Thursday, 17 August 2017

Straitgate application delayed as EA requests more information

Aggregate Industries’ planning application to quarry Straitgate Farm was due to be determined by DCC’s Development Management Committee on 6 September 2017.

Determination has now been delayed. DCC confirmed that the Environment Agency has "requested further clarification" following a meeting with AI this week.

The EA objected in April. AI subsequently delivered yet another lengthy water report, which was supposed to address the issues raised in DCC’s Reg22 request. Plainly it didn’t.

The fact that AI still can’t get its groundwater model to stack up after all these years is telling. We recently posted on the issue, saying that "for the majority of the site - except where boreholes have actually been drilled - AI and their merry band of consultants haven’t got a clue where the water is".

No doubt, if AI had just decided to leave 1m unquarried above the maximum water table to protect drinking water supplies - like any normal quarry company - it wouldn’t be in this mess.

The next DMC meeting is scheduled for 25 October. Who knows if the company’s application will be ready by then. As we post below, water isn't AI's only problem.

So, if AI can’t use Birdcage Lane…

... without damaging other people’s property - without the necessary space to allow the unrestricted two-way flow of HGV traffic called for by DCC - what’s left?

Site access problems have dogged Aggregate Industries from the start. Click on the maps below to see the three ideas that have been proposed for Straitgate Farm so far.

pic name

Having discarded the Straitgate Farm entrance itself as being too dangerous, AI’s first idea for site access was on the west side of the site. In November 2012, residents found out what that would have been like, when they woke up to find this on their doorstep without warning. The idea was quickly discarded, for a multitude of reasons.

AI’s second idea for site access was at the northern end of the site. Numerous residents had concerns over that idea, and Hugo Swire MP met with the company to voice them. It transpired, in any case, that AI had no rights to use the land in the way it intended - something we'd warned about two years before - and the planning application that relied upon it was subsequently withdrawn.

'If planning is eventually granted then I do feel that DCC should explore alternative entry and exit points to mitigate the disruption that this development will cause.'
AI is now on its third idea. The company's Transport Assessment - the one with the fictional traffic figures for the Exeter Road - reckoned this was an improvement on the previous idea:
The presently proposed access is better for goods vehicle movements from Straitgate Farm than the initially proposed route. 9.29
But that was obviously without taking third party property, trees or the width of the lane into account.

If AI can’t use Birdcage Lane or land to the north, what’s left? Last year, after the first application was withdrawn, AI had looked at another option: Little Straitgate.

It was an odd decision, because Little Straitgate - 75m to the west of Birdcage Lane - 75m closer to the brow of a hill - had already been deemed too dangerous in the company's first application:
Initially two possible locations for site access at Straitgate Farm were assessed, one being in the south of the site and the other at the northern end of the site. 5.43
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
Nevertheless, AI prepared some access plans for Little Straitgate. This was the option that a Road Safety Audit suggested should be left turn only - not right, the way AI needed to go; the option that subsequently involved installing traffic lights on the B3174. Concerns were raised by DCC, including on visibility splays, and - after the high vis jackets meeting - the whole idea was dropped in favour of Birdcage Lane.

If AI was to revisit Little Straitgate - it would have to factor in the cows too - the ones that would need to cross the road 4 times a day to find replacement pasture - the ones that would need two more entrances onto the Exeter Road; one of which would be between the Little Straitgate and Straitgate Farm entrances, and one opposite. Would the HGVs and cows each have their own set of traffic lights?? It’s all looking very complicated. Perhaps it would be simpler if AI helicoptered the sand and gravel out.

But don’t quarry companies always find a way around these things? Not always. In June of this year, an attempt by Tarmac to reopen a quarry was blocked by councillors over road safety concerns:
I’m not quite sure that the proposals to improve the signage and cut back vegetation to improve views is the answer.
Sound familiar? Tarmac was looking at "up to 13 vehicle movements per hour" onto a 50mph road; here, it’s up to 20 per hour, onto a 60mph road, on a hill.

Monday, 14 August 2017

Two-way HGV traffic cannot work on Birdcage Lane

You only have to take one look at Aggregate Industries' swept path drawings below to see that two-way HGV traffic cannot work on Birdcage Lane. See how AI's trucks would cut across the central white lines; see how AI's trucks could not pass each other or anything else at this point.

Whilst this may be acceptable to AI, it would obviously be less so for oncoming farm or other vehicles being faced down by 44-tonne articulated lorries. Who would reverse to let the other through? Tractor and trailer or 50-foot artic?

