Tuesday, 29 March 2016

Straitgate downgraded from ‘Specific Site’ to ‘Preferred Area’

Only two months ago, DCC was stubbornly defending the merits of including Straitgate Farm as a 'Specific Site' in its new Minerals Plan - despite numerous objections to the Council on the matter, despite the landowner of part of the site not being supportive, despite being warned at the DMC meeting on 27 January that there were "fundamental issues that cannot be ignored".

Straitgate was the most contentious issue at that DMC meeting; it consumed the bulk of the discussion on the Minerals Plan, despite the Chair not wanting to hear about Straitgate at all: "this is about the strategic document, it is not about site specific". DCC’s Head of Planning argued that Straitgate’s "been through numerous levels of evaluation - it clearly fulfils the criteria for the Plan".

Now it turns out that it was about "site specific" after all:
To address matters raised in response to the Minerals Plan pre-submission consultation, together with the issues and questions recently published by the Inspector, Devon County Council has prepared draft modifications to the Plan.
Straitgate’s designation has been downgraded from 'Specific Site' to 'Preferred Area'. Here are links to the Examination page, the Main Modifications and the second draft Devon Minerals Plan.

Specific Site is "where viable resources are known to exist, landowners are supportive of minerals development and the proposal is likely to be acceptable in planning terms", a Preferred Area is "areas of known resources where planning permission might reasonably be anticipated".

DCC maintains that the reason for the volte-face over Straitgate is:
To reflect information arising since the presubmission consultation
However, DCC was advised of the position of the 3rd party landowner last June - two months before the start of the presubmission consultation. Furthermore, given that AI's revised plans will exclude the use of this 3rd party land, one could assume that a 'Specific Site' designation would now be easier to defend, not harder, which makes the downgrade from where "the proposal is likely to be acceptable in planning terms" to "where planning permission might reasonably be anticipated" more telling.

NPPF planning guidance encourages mineral planning authorities to designate Specific Sites:
Designating Specific Sites in minerals plans provides the necessary certainty on when and where development may take place. The better the quality of data available to mineral planning authorities, the better the prospect of a site being designated as a Specific Site.
So, the move could also be seen as a reflection of the hash AI has made of its Straitgate application.

However, even a 'Preferred Area' designation would appear unsound, given that AI says it can only process Straitgate’s material at Blackhill in the AONB - for which no provision has been made in the new Plan, for which no 'exceptional circumstances' have been demonstrated, and for which planning permission cannot therefore "reasonably be anticipated".

In the news

Earlier this month, we wrote that if AI now wants to use the main road in to and out of Ottery it should at least tell local people. The Herald reports that AI "will not be holding any further public exhibitions – choosing instead to distribute information leaflets to householders"; for its last applications it did both.

AI says the reason it now wants to use the Exeter Road B3174 for its site access, for up to 200 44-tonne articulated HGVs a day - one every 3 minutes:
...is to address concerns raised about the transport of materials. Instead of using the more rural Birdcage Lane to exit the Straitgate site, we will be proposing an alternative site entrance. We feel this will provide a safer way for vehicles to enter and exit the site and it shows that we are acting on feedback from the community.
This is, of course, utter nonsense.

Firstly, it is completely the reverse of what AI said last year:
The southern option, onto the B3174, was dismissed early in the process on highway safety grounds. It would have been too close to existing accesses, including the access to Straitgate Farmhouse, and the vertical alignment of the highway at this point would compromise visibility. It was decided therefore to create a new access at the northern end of the site... 5.44
Secondly, the simple and widely known fact of the matter was that AI didn’t have the rights to use 3rd party land for its site access at the northern end of the site. Only when AI realised there was no possibility of obtaining access rights to this land did it finally withdraw the application; it had nothing to do with "acting on feedback from the community".

The Exmouth Journal quotes AI as saying "following our positive discussions with residents... to address concerns raised about the transport of materials", which is again some stretch given that it was Hugo Swire MP that represented the angry residents in question.

Is there anything that AI won't spin?

Thursday, 24 March 2016

Group response...

...to Aggregate Industries' Blackhill Houndaller planning application, DCC/3816/2015, can be found here.

