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Greytops

West Hill Road

West Hill

Ottery St Mary

Devon EX11 1TY

15 March 2017

Ms Sue Penaluna

Planning, Transportation and Environment

Devon County Council

County Hall

Topsham Road

EXETER EX2 4QD

Dear Ms Penaluna

Application DCC/3944/2017

Extraction of up to 1.5 million tonnes of as raised sand and gravel, restoration to

agricultural land together with temporary change of use of a residential dwelling to a

quarry office/welfare facility

Straitgate Farm, Exeter Road, Ottery St Mary EX11 1LG

West Hill Residents’ Association object to this application.

Need

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.

Policy

The Devon Minerals Plan is the relevant adopted policy. Straitgate is identified as a preferred

area, but no site for processing material from Straitgate was identified. Policy M22 states:

“Within geological constraints, mineral development should minimise the distance that

minerals are transported while maximising opportunities for sustainable transportation and

access by a variety of modes.” The proposed transport of material to Uffculme for

processing, a 46 mile round trip, is therefore contrary to policy.

Agricultural Land & soil

The agricultural land at Straitgate is mostly (81%) Grade 3a, with a small amount of Grade 2

(8%), 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.

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Landscape and visual impact

The quarrying activities would cause harm to the local landscape during the operational life

of the quarry. Restoration would partially reverse this. 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.

Ecology & Biodiversity

The proposed mineral extraction would necessitate the removal of 4 Category B oak trees,

and more importantly, 1.8 kilometres of important hedgerows. Although the hedgerows are

to be reinstated in the restoration, new hedgerows cannot replace centuries-old, species- rich hedgerows. Studies have shown that there are significant numbers of dormice in the

hedgerows to be removed, also several species of bats have been recorded. Mitigation

measures cannot fully protect against adverse effects on these protected species.

Heritage Assets

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 1580. 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 MP19, 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.

Hydrogeology

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 have previously raised concerns that the 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.

Transport

The proposed route is onto Birdcage Lane, the B3174 to Daisymount, then the A30, M5 and

A38 to Uffculme, a distance of 23 miles. From a West Hill point of view, the abandoning of

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the transport route to Blackhill quarry is an improvement, but this has been replaced by

another route with serious problems.

The proposed route necessitates widening of Birdcage Lane for 45 metres to its junction with

the B3174. We believe that this widening not only requires felling of an oak tree, but

involves works on land that is not in AI’s ownership.

Despite the proposed road signs warning of HGV’s turning onto and off the B3174, we have

serious concerns over the safety of this route. The B3174 has a 60 mph speed limit, and

visibility is not good. The transport assessment includes Personal Injury Collision Date from

2010 to December 2014. This conveniently pre-dates the start of major building work at the

Barrack Road Bovis site in Ottery, which has generated much traffic, including HGVs. There

was also a fatal collision on this section of road in 2016.

The transport assessment includes traffic counts of 4,272 vehicles per day. This is

significantly less that Highways England’s figures, taken only 2 months before the applicant’s

study, of 6,634-6,936. The increase in HGV traffic of up to 172 movements per day will have

a significant effect. Turning traffic will be slow-moving and this, combined with the speed of

other traffic at up to 60 mph, and limited visibility on the hill, is dangerous.

There would be significant levels of air pollution from this (CO2, NO2 and particulates) from

up to 172 HGV movements per day. The cumulative effect of this with the much longer haul

route is unacceptable.

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;

• the adverse effects on hedgerows, dormice;

• the harm to heritage assets and their settings;

• unsafe transport route on Birdcage Lane/B3174

• environmental pollution from unsustainable transport route to Uffculme

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