Devon EX11 1TY June 2015

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1 24 June 2015 Greytops West Hill Road West Hill Ottery St Mary Devon EX11 1TY Ms Sue Penaluna Planning, Transportation and Environment Devon County Council County Hall Topsham Road EXETER EX2 4QD Dear Ms Penaluna Application DCC/3774/2015 Quarry development for the extraction of sand and gravel at Straitgate Farm extending to ha including new site access onto Birdcage Lane at northern end of site, together with staff welfare facilities, car parking and wheelwash Straitgate Farm, Exeter Road, Ottery St Mary 1. West Hill Residents Association object to this application. 2. Need 2.1. We do not consider that the need for this quarry has been proven. The amount of available sand and gravel amounts to only 1.2Mt. The amount of aggregates used has fallen over recent years. Though it is necessary to maintain a 7 year supply, Aggregate Industries ( AI ) have not shown that it would not be possible to meet demand for many years from alternative sites under their ownership. Also there should be increasing use of secondary aggregates, which should lessen the demand for new quarry sites such as Straitgate Previously AI have proposed a second wet working phase of extraction at Straitgate. The Environmental Statement does not consider the environmental impacts of this, which would be very considerable. This application must not in any way be considered to set a precedent for any such later application. 3. Policy 3.1. The Devon Mineral Local Plan 2004 is the relevant adopted policy. Straitgate is not mentioned as an Area of Mineral Resource, nor as a Mineral Consultation Area. This application is therefore not consistent with the development plan. The emerging Minerals Plan proposed to include Straitgate, but as there has been widespread opposition to this, it should not be accorded much weight.

2 2 4. Agricultural Land & soil 4.1. The agricultural land at Straitgate is Grade 3a, which is best and most versatile land. It is currently being used for dairy farming. The economic values of BMV land must be taken into account (NPPF 112) and lower quality land used where possible. Soil itself is a precious commodity and therefore great care should be taken of it. Using this land for a quarry would be contrary to policy. 5. Landscape and visual impact 5.1. The quarrying activities would cause harm to the local landscape during the operational life of the quarry. Restoration would partially reverse this, but the original field boundaries are not being replaced. The visual impact would be significant and adverse. The site is on the main gateway access to Ottery St Mary. Distant views of the quarry will also be possible from East Hill, and from inside East Devon AONB. 6. Airport safeguarding 6.1. The concerns of Exeter Airport, regarding bird strike, are serious and should be given considerable weight. It should be noted that some of the proposed planting for mitigation would have a further adverse effect by penetrating the OLS, and is contrary to the CAA Aerodrome safeguarding advice. Any ponding of water during quarrying operations would add further hazards by attracting birds. 7. Heritage Assets 7.1. The impacts on Heritage Assets are very important. Cadhay is Grade 1 listed, and therefore needs the greatest level of protection. The medieval fishponds depend on a water supply from Straitgate. Also the ancient woodland at Cadhay bog also depends on the water supply from Straitgate. Any potential for harm to these should be given considerable weight Straitgate farmhouse is Grade II listed, and dates to Part of the setting of the farm houses are the surrounding fields. The field pattern is ancient, in particular the north-south field boundary, which would be totally removed in the quarry operations. This damage would be permanent. This harm should also be given considerable weight The Devon Minerals Plan Policy MP5, NPPF paragraphs 132, 133 & 134, and East Devon Local Plan policy EN9 all place great weight on the conservation of heritage assets and their settings. 8. Hydrogeology 8.1. AI claim that restricting the working to dry working means that there is a negligible effect on water flows, and that private water supplies to local residential properties will not be affected, nor will the water supply to Cadhay and Cadhay bog. However, the Environment Agency raise concerns that the