Wednesday, 23 March 2016

Houndaller waste material insignificant to Blackhill restoration

From what Aggregate Industries claims - in its crazy scheme to import 100,000 tonnes of sand and gravel all the way from Hillhead into Blackhill for processing, each round trip almost 53 miles - the waste material from Houndaller is pretty important to the restoration of Blackhill, crucial in fact:
The silt (contained in the unprocessed material) being brought in from Houndaller Quarry would ensure that the steep sided former quarry void in the south-eastern lagoon would be filled and more sympathetically restored, in accordance with the consented restoration and aftercare scheme. 6.15
It’s a bold claim. But it doesn’t stop there. To justify the exceptional circumstances that the NPPF requires for major development in an AONB, to justify all the 44-tonne HGVs traipsing back and forth across Woodbury Common and the East Devon Pebblebed Heaths SAC SPA:
...the additional silt that would be generated from processing Hillhead (Houndaller) mineral would supplement the filling of the lagoons at Blackhill to meet the approved restoration contours of the site upon cessation of mineral processing operations, allowing a heathland restoration commensurate with the SSSI, SAC, SPA designations of the surrounding common.
Should materials not be permitted to be imported to the site, this could potentially result in the processing plant at Blackhill Quarry otherwise remaining under-utilised for the remainder of the planning permission and the permitted restoration not being able to be completed.
Importing this material is required in order to achieve approved ground contours and restoration. 1
More bold claims. Are any true?

If we assume - using AI’s figures - a maximum of 20% wastage, then from 100,000 tonnes this would amount to some 20,000 tonnes or about 10,000m3. AI has already said, in its application to quarry Straitgate Farm, that the area in question, Lagoon 3 (Area 6), has a void capacity of 218,000m3 and that "infilling of this lagoon would achieve the approved restoration contours" 8.12.

The waste material from Houndaller would therefore fill less than 5% of this void. It would make no significant difference to the restoration of Blackhill, particularly given the steep sides elsewhere in the quarry - see below. The statements in 6.15 and elsewhere are therefore false; yet more fabrications, fibs, inventions, deceptions; the material would NOT ensure the filling of any steep sided former quarry void; the material would NOT ensure the completion of any permitted restoration.

More to the point, the waste material from Houndaller may actually be damaging to Blackhill's restoration; phosphorus levels for the Hillhead material range from 63mg/kg to 173mg/kg, pH values from 5.89 to 7.13. The approved restoration scheme for Blackhill says:
...all soils will be tested for pH and nutrient content to ensure that they are suitable for heathland restoration i.e. phosphorous is less than 10mg/kg and that the pH is between 3 and 5 3.6.1
Moreover, the restoration scheme does not rely on importation of material from either Houndaller or Straitgate. For Area 6, quite the contrary in fact:
It is expected that the majority of the available void will be used during the remaining life of the processing plant (i.e. to the end of 2016). The final height of the silt is not yet known but may be higher than originally thought. 4.8.2
On completion of silting operations at the end of 2016, the eastern wall will be clear felled and the timber removed from the site and soils will be stripped and stored for use in the restoration of the area. The eastern wall will then be removed to a depth of 3 metres above the surface of the drying silt. The material from the wall will be used with other indigenous material to form a capping to the silt body, approximately 1 metre in depth, and to batter the side slopes. The soils will be thinly spread over the whole area. 4.8.3
Perhaps AI should explain how, in little more than 2 years, it managed to go from a final height of silt that "may be higher than originally thought" to a shortfall of 218,000m3, particularly given that Venn Ottery has yielded more material than originally expected. In any case, a DCC officer has already explained that if material from elsewhere was not available to meet any shortfall, the already agreed earthworks would produce a perfectly acceptable landform.

AI was granted planning permission to continue processing at Blackhill in 2011, with Condition 7:
The restoration shall be carried out in accordance with the approved scheme, or such alternative schemes as may be subsequently approved in writing by the MPA.
It's a condition, not a suggestion.

Preparation is everything...

