Thursday 6 September 2012

SA ‘audit’ raises inconsistencies

Now that it is clear that the Sustainability Appraisal (SA) was performed as an "audit" of the site appraisals rather than to inform them, as Dave Black explains in his letter of 10 August, an inconsistency arises that DCC will need to explain. Specifically, how did the Aggregate Industries owned Straitgate Farm (S7), with the joint second most references to "significant negative impacts" (where there is no likely mitigation) in the SA summary for the southern sites, manage to conveniently avoid any "showstoppers" in DCC's earlier site appraisal?

The Environment Agency (EA) also recognised the inconsistency, and wrote "It is apparent from the SA that some of the excluded sites may [be] preferable in environmental terms". DCC would argue that the site appraisal assessed a smaller area for S7 than the SA, but as the EA pointed out for one of the impacts "distance is irrelevant, as the wetland functioning of the [County Wildlife Site] is reliant on the watercourse supply". The SA considered S9 "too small to be viable" and did not assess it.

To many it will look like site ownership influenced DCC's judgement; the site appraisals would hardly have been different if Aggregate Industries had performed the exercise themselves.