3 3 Environmental Statement does not consider the loss of aquifer storage which would result from removal of the Budleigh Salterton Pebble Beds through either wet or dry working. Removal of the Pebble Beds could potentially result in more flashy groundwater and surface water flow, and a reduction in water resources during dry periods. This could adversely impact the numerous groundwater and spring abstractions down-gradient of the proposed quarry We therefore consider that AI have underestimated the adverse effects. There are real concerns still about the potential to contaminate or affect local domestic water supplies, the supply of water to the medieval fishponds at Cadhay and to Cadhay bog. Additionally there is a risk of aggravating the flood risk to Ottery St Mary by removing a natural water storage facility. 9. Transporting material 9.1. The proposed route is onto Birdcage Lane, the old A30, Daisymount, then the B3180 to Blackhill quarry, a distance of 13km. The B3180 runs through the western edge of West Hill There would be significant levels of air pollution from this (CO2, No2 and particulates) from up to 200 HGV movements per day. The alternative routes via the A30, A3052 and B3179 through Woodbury should be discounted as they would incur even greater environmental pollution. In particular the route through Woodbury would have similar adverse consequences as through West Hill The noise assessment states that there would be a negligible increase in noise for residents of West Hill. We profoundly disagree with this. West Hill residents have already been exposed to noise from HGV movements to and from Marshbroadmoor, and know from firsthand experience that the noise and vibration are significant In addition there is no consideration of the damage to roadside verges and banks by HGVs using the narrow roads and passing each other. Also there has been significant damage to the road surface and structure which has necessitated the B3180 being closed for several weeks to effect repairs. Also there is a significant risk of accidents due to the frequent HGV movements, particularly on the narrower sections of road The cumulative effects of noise, vibration, damage to the road and roadside verges, and accident risk mean that transporting material to Blackhill for processing is unacceptable. The only acceptable location for processing is at Rockbeare quarry. We do not agree that the site problems there are insuperable. 10. Processing at Blackhill We consider that it is completely unacceptable to continue using Blackhill quarry for processing aggregates. Blackhill quarry is on Woodbury Common, a Natura 2000 site which has the highest level of European protection under the

4 4 Habitats Directive. It is an SSSI, SPA and SAC, and is also inside the East Devon AONB The as dug material quarried at Straitgate would contain high levels of nitrates due to the effects of intensive farming over many years. During the processing and washing, this would leach out into the local water supply and into the soil. This would have a very adverse effect on the very sensitive environment at Blackhill quarry. Nitrogen levels are already close to the maximum critical load for the heathlands Quarrying at Blackhill was curtailed in 1999, apart from Thorn Tree Plantation, because it was judged that the impact of mineral working put at risk the integrity of the wildlife interest in the SPA site. Processing should have been stopped and restoration completed by March Devon County Council extended permission for processing at Blackhill in 2010 when the Venn Ottery Quarry was reopened, but applied a condition that processing should stop by 31 December Paragraph 116 of the NPPF states that permission for major development inside the AONB should be refused except in exceptional circumstances. We do not consider that AI have shown that there are exceptional circumstances, or sufficient public benefit, to overcome this policy. Policy EN4 of the East Devon Local Plan also applies. Policy MP 2 of the Devon County Minerals Plan states 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 We do not consider that permission to continue processing at Blackhill (subject of a separate planning application) should be permitted. The alternative site at Rockbeare Quarry would be far less harmful. 11. Planning balance The benefit of the scheme, in achieving the supply of aggregates, is small only 1.2Mt, which must be set against the harms of the scheme. These include: opening up a new quarry on good agricultural land; the adverse effects on local water supplies to domestic properties and to Cadhay, and the increased flood risk to Ottery St Mary; the adverse landscape and visual impacts; adverse impact on airport safeguarding; the harm to heritage assets and their settings; the harms of transporting the material for processing on the local road network and noise and nuisance for local residents;

5 5 the harms of processing the material at the very sensitive location of Blackhill quarry, inside a Natura 2000 site Therefore it is clear that the harms significantly outweigh the benefits, and this application should be refused. Yours sincerely Dr Margaret Hall Chairman, West Hill Residents Association