SLR are the team of consultants charged with securing planning permission for Aggregate Industries at Straitgate. SLR’s Head of Marketing has recently written about "Why joined-up EIA de-risks planning".

It was, of course, after one of SLR’s joined-up Environmental Impact Assessment exercises that AI withdrew its planning applications for Straitgate and Blackhill. There's not much to smile about in AI's ongoing quest to quarry the living daylights out of the East Devon countryside, but perhaps local people would like to see how little they recognise in these claims from SLR:
... how can you ensure your development sails through in 13 weeks as opposed to being mired in costly battles?
Preparation is everything and it is absolutely critical to get the right players in place from the outset. Increasingly this means an experienced team with a joined-up approach so that issues are identified and proactively resolved from the outset. It means having the right creative approach to masterplanning and landscape so that development complements and enhances its surroundings, especially if AONB or Green Belt is a consideration. It means proven strategies in relation to flood risk and sensitive mitigation of ecology and archaeology. It means early and meaningful engagement with all stakeholders, especially local communities, by ensuring there really is something in it for everyone with development that enhances and becomes an asset to their community. It means designing-in a strong sense of place with sensory considerations like health, wellbeing and security as an innate part of the vision. It means using savvy planners who fully understand the best way to position the development and seamlessly pull together the EIA to support your application.
In short, an intelligent, sensitive 'one team' approach will leave little space for refusal. All local authorities want good development and 'good' is actually quite well defined; the key is ensuring you have the right team to guide you towards that consent.
If AI - before the countless delays and requests for further reports, information and clarification - had been taken in by this sort of talk, by the promise of an experienced team with a joined-up approach so that issues are identified and proactively resolved from the outset, they must surely be regretting it now.

Tuesday, 15 March 2016

AI wants to process Hillhead material at Blackhill - each round trip 52.8 miles

In November last year, we wrote that Devon's sand and gravel soap opera has taken a new and bizarre twist, after Aggregate Industries lodged a planning application to process material from Houndaller (Hillhead Quarry, near Uffculme) at Blackhill on Woodbury Common.

Following the supply of further information, that application DCC/3816/2015 has now been validated, and is open for comments for 21 days.

AI wants to process 100,000 tonnes of sand and gravel on a campaign basis at a maximum rate of 1,900 tonnes or 134 HGV movements per day:
6.12 While the distance travelled by HGVs will increase, when compared to those previously originating from Marshbroadmoor (Rockbeare) Quarry, the optimum route has been selected in order to avoid any potential significant adverse impacts on amenity by utilising the M5 motorway for much of the distance. The proposed route would see HGVs traveling from Houndaller (Hillhead) Quarry to Blackhill Quarry via Broad Path onto the A38 before joining onto the M5 at junction 27. HGVs will travel along the M5 before exiting at junction 30 onto the A3052. From the A3052 HGVs will take the B3180 from which they can access the site.
There are a number of distances mentioned in the supporting documentation but funnily enough not actually the one that matters; numbers always seem to be a problem for AI - so many times being wrong, misleading or absent. Because, whilst AI mentions Marshbroadmoor, which is 6.7 miles from Blackhill, what it fails to say is that Houndaller is 26.4 miles from Blackhill, a round trip of an incredible 52.8 miles for each load, or 185,000 miles in total; it's good to see that AI is thinking about sustainability again, and about CO2 and NOX emissions.

As we said before, this application makes a mockery of minerals planning in Devon; it makes a mockery of the draft Minerals Plan's claim that "Maintaining the production of sand and gravel from the southern and northern parts of the Pebble Beds is also important in minimising transportation distances" 5.4.8.

In its request for further information, DCC has obviously asked AI to spell out what exceptional circumstances exist that should permit the processing of this material in an AONB. The responses given in the letter below are frankly laughable. The NPPF is clear when it says that:
Planning permission should be refused for major developments in [AONBs] except in exceptional circumstances and where it can be demonstrated they are in the public interest. 116
The approach adopted by the Applicant towards AONB planning policy betrays a fundamental misunderstanding of the purpose of paras 115 and 116 of the NPPF. It is clear from the Framework that major development in an AONB should be regarded as damaging per se. Para. 115 states 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.”
Any major industrial development in an AONB must therefore be regarded as wholly inappropriate and undesirable in such a designated area, thus the requirement of meeting not just the threshold of exceptionality, but also (wholly unaddressed by the Applicant) that of demonstrating that such development is in the public (as opposed to private) interest.
Plainly, AI is unable to demonstrate any exceptional circumstances to process at Blackhill.