Without free-flowing two-way movement, and with up to one truck every 3 minutes, HGVs could even be forced to queue up towards and onto the Exeter Road.

DCC had insisted on a 6.5m wide two-way carriageway for Birdcage Lane, for the whole stretch from the B3174 junction to the site access. We've said before that it didn't look possible. The drawings below clearly show that it isn't, within the given constraints.

Meanwhile, at Uffculme, for AI's ‘inextricably linked’ application to import Straitgate material into Hillhead:
It is proposed to widen Clay Lane on its western side by between 1 to 2 metres to achieve an overall carriageway width of 7.3 metres. This will allow the safe two-way lorry movements for all mineral and waste related traffic 4.5.2
If 7.3m is proposed for safe two-way lorry movements on Clay Lane, for the import of Straitgate material, we can obviously assume that the 6m or less proposed for Birdcage Lane for the export of the same material would create unsafe lorry movements.

And while we're talking safety, see where AI's trucks would swing out beyond the carriageway, by the field entrance - exactly where children stand waiting for school buses.

AI hasn’t done enough compensation planting so it’s come up with a new wheeze

One of the marvels of biodiversity offsetting for planning consultants is being able to show that you can rip out 1.5km of ancient hedgerows, lose 6 mature oak trees, cut down 6000m2 of advance planting, not restore things for more than 10-12 years, replace natural history hundreds of years old with saplings and tree tubes - and then show a net biodiversity gain. It's like magic!

No wonder nature’s in trouble.

Aggregate Industries' Reg22 Ecology Report says:
It is recognised that ‘no net loss of biodiversity’ will not always be possible within a development red line boundary and therefore the option of Biodiversity Offsetting has been considered within the proposed development.
Based on the Phase 1 Habitat Survey, and the proposed development footprint, the application site represents 130.06 biodiversity units before development, and 183.96 after development; a net gain of 53.90 biodiversity units.
It is acknowledged that there will be a time lag between the clearance of habitats and the establishment/ development of new habitats of equal or greater value. 
But the real question is this: How can there be enough compensatory planting for dormice - if there wasn’t enough before, and 60% is now due to be removed?

AI's revised plans for Straitgate would see the removal of 1.5km of ancient hedgerows; dormice - a European Protected Species - are assumed to be in all them. AI has consistently underplayed the amount of hedgerow that would be lost and overplayed the amount of compensatory planting.

DCC’s Reg22 wanted to know:
The MPA must ensure that the application provides sufficient compensatory habitat for loss of species rich / ecologically valuable hedges and associated species.
As a dormouse licence is required from NE [Natural England] we need to be sure that the three Habitats Regulations tests will be met and that it is likely that NE will issue a licence. Please can the applicant provide information to evidence that the favourable conservation test will be met and that they believe that NE will issue a licence.
In relation to the Habitats Regulations tests, AI’s consultants argued that:
With regard to Test 3 consideration of dormouse has taken place since 2014 with supplementary planting of new woodland and hedgerows. These have developed significantly since being planted, with the latter already suitable for dormice.
However, 60% of this supplementary planting will now be removed:
6,000 m2 (0.6 ha) of advance woodland planting within the application boundary will be removed due to issues relating to Exeter Airport.
Despite that, despite the fact that dormouse numbers have plummeted 72% between 1993 and 2014; despite the fact that the PTES 'strongly objected' to the Straitgate proposal saying:
Compensation planting (for that is what replanting is – not mitigation as suggested) for losses of irreplaceable habitat should be at a ratio in the region of 30 – 1. Proposed replanting and that already done falls far short of this;
despite Devon Wildlife Trust saying:
We note that the restoration proposals include the replacement of the existing hedgerow field boundaries but we believe that further consideration needs to be given to the fact that these will need many years to reach a state in which they can perform a meaningful part of the ecological network of this area;
despite all that, AI’s ecologist thinks that:
Given the above I am satisfied that NE will issue an EPSL for dormouse in relation to the Straitgate 
Of course, working for AI he would, wouldn't he? However, who the "I" is we do not know; there is no name on the report.

Is it any wonder that dormice are going extinct?

‘Drillers were really surprised they struck water so quickly’

That's what one local was told, after Aggregate Industries’ latest round of drilling at Straitgate Farm in June this year, for one of the boreholes.

