Get your own Free Home PageWatts Blake Bearne & Co Ltd., Proposed River Diversions, Quarry Extension, and Waste Tip at Teigngrace, Newton Abbot, Devon. (Devon County Council Planning Application 96/3040/20/9)
Overview
1.0 Non-technical summary
2.0 Planning application supporting statement and planning policies
3.0 Identification of key issues and consultation
4.0 Economic effects and need for the mineral
5.0 Description of the proposed development
5.1 Letter from ECC Ball Clays
6.0 Rivers diversion design and flood amelioration
7.0 Fisheries Assessment
8.0 Ecological Assessment
9.0 Landscape visibility and amenity assessment
10.0 Archaeological assessment
11.0 Noise assessment
12.0 Dust assessment
13.0 Agricultural assessment
14.0 Summary of effects
Although WBB have produced an environmental statement for their proposed quarry expansion at Teigngrace, as required by the Environmental Impact Assessment directive (85/337/EEC), objectors claim it is deficient in a number of areas. In particular, they claim that it presents a biased economic assessment of the scheme, an incomplete ecological assessment, and a highly technical assessment of the noise produced by the new works that no ordinary person could understand. They claim the summary of the assessment downplays the detailed impacts identified in the main body of the document.
The statement is in 14 separate sections and includes a number of self-contained reports commissioned from e.g. HR Wallingford, Exeter Archaeology, interleaved with explanatory comments.
These four pages are a somewhat disproportionate representation of the fourteen sections of the complete environmental statement: 1« pages on the need for the mineral; « a page on the effects of the river diversion; page on the ecological effects; « page on the landscape effects; « page on archaeology; « page on everything else. Obvious important omissions from the NTS include: no mention of species protected in their own right (lack of habitat conservation designations not necessarily relevant); no information on the height or other dimensions of the tip site (artist impressions are included in the main document) or the total size/scale of the quarry works.
2.0 Planning application supporting statement and planning policies
This section quotes selectively from relevant sections of the Devon County Structure Plan. For example, the quote from policy PRW3 misses out the part about "the effects of mineral working on the environment and arrangements for restoration and aftercare." The full text of policy PRW4 also lists the Petrockstowe deposit in North Devon, which is not listed or assessed here.
3.0 Identification of key issues and consultation
Despite the considerable archaeological interest, there was no consultation with bodies such as the Council for British Archaeology. The Council for Protection of Rural England, and similar bodies, have also not been consulted. There is no suggestion that comments were actually sought from members of the public or taken into consideration.
4.0 Economic effects and need for the mineral
There is a comparitive evaluation of the impact of quarrying in Wareham with quarrying in the Bovey Basin, but no evaluation of Petrockstowe, Devon. There is no mention of the fact that the Bovey Basin area contains some nine SSSIs.
Economic assessment. WBB present a very generalised account of the economic value of the entire ball clay industry (WBB plus English China Clays, plus everyone else). There is no mention of WBB's considerable overseas ball clay mining (described in detail on the WBB web-site). There is no evaluation of the effect of exchange rates on the competitiveness of the British ball clay industry. There is no mention of the fact that only 24 jobs are involved at Southacre Quarry and that no new ones would be created by this proposal (information supplied by WBB Planning and Estates Manager, J.M.Briggs, in section 8 of the Planning Application form submitted to Devon County Council).
There is no evaluation of the working life of Southacre Quarry without the extension. The paragraph starting "Failure to extend Southacre Quarry would have the following effects..." assumes a complete cessation of ball clay operations in the Bovey Basin and fails to point out that WBB has eight other quarries (and two consents, and permission to move the B3193 Chudleigh Road to link and expand existing quarries) in the area.
5.0 Description of the proposed development
This section mentions county minerals policy M45, but should also mention M46, M47, M48. There is no detailed assessment of Mineral Planning Guidance (MPG) notes, Planning Policy Guidance (PPG) notes, or relevant parts of Regional Planning Guidance (RPG) note 10, for the south west of England.
Appendix 5.1: Letter from ECC Ball Clays
This appendix includes a letter from G.Muskett of English China Clays to J.M.Briggs of Watts Blake Bearne, confirming that ECC has no land available that could accommodate the proposed WBB tip site. The preceding letter from J.M.Briggs to G.Muskett is not included.
6.0 Rivers diversion design and flood amelioration
This section does not detail the effects of fluvial geomorphology, and makes no assessment of the effects downstream of the diversion area. In particular, it fails to assess the more energetic flow of the rivers (greater mass in the greater channel size and greater velocity, in the case of the Bovey). There is no evaluation of the effect of water draining from the tip site through a proposed new discharge pipe to one of the rivers. There is no evaluation of the effect of rainfall collected by the expanded quarry draining through a single discharge pipe (SD8) into the river Teign. There is no consideration of the effect of removing 3000 mature trees on hydrology, or general hydrological changes due to the works.
In section 8.0 of the Environmental Statement (ecological assessment), there are details of how the flow velocities will change in each river, but that information is not included or discussed here. This seems an important omission (fluvial geomorphological effects), especially as the Bovey velocity will increase substantially -- from 1.5 m/s to 2.5 m/s.
The considerations of groundwater seem rather vague.
The river diversion study talks about "increased fine sediment load", but there is no ecological assessment of the effects of turbidity (cloudiness) on light sensitive species, fry, filter feeding invertebrates. Increased turbidity can lead to the complete disappearance of these species, but those effects are not considered here.
Examples are cited of previous river diversions, but they are examples "mainly in the enhancement of previously degraded rivers". What examples exist of unsuccessful river diversions?
No mention of the impact of "increased sediment load", as above.
8.0 Ecological assessment - see separate document.
9.0 Landscape visibility and amenity assessment
These consideratons are not properly represented in the non-technical summary. The amenity assessment is not an accurate reflection of how heavily the site is used, particularly by dog walkers.
10.0 Archaeological assessment This report by Exeter Archaeology is thorough, but it is biased towards desk research at the expense of field assessment. It indicates a very high potential for finds from all periods (from prehistoric onwards). But:
In contrast to the noise assessments of new road schemes, which are often self explanatory, this assessment is particularly opaque -- a non-specialist couldn't hope to understand it; nothing (not even measurement units) is explained. The NTS describes the "negligible effects of existing operations" and claims there will not be "any significant long term increases... for local residents". But the conclusions of the noise report (p22 s5.0) seem not to support this, at least for Ventiford Cottages and Brocks Farm.
No current average background noise figure is given, making comparisons difficult, but appendix 1 suggests an average for Ventiford Cottages of perhaps 48-50dB(A). No measurements are included for Brocks Farm. So the only reliable thing to do is compare the noise levels from the different activities listed here.
For Brocks Farm, "Depositing waste material on proposed tip at closest position no barrier" is 17dB(A) louder than "Combined noise of excavation from riverbed..." and 19dB(A) louder than "Depositing waste material on tip with barrier". So the difference in noise at Brocks Farm could be very substantial -- two or three times louder?
MAFF objects to the loss of 31 hectares of the best and most versatile agricultural land, especially for tipping. They will only withdraw their objection if the proposal to tip on such high grade land is withdrawn.
Almost every single one of the summaries for the ten areas appears to be a gross oversimplification and understatement of the main body text. Eg: Archaeology speaks of a "minor effect - potential for prehistoric 'discoveries'", when the Exeter Archaeology assessment confirms there is a high potential for discoveries, and nationally important finds have been located very nearby. Ecological effects are described as "Long term loss of habitat quality unlikely to be major, but difficult to prove." By contrast, the Environment Agency objects to a major and long term impact on wildlife and landscape features within the river corridors.
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