Noise, dust, statutory nuisance - continued

Following on from the Noise, dust, statutory nuisance post, why is it that residents around Straitgate are facing quarry proposals from Aggregate Industries with extraction just 70m from their homes, and construction of screening bunds even closer? Why is it that DCC is even entertaining such distances?

Take just three dust impact reports: one for an extension to Newbold Quarry in 2011, one for an extension to Kempsford Quarry in 2013, and one for Straitgate Farm in 2015 - same consultants, same author, same material, all commissioned by AI.

These might be mistaken for off-the-shelf reports; much of the text is the same - certainly for the dust mitigation measures outlined in Section 8.0 of each report - but there’s one important difference; it’s not difficult to spot:

Newbold Quarry
9.1 The potential for fugitive dust emissions from the proposed excavation of sand and gravel associated with the south and west extension at Newbold Quarry is minimal due to the inherently high moisture content of the ‘as dug’ material. 
9.2 Potentially, the most dust sensitive receptors associated with the development not in the ownership of the Applicant are... there will be a minimum stand-off distance of 200 metres between the extraction area and these receptors, again minimising any impact.
Kempsford Quarry
10.1 The potential for fugitive dust emissions from the proposed excavation of sand and gravel associated with the south and west extension at Kempsford Quarry is minimal due to the inherently high moisture content of the ‘as dug’ material. 
10.2 Potentially, the most dust sensitive receptors associated with the development are... there will be a minimum stand-off distance of 150 metres between the extraction area and these receptors, again minimising any impact.
Straitgate Farm
9.1 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. 
9.2 Potentially, the most dust sensitive receptors associated with the development are...
That’s right. No mention of a minimum stand-off distance for those living around Straitgate, just:
6.4 The nearest boundary of the mineral extraction area for Phases 2B and 2C are approximately 70 metres from [homes]…
Why do the people around Straitgate warrant just 70m? Has AI put in place some special, magical dust mitigation measures? Something over and above Newbold and Kempsford? No. Just the same Section 8.0, the same wing and a prayer:
... the operator will ensure the diligent application of appropriate mitigation measures as outlined in section 8.0
Devon's new draft Minerals Plan Policy, M23: Quality of Life, says:
Peoples’ quality of life, health and amenity will be protected from the adverse effects of mineral development and transportation. Development proposals must demonstrate that the following adverse impacts will be strictly controlled or mitigated to avoid any significant nuisance being caused to dwellings and other sensitive properties close to the site or its transportation routes and other users of these routes: (a) noise and vibration, including effects on areas of tranquility; (b) dust and other reduction in air quality;(c) loss of privacy or natural light; and (d) light pollution and visual intrusion.
Following AI's original application, DCC made a Regulation 22 request:
The applicant should submit for consideration a detailed dust management and monitoring scheme for the site and for the HGV traffic moving between the site and the processing plant. Reason: The applicant should demonstrate that increased dust would not have significant adverse impacts on local residents.
So, AI bought itself another report - with suppression measures (a repeat of that Section 8.0 again) and a complaints procedure - but no-one has demonstrated that increased dust would not have significant adverse impacts on local residents; how could they, with homes just 70m away?