It was surprising, after such a dry winter, and in the middle of the summer too, but Aggregate Industries’ Technical note: Straitgate Farm Unsaturated Zone Infiltration Tests June 2017 confirms it.

Infiltration testing was performed in five locations. This is where "Test Hole 4" lies:

And this is what AI’s report says about "Test Hole 4":
It is possible that a hydraulic connection to the water table was achieved at this test holes due to the closeness of the water table to ground level in this area.
You can see where "Test Hole 4" is located on AI’s work of fiction below.

Those contours apparently show the difference between the maximum winter water table (MWWT) and average summer low groundwater levels. AI is using this to show it can be trusted to dig to the MWWT during the summer months without affecting surrounding drinking water supplies or wetland habitats in ancient woodland.

Essentially AI's 'model' has been derived from just 6 locations. As Dr Rutter says in her report:
This surface is only a model of reality, and may not represent actual groundwater levels across the site...
AI has extrapolated data from these 6 locations across some 60 acres and pretended that measurements can be deduced to the nearest cm: "At the nearest point to PZ01 within the excavation, difference is 1.17 m", etc, etc. Here's AI's maths:

Guesstimate (in metres) minus Wilder Guesstimate (in metres) = Who Knows (in centimetres)

Of course, it's utter nonsense; you don't need to be a mathematician to see that.

In reality, for a site this sloping, AI can’t make predictions to the nearest metre; that's why 1m is normally left above the MWWT when sensitive groundwater receptors are at risk. As Dr Rutter says again:
The steep hydraulic gradient combined with limited monitoring, in my opinion, is likely to result in errors in the actual depth to maximum groundwater across the site.
We’ve already exposed the lie at PZ05, where the difference is supposedly and very conveniently shown as 0.99m. In reality the groundwater movement here is next to nothing - as the water record - and Amec's report shows:

Now "Test Hole 4" exposes the lie at another location too.

AI’s contours at the location of "Test Hole 4" pretend that 4m separates the MWWT and the summer groundwater levels. In AI’s world, summer water levels should be about 6.5m below ground level. However, in the land of reality, "Test Hole 4" demonstrates "the closeness of the water table to ground level in this area".

In fact, if instead of looking at average summer low groundwater levels we look at maximum summer groundwater levels (MSWT), AI’s model falls apart completely, with half of the piezometers around the site showing significantly less than a metre difference between maximum winter and summer levels. It makes a mockery of this statement:
...the working method ensures that the floor of the excavation will always have at least 1.0m of unsaturated gravels beneath. 2.4.7

It all goes to show that for the majority of the site - except where boreholes have actually been drilled - AI and their merry band of consultants haven’t got a clue where the water is.

No wonder AI kept this document back

DCC’s Reg22 wanted to know why:
Some (but not all) of the information on headwaters impacts has been reproduced in the current submission (AFW December 2016), but the information on the loss of the unsaturated zone has been mainly excluded.
The information on both the headwaters and the unsaturated zone is important and should be included so that it can be considered in relation to the current planning application.
AI has now supplied Technical note: Straitgate Farm – summary hydrogeological assessment of dry working: further clarification, AFW, June 2015, "so that the salient points can be taken into consideration".

Why did AI not include this document before? One of the salient points is this:

In removing a proportion of the unsaturated zone including the soil layer there will be a reduction in the storage capacity/buffering and so recharge may move more quickly through the unsaturated zone. The extent to which this makes the groundwater hydrograph more "flashier" would be difficult to quantify with a high degree of certainty… Within the proposed development the establishment of a 1m freeboard over and above the highest known water level provides for this eventuality.
As we all know by now, AI’s unorthodox seasonal working scheme does NOT propose to leave "a 1m freeboard over and above the highest known water level". Obviously we can now assume, by inference, that a flashier groundwater hydrograph has NOT been provided for.

Friday, 11 August 2017

AI was asked a very simple question

The applicant is requested to provide information on other sites either in their control or operated by another company where the proposed working technique is used successfully.
DCC asked this question, in its Reg22 request, because:
The MPA will wish to consider whether the proposed working technique is a "novel approach" as set out in the NPPF Paragraph: 048 Reference ID: 27-048-20140306 in respect of the requirements for guarantees on the amelioration of impacts on local water supplies should there be any technical failure. 
How telling that Aggregate Industries could not point to a single other site where its unorthodox seasonal working scheme has been tried before 8.5.

Should the 100 or so people who rely on the site for their clean and uninterrupted drinking water be delighted that they could be part of this new experiment?