Let's not forget that:
Large dust particles (greater than 30 µm), which make up the greatest proportion of dust emitted from mineral workings, will largely deposit within 100m of sources. Intermediate-sized particles (10–30 µm) are likely to travel up to 200–500m. Smaller particles (less than 10 µm) which make up a small proportion of the dust emitted from most mineral workings, are only deposited slowly but may travel 1000m or more. 1A.5
Fine particles of PM10 (particles with an aerodynamic diameter of less than 10 µm) are of concern to human health as the particles can be inhaled deep into the lungs, whilst coarse dust relates to nuisance impacts. 3.5
Dust emission, dispersion patterns and impacts are difficult to predict due to the wide range of activities on site that may give rise to dust, and the lack of reliable knowledge of the dust-generation capacities for these activities, together with the influence of local meteorology and topography. 1A.6
As with noise,
There are no statutory limit values for dust deposition above which ‘nuisance’ is deemed to exist – ‘nuisance’ is a subjective concept and its perception is highly dependent upon the existing conditions and the change which has occurred. 2.3.2
the following matters constitute "statutory nuisances"... (d) any dust, steam, smell or other effluvia arising on industrial, trade or business premises and being prejudicial to health or a nuisance; (e) any accumulation or deposit which is prejudicial to health or a nuisance 79
It's another example of just how fast and loose AI is playing with Straitgate, local people and the local area: 70m standoffs from homes can be added to the long and growing list of other things AI is trying to get away with - not leaving 1m unquarried above the maximum water table to protect drinking water supplies, a water table not known with any degree of accuracy; processing 8 miles away in an AONB and an area of European importance to nature, a total of 1.2 million HGV polluting miles on an inappropriate B road; fallacious arguments for not processing at nearby Rockbeare instead; loss of 2km of ancient hedgerows with barely any appropriate mitigation planting for dormice; inaccurate resource figures; non-existent GCN survey; doctored HGV accident reporting; and more.

Thursday, 10 March 2016

If AI now wants to use the main road in to and out of Ottery...

...shouldn't it tell people? Shouldn't it listen to their views?

Whilst Aggregate Industries says "we are in the process of assembling revised applications for essentially the same development", what it actually intends to do now is to use the B3174 Exeter Road - for up to 200 HGV movements a day; not essentially the same development at all, when the impacts on local people are considered.

Given that "the revised applications will be submitted towards the end of March 2016", you might think that, over the next week or two, AI would want to hear from as many local people as possible and canvass their views about these new plans, so that their suggestions might inform - even improve - the company’s planning applications before submission.

Or perhaps AI thinks it knows enough already; the company obviously thought so last time - for the applications that have now been withdrawn.

A week ago we wrote to AI, and asked:
With reference to your revised proposals for Straitgate Farm, please can you tell us when you will be carrying out leaflet drops and holding public exhibitions to explain the changes and enable local people to inform your forthcoming planning applications, particularly on your new plan to use the main road in to and out of Ottery?
This is the answer:

We will update this post when we receive a reply. As far as the NPPF is concerned:
Local planning authorities... should also, where they think this would be beneficial, encourage any applicants who are not already required to do so by law to engage with the local community before submitting their applications. 189 

EA response to Minerals Plan

The Environment Agency’s response to the draft Devon Minerals Plan contains a paragraph on Straitgate. The EA has confirmed that it should in fact read:
In addition, although it was our understanding that the minerals development at Straitgate would entail above max water table working, we note that the operator is now proposing an operation that does not conform to the requirements of this policy or the mitigation proposed in Appendix C.
Policy M12: Land-won Sand and Gravel Supply of the draft Minerals Plan states:
The adequate and steady supply of land-won sand and gravel to meet the requirements of Policy M11 will be met through:(a) the extraction of remaining reserves at existing quarries;(b) the development of further sand and gravel resources within the Budleigh Salterton Pebble Beds at the following locations illustrated on the Policies Map, subject to the mitigation measures identified in Appendix C:(i) Straitgate Farm, Ottery St Mary (Specific Site) through working only above the maximum water table; ...
Appendix C, relating to Straitgate, states:
The development of this site will only involve dry working, above the maximum winter (wet) level of groundwater with an unsaturated zone of at least 1m maintained across the site.

Devon Minerals Plan Examination - hearing programme and documents released

Hearing sessions for the Examination of Devon's Minerals Plan will begin on Tuesday 24 May 2016 10.00am at the Committee Suite, County Hall, Topsham Road, Exeter. The Inspector has produced a series of documents:

Straitgate will be discussed on Wednesday 25 May 2.00pm; specifically:
1. What are the circumstances that have led to the selection of Straitgate Farm as the one specific site for sand and gravel extraction?
2. Is the site specific designation of Straitgate Farm unsound?

Monday, 7 March 2016

Noise, dust, statutory nuisance

Whilst we wait for Aggregate Industries to rewrite its planning applications - right the wrongs, bury the bad bits, create some new fiction - look what’s been going on in Buckfastleigh, and the joys that quarrying can bring to a community. Buckfastleigh Town Council has produced a noise leaflet, because:
The Council has received a number of complaints from local residents about the noise coming from Whitecleave Quarry and we understand that noise has disturbed some people in areas of the parish not usually affected by activities at the quarry.
The Council decided to produce this leaflet to provide information to those affected by noise to tell them how they should register their complaints and provide a facility to complain anonymously if required. This information has not previously been made available to residents by Devon County Council, Teignbridge District Council or the quarry operator.

As the leaflet points out:
There is no specific decibel level or limit to determine nuisance. If it is found to be 'statutory nuisance' the authority must serve an abatement notice – which is an order to deal with the nuisance. This order may demand the noise stops altogether.
For those unfamiliar with the term, 'statutory nuisance' is a decision based on what the average reasonable person would find unacceptable; it is a criminal offence. East Devon District Council has more information on Common Law Nuisance and Statutory Nuisance:
In common law there is something termed a 'nuisance' which can be defined as a matter which is an unreasonable and substantial interference on the use and enjoyment of a person's property.
A statutory nuisance, under the Environmental Protection Act 1990, must fall within one of the following categories: i.e.
(g) noise emitted from premises so as to be prejudicial to health or a nuisance;
or for that matter
(d) any dust, steam, smell or other effluvia arising on industrial, trade or business premises and being prejudicial to health or a nuisance;
(e) any accumulation or deposit which is prejudicial to health or a nuisance;
As the Environmental Protection Act 1990 makes clear:
For those interested in the matter, here are two more links: Statutory nuisances - how councils deal with complaints, and Friends of the Earth - Statutory Nuisance.

On the face of it, and without appropriate standoffs, the average reasonable person would find much of what a quarry brings to communities to be unacceptable. Any operation at Straitgate would grind to a halt if it became a 'statutory nuisance', but with some homes as close as 70m to its previously proposed extraction zone - reneging on assurances made by AI in 2013 of a 100m minimum standoff - AI is already setting itself up for problems. AI says:
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. 11.8
Here's Blackhill Quarry down the road; same material, same 'dust mitigation policy', same operator:

Is DCC Minerals Planning any help in all this? No. The new Plan cares more about minerals, and multinational cement conglomerates, than local people. It proposes Mineral Safeguarding Areas all over Devon "for the protection of mineral resources" with buffers delineated around such areas which "ensures that account is taken of development beyond the extent of the mineral resource or site that could constrain existing or future mineral operation". 

DCC says the buffer "reflects the characteristics of each resource"; ball clay has 100m, china clay, sand and gravel 250m; the buffers "are considered to reasonably reflect the differing degree of impact of extraction of different groups of minerals" - in itself, an admission that sand and gravel operations can have impacts 250m away. Absurdly, no such standoffs are specified to protect people. DCC says:
Buffer zones are one means of minimising adverse effects... but the choice of mitigation measures will be dependent on specific circumstances and it is inappropriate to require buffer zones for all development.
However, the industry - in the form of Imerys Minerals responding to the Minerals Plan - has expressed: 
Concern that the 100m and 250m buffer zones will be insufficient to avoid issues arising from the proximity of mining and residential / other uses. To avoid conflict and nuisance claims arising from ball clay and china clay operations the buffer may need to increase
In other words, whilst Imerys are concerned that even 250m may be insufficient to avoid nuisance claims, AI is hoping to get away with 70m. Keep a copy of Buckfastleigh’s noise leaflet - it may come in useful.

Tuesday, 1 March 2016

AI pulls Straitgate & Blackhill planning applications...

...and EVERYTHING starts again.

What a fiasco. With no rights over 3rd party land, Aggregate Industries has withdrawn its planning application for Straitgate Farm and, following advice from DCC, the linked application for Blackhill too.