Not if AI’s Reg22 response is anything to go by. AI's water consultants have changed their tune since 2015, and now claim:
By working only to the MWWT then during the summer months the water table will be lower. Therefore across the areas being worked the zone of water level fluctuation is undisturbed. This zone is at least 1m thick. 2.2.8
AI says:
The proposal to dry-dig to the MWWT and no lower at any point in the year, for the duration of the development, actually preserves between 2 and 5 metres of BSPB above the Aylesbeare Mudstone Formation. 8.5
In reality, however, there are large parts of the site that have very little or no zone of water level fluctuation to allow a 1m ‘freeboard’ between the maximum winter water table and the summer water level; Amec previously confirmed this in 2015:
In reality, digging to the MWWT at PZ05 would preserve 0m of BSPB above the Aylesbeare Mudstone Formation. Here's the log for PZ05 - which is towards the middle of the site.

If AI can’t provide any examples of its unorthodox scheme, its architect can now at least point to some "cartoons" instead. In the minutes of a meeting with the Environment Agency:
EB to include "cartoons" showing method of working
Here are those cartoons. Locals, whose water supplies are at risk, will draw their own conclusions.

So what happens if people lose their water supplies?

DCC's Reg22 wanted to know:
The planning policy section of the application includes the text from the Devon Minerals plan, ‘any proposal should include provision for alternative supply in the event of derogation of private water supplies resulting from mineral development’. However, there is no detail on this in the body of the report. Full detail should be provided including proposals for either a bond or legal agreement dealing with this matter.
Remember, Aggregate Industries' last application tried to get away with the wording:
If we dispute that the derogation is caused by our working we may, once we have restored your water supply, have the matter referred to an independent arbitrator... etc etc
Now there’s something new. Would it be any better? 
The degree of change that would trigger an action may vary from location to location and the nature of the receptor. Any future measurements that highlight unexpected behaviour or reports from stakeholders of changes to flows would trigger an investigation that may require up to a further 12 months monitoring. The investigation would examine if the change had arisen from natural climatic changes, quarry activities, third party influence (e.g. new drainage work on a water course) a change in use (i.e. increased use of a private water supply) or an error in measurement. 2.4.9
Does that inspire confidence?

Who would be the arbiter - for the 100 or so people relying on the site for their drinking water - together with the 3 farms - and the mediaeval ponds at Grade I Cadhay - if things went wrong?
In the event that there shall be interference with any of the private water supplies (as indicated on plan to be agreed with Devon County Council, in consultation with the Environment Agency) or an inability to draw a satisfactory water supply in respect of any of the private water supplies and such interference or inability to draw a satisfactory water supply is in the opinion of the County Council, in consultation with the Environment Agency, on the balance of probability, attributable partly or wholly as a result of the winning and working of minerals at Straitgate Farm then AIUK shall forthwith at its own expense take such action or make temporary or permanent arrangements for the provision of any alternative or additional water supply to the users of the private water supplies as shall be necessary or appropriate in the opinion of the County Council, in consultation with the Environment Agency, to replace or compensate for the interference or inability to draw a satisfactory supply to the extent that the same is attributable to such activities associated with the winning and working of minerals at Straitgate Farm, such provision to be kept in place until a satisfactory water supply is reinstated. 2.8.1
Locals will no doubt wonder about the interpretation of "any alternative". Would it be bottled water, emergency tanker supplies, or what? Some properties are miles from a mains supply, but if mains were to be installed, there's nothing in AI's legal blurb to say who would pay the water bill for ever more; a water bill that for farms or Cadhay could be enormous.

Wednesday, 9 August 2017

Should DCC support a scheme that requires criminal damage to implement?

Ordinarily, if someone put a pick axe through your front window without your consent it would amount to criminal damage. Ordinarily, if someone cut down your tree without your consent, or cut through its roots knowing it would cause it to die, that would also amount to criminal damage.

We’ve already posted that AI’s site access plans still have a major problem; specifically, that Tree H - shown below - "is likely [to] be damaged by the development and need to be felled".

The tree is not unhealthy. It belongs to a third party, who has already objected. The third party will not consent to destruction or damage to their property.

Under the circumstances therefore, and based on advice we've received, any harm to this tree by Aggregate Industries is likely to constitute criminal damage.

Clearly, DCC should not be supporting a scheme that requires criminal damage for its implementation.

DCC is working on the assumption that it's only a civil matter. The County Solicitor thinks that any damage would be a private legal matter between the third party and AI.

This is of course the same County Solicitor who chose not to pursue AI on its failure "to notify owners of the land or buildings to which the application relates", not to pursue AI on its failure to produce an accurate ownership certificate - an offence "with a maximum fine of up to £5,000."

It makes you wonder whether DCC has any legal teeth? Because ordinarily:
the Criminal Damage Act 1971 [provides] a definition wide enough to apply to any tangible property. By section 1(1) of the Act:
A person who without lawful excuse destroys or damages any property belonging to another intending to destroy or damage any such property or being reckless as to whether any such property would be destroyed or damaged shall be guilty of an offence.

Monday, 7 August 2017

How does AI square the CO2 emissions from its 2.5 million mile haulage route?

As parts of Europe experience their most extreme heat in more than a decade, the news on climate change keeps getting worse:
For those worried about the world our children or grand children will inherit, one study now puts the chance of us hitting the Paris climate goals at just 5%:
“Our results show that an abrupt change of course is needed to achieve these goals.”
“If we want to avoid 2C, we have very little time left. The public should be very concerned.”
But despite all that, despite all the sobering news on wildfires, droughts, flooding and ice caps melting, some companies shamefully act as though climate change is not their problem.

Take Aggregate Industries' ludicrous plan to haul every load of as-dug material from Straitgate to Hillhead for processing: a total of 105,000 HGV movements, a total of 2.5 million CO2 belching miles.

Over all the years of following this debacle, we've not come across anything similar - where 23 miles of public roads separate quarry face and processing plant, where 46 miles is clocked up before the product is even sold. And why would we? Profit margins on sand and gravel normally restrict the supply radius to 30 miles or so.

It is noted that current ES does not provide the information on comparative transportation distances and CO2 emissions, and the applicant is requested to explain why the previous view on the unsustainability of Hillhead Quarry as a location for processing materials from Straitgate Farm appears to have changed.
Policy M12 establishes the principle of extraction at Straitgate Farm, but one of the key requirements of supporting Appendix C is that “transportation of extracted materials for processing elsewhere should meet the requirements of Objective 1 and Policy M22 for minimal transportation by road” [Objective 1 also seeks to minimise generation of greenhouse gases].
Policy M12, M22 and Objective 1 are from the newly adopted Devon Minerals Plan. Objective 1:
Within geological constraints, secure a spatial pattern of mineral development that delivers the essential resources to markets within and outside Devon while minimising transportation by road and generation of greenhouse gases, supporting the development of its economy while conserving and enhancing the County’s key environmental assets.
Because, as the Minerals Plan says, "One of the biggest challenges facing Devon’s communities and environment, together with the wider world, is climate change driven by global warming." 3.4.1, so much so that "Mitigation of and adaptation to climate change is a key consideration and statutory duty for the Devon Minerals Plan, and will be a cross-cutting theme for the Strategy." 2.2.4

Determination of the Straitgate Farm application - an application that maximises transportation distances and greenhouse gases - will be one of the first tests for this new Plan.

The Applicant considers that Hillhead Quarry is the only viable solution in terms of its processing requirements. 8.1
Hillhead Quarry is now deemed the most sustainable option as Blackhill Quarry has been discounted as a processing location notwithstanding that CO2 emissions from HGV’s will be comparatively higher than the previously favoured Blackhill Quarry option due to haulage distances. This is partly offset, as a proportion of ex-Straitgate mineral products supplies markets in the mid-Devon area, in close proximity to Hillhead Quarry.
Furthermore… if high polished stone value (PSV) mineral is not extracted from Straitgate Farm then it will need to be imported from elsewhere. The comparative importation distances will be considerably greater than the distance from Straitgate Farm to Hillhead Quarry therefore in this respect...
As with everything AI says, this is worth scrutinising. The Transport Assessment helpfully tells us that:
so "partly offset" means by about 10%.

On the high PSV issue, and if we ignore the 4 million tonnes of sand and gravel at Hillhead - the same BSPB resource as at Straitgate Farm - and the piles of unprocessed oversized cobbles that are already building up there, this is not quite what it seems either. The majority of the Straitgate resource would not end up in the high PSV market - which is relatively small. Any increased comparative importation distances for this product would be dwarfed by the multi-million mile haulage plan to get Straitgate material to Hillhead in the first place.