If AI and its merry band of consultants and lawyers had done their homework properly, investigated rights over neighbouring land properly, we would not be in this position now.

If AI had had any thoughts of sustainability, any thoughts for the environment or for people, any thoughts for local roads, air pollution, climate change, drinking water supplies, airport safeguarding, flooding, heritage, listed buildings, European Protected Species, hedgerows, AONBs, SPAs, SACs, SSSIs, Woodbury Common or Ottery St Mary, we would not be in this position now.

But it didn’t, and because of AI’s incompetence it looks like we have got to go through this all over again. New applications will follow, this time with access at Little Straitgate onto the B3174 Exeter Road - the main road into and out of Ottery St Mary. AI had previously rejected this option on safety grounds:
The southern option, onto the B3174, was dismissed early in the process on highway safety grounds. It would have been too close to existing accesses, including the access to Straitgate Farmhouse, and the vertical alignment of the highway at this point would compromise visibility. 5.44 
New surveys will need to be performed for highways, hedgerows, archaeology, etc. Overtures by AI to the long-term tenant of this land, which is not part of Straitgate Farm, have already been rejected.

Huge questions will now hang over the site at the time of the Examination of the Minerals Plan; a Plan that has gone forward to the Inspector with the wrong tonnages, the wrong area, the wrong fields, the wrong access point, but laughably still as a Specific Site - where "the proposal is likely to be acceptable in planning terms". Perhaps DCC should have listened more to local people and less to the tales spun by a multinational cement conglomerate. On 25 June last year, DCC was advised by solicitors:
The area of land in question, as owned by our clients has been designated as land suitable for use as a transportation hub and we confirm that Aggregate Industries have not supplied evidence of their right to use that land for those purposes. Our clients therefore wish to object on the basis that their land will be used for purposes beyond the extent of any usage rights that Aggregate Industries have.
AI was warned by these solicitors on 13 May 2015. DCC and AI ploughed on regardless. All AI would say:
The applicant contends that it has necessary rights over the surface to implement the proposals as presented. 8.78
And as late as last month, in response to representations on the Minerals Plan about site access and resource, DCC was still stubbornly sticking to the line:
The anticipated tonnage figure was provided by the operator on the basis of retention of one metre unsaturated zone. If it emerges that this is incorrect and/or that the operator does not have the necessary land rights to part of the site, these issues can be considered during the examination and, if necessary, suitable modifications proposed.
Further information will be sought from the mineral operator on land ownership and access issues and consideration given to the need for modifications.
In other words, despite being told to the contrary by the 3rd party’s solicitor, DCC was still siding with AI - changes would be made "if it emerges", "if necessary". This, despite DCC having already sought further information on this matter from AI without success back in 2012. For four years, DCC has blindly and doggedly pursued Straitgate without seeing ANY evidence of AI’s access rights. It’s shameful.

Now another box-load of documents will be generated. AI will have a second chance to either get it right or make another hash of it. Perhaps this time these documents will have the right numbers. Perhaps the facts will be consistent. Perhaps the surveys will be truthful. Perhaps the arguments will stand up to scrutiny. Perhaps not.

The worst part of all this? DCC says none of your responses to the previous applications will stand. New objections will have to be made. In time, DCC will contact those who objected last time. That’s bad news for local people who have been submitting responses on this matter on and off since 2001. Perhaps that’s the plan - wearing down objectors by attrition. 

For AI, it’s obviously a major setback: more expense, more delay; look at when things happened last year: Scoping request (Jan'15), consultation, public exhibitions (Mar'15), AI’s planning applications (Jun'15), consultation, DCC’s Reg22 request (Jul/Aug'15), consultation, AI's Reg22 response (Oct'15).

It now has new people on the job, but still AI appears to have no Plan B and has to be out of Blackhill on Woodbury Common in 10 months. By the time of determination, Devon's new Minerals Plan may even have been adopted, the same Plan that "does not propose Blackhill as a location for processing":
Proposals for the off-site processing of extracted materials should be located outside of the AONB unless exceptional circumstances can be demonstrated.

So, on we go.