AI says it "will endeavour to utilise as many return loads as possible". But how successful would that be? Most of the processed material would be transported by third party hauliers, as AI has made clear before:
Whereas the transport of unprocessed mineral to an off-site processing plant would be in vehicles under the control of the operator, either company-owned vehicles or under a haulage contract with terms and conditions, the export and sales of mineral product would involve third party hauliers. 5.31
There's no getting away from the fact that AI’s haulage plan would mean a lot of pollution. We calculate it's about ‘30 tonnes of NOX air pollution and 4,500 tonnes of CO2’; AI's calculations are nowhere to be seen. This is what the company said on the matter for its last application:

Thursday, 3 August 2017

Emergency working

The whole argument behind Aggregate Industries' unorthodox extraction scheme, behind not leaving 1m unquarried above the maximum winter water table to protect drinking water supplies, is that it relies on summer working, or at least:
Mineral working will not be continuous but in campaigns of 5-7 weeks duration and will be predominantly in the summer when groundwater levels will be much lower than the maximum water level identified. 1.1.3
But AI's consultants supplied an extra detail:
Excavations will maintain a 1m unsaturated ‘freeboard’ or standoff above the maximum winter water level during the winter months or when the water table is high unless there is an overriding emergency situation.1.1.3
We posted, for local residents reliant on the site for their drinking water, that:
What an emergency situation might be, Amec does not say. To AI, running low of gravel stocks could be an emergency.
DCC's Reg22 request wanted to know about it too, and was:
... unconvinced by the information supplied of the need for any winter working at all.
So we were all intrigued to know what an "emergency" really meant, and the truth has come out:
The term ‘emergency winter working’ is to be deemed a strong term for what is essentially working to operational requirements. Aggregate Industries will endeavour to extract mineral in the months when the water table is expected to be low. However, if there is increased or unexpected demand working may be required during the winter months. 2.16.1
Or in other words: 'We’ll protect drinking water supplies, unless we can flog some more gravel'. AI tells us not to worry:
It is noted that even in winter months, the water table can be more than 1m lower than the MWWT. 2.16.1

And the impact on the AONB - if all these trees were removed?

This is the view from Little Straitgate; the East Devon AONB can be glimpsed in the background.

Aggregate Industries' site access plans cut through the middle of the trees shown in the photo. It is likely that the majority of trees seen here would be felled, including those three tall oaks. AI calls these trees F, G and H; Tree H belongs to a third party who objects to the proposal:
The “no dig” construction means that the works will potentially interfere with the root protection areas of Trees F, G and H and some of G15A as illustrated by Drawing R22/L/3-3-005 and it is likely they will be damaged by the development and need to be felled. 4.1
Whilst AI’s plans would afford beautiful unobstructed views towards the East Hill strips, they would also afford less welcome unobstructed views into Straitgate - and the 5m high storage mounds detailed on the plans below - from the AONB.

The visual impact of these trees coming down on views from the AONB has not been assessed.

Tuesday, 1 August 2017

The number one thing that AI had to answer

DCC's Reg22 request continues:
It has been suggested that the reduction in available farmland on the Straitgate side of the B3174 means that there will have to be cattle movement across the road to land on the south for grazing and milking. As the applicant is the landlord for the Agricultural Tenancy then the MPA would request a joint statement of the likely impact and number of such agricultural movements on the safety of the public highway. If it is the case that this will happen as a result of the proposal then the impacts should be factored into the safety assessments and traffic calculations.
What has Aggregate Industries come back with? The meagre reply on this important issue is telling:
The new route would include a proposed cattle crossing on the B3174 Exeter Road. The number of daily movements over the proposed cattle crossing at times when the dairy herd is grazing the land south of Exeter Road would be twice in each direction. 1.5
The issues raised over signage will be dealt with under the detailed design and the Stage 2 Road Safety Audit that would be necessary following any grant of permission. 1.8
And that’s it??

Where's the revised Transport Assessment? Because there's no mention of 150 cows crossing the main road into and out of Ottery St Mary four times a day in AI's previous reports, here or here.

What about the impact on traffic? the functioning of the B3174 during rush hour? queue lengths? waiting times? vehicles backing up towards the blind brow? etc? etc? What's the impact of all that, with AI's 44-tonne HGVs thundering up and down the Exeter Road as frequently as one every 3 minutes?

A Stage 1 Road Safety Audit has been performed, which recognises that cattle crossing:
but you don’t need to be a rocket scientist to work that out.