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The current production of dimension stone is featured prior to the main purpose of the quarry, which is to produce crushed aggregate. The Department believes this is misleading as historic data proves that dimension stone has been a relatively small proportion of the output of this quarry over the last five years.
Please see earlier comments. The historic information provided in the ES illustrates that there is an existing market for dimension stone, which the quarry supplies currently. It is the intention of the applicant to increase sales of dimension stone, still within the current lease output levels. There is no misleading regarding the applicant's intention. It is reiterated that the DTI should be encouraging dimension stone production from a suitable source such as Dreemskerry can demonstrate, with a view to increasing its revenues.
The orientation and dip of the bedding makes this a difficult quarry to continually work safely... The ES does not, in the opinion of the Department, adequately address this issue and the planning application should do so.
We refer you to the areas to be covered in an ES.
Detailed design plans are provided within the ES for the five major phases of the development. Geotechnical factors at the quarry have been assessed and the extension designed by a fully qualified and experienced geologist and engineer, Karen Dalgleish of Dalgleish Associates, BSc CGeol CEng MIMMM FGS FIQ, who is a geotechnical specialist under the provisions of the UK Quarries Regulations 1999 and a Health and Safety Specialist with respect to Excavations and Tips. Geotechnical issues, such as noted above, have been fully covered in the design.
Impacts arise from design, be they health and safety related, environmental or amenity based. These factors are interrelated and Dalgleish Associates are specialists in the design of quarries, minerals planning and related environmental matters.
The design is presented in Section 3 of the ES. The quarry is designed to minimise potential impacts. Assessment of the potential impacts is covered fully from Section 6 of the ES onwards, under the relevant Sections.
The plans submitted are full design drawings illustrating the development of the quarry.
No alternative sites are discussed here. Certainly in the view of the Department there should be recognition that the existing operating quarries of South Barrule and Cringle potentially have reserves worth assessing.
This sub-section in its last paragraph "In view of the above, and the potential environmental impact of any environmental proposal to development [of] a quarry on a green-field site, further consideration of alternative sites is not regarded as necessary" is totally dismissive of the necessity to even consider alternative sites.
In referring to "alternatives" Schedule 4 of the EIA Regulations 1999, is making reference to alternative locations and/or alternative methods of working. It does not mean sites under the control of another party, which patently, ARE NOT ALTERNATIVES.
Where a rock type is only found in one location, the DOT quarry at Poortown, now relocating to Rockmount, adjacent, being a case in point, then alternative locations simply do not exist. The extent of the Creg Agneash outcrop is similarly limited. The reason for the existence of Dreemkerry quarry, in the first instance, is undoubtedly because the masons of the time recognised its inherent properties. The applicant seeks to make optimal use of these properties in maximising the potential production of dimension stone.
This sub-section states that the objective of the Dreemskerry extension is to produce “dimension stone...with the utilisation of non-suitable and by-product stone as rock aggregate”. Again the emphasis is on the production of dimension stone, which is of the order of 5% of the current output.
Section 4.2 of the ES clearly states “if there are overriding environmental and amenity considerations, then there is one alternative only, and that is not to quarry”.
It goes on to say “In this case however there are two main objectives. Firstly the objective of a safe and meaningful restoration must be considered and secondly, in so doing the objective of sustainable development may be addressed. Sustainable development in terms of minerals requires that the use of the resource is optimised. At Dreemskerry this would mean focussing on the production of dimension stone, where that is possible and with the utilisation of non-suitable and by product stone as rock aggregate. The aggregate so produced will not only go to meet current dry stone markets but gravel sized aggregate will be blended with Island Aggregates sand production at Point of Ayre to maximise the use of that resource.
The alternative not to quarry would jeopardise these objectives and could result in the sterilisation of a strategic mineral reserve for the north of the Island, which could have transport, cost and environmental implications, all of which are contrary to the Strategic Plan policies.
There are no overriding environmental or amenity considerations which could justify not quarrying.” This is a clear statement and it is disingenuous of the DTI to put another interpretation on these words. On an Island with limited rock resources it is important that these are used in the most sustainable way.
...”The design of the quarry has been driven by a need to effect an early restoration of the current, prominent and over high, rear face of the quarry”.
These existing faces cause the Department concern and are not in our view safe. On the south eastern face the bedding dips steeply into the quarry, encouraging movement of rock and overburden into the quarry. The existing faces are at – or possibly [to be determined] beyond – the current planning permission boundary and accordingly these “final” faces should have been produced to reflect a final stable face, not, as it would seem, as a reason for extending the quarry faces beyond as a means of stabilising those faces.
For the avoidance of doubt, alternative methods of working have been considered by the applicant. The design provides for, as discussed in the application, the early restoration of the existing over high and over steep rear quarry face.
The design furthermore utilises this restored face to screen further working. A full landscape and visual assessment has been prepared to demonstrate any impacts, beneficial or adverse, on receptors.
On the matter of the profile of the faces as they are at present:
The DTI employs minerals consultants to advise on such matters, if that is part of the consultant's remit. An annual topographic survey is currently a requirement under lease conditions and inspections are undertaken by the minerals consultants on a routine basis. Equally DLGE sets conditions and will attend to their enforcement.
If the state of these faces is now being criticised, that is not a matter for the applicant, Island Aggregates Limited. In fact the applicant and the DTI appear to be in agreement, that remediation of these faces is desirable. The applicant, through the planning application, seeks to address, immediately following grant of planning permission, these “not in our view safe” faces and to subsequently work the quarry in a manner that ensures that safe faces are paramount and in full compliance with the UK Quarry Regulations 1999 ACOP, which has been adopted by the HSW on the Island as reflecting best practice.
Island Aggregates has approached and secured an agreement with the adjacent landowner which will enable the early restoration of the present over high and over steep rear face as an integral part of the quarry design.
The penultimate sentence of this sub-clause on page 42 states that “Noise and vibration from current operations utilising drilling and blasting are not giving rise to complaint.” From the Department’s experience this is not the case.
No complaints are on record at DLGE with respect to noise and vibration at the time of the submission of the planning application. No intimation has been received by the current operators in this regards from the DTI. It is not clear what experience the DTI is referring to in this instance.
This states that consultation has taken place, with, amongst others, the Department. The Department became aware of this application after being invited to a public meeting by the local Commissioners.
DAL understand that the Department was approached by the applicant direct and made aware of Island Aggregates intentions. Dates and contemporaneous notes of meetings held with the DTI can be provided by Island Aggregates if required.
With regard to the public meeting, which was at the behest of the Commissioners following early discussions with that body, DAL suggested to the Clerk to the Commissioners that he approach the several Government bodies and invite those parties to the meeting, as an effective means of communicating the applicant’s intentions, in an open fashion to all concerned.
It should be noted that the DOT, the Government Department dealing with hydrological matters, following clarification of several points by DAL, is satisfied as to there being no significant impacts from the development.
This states that “The quarry has applied for planning permission to excavate rock as a strategic resource for the Island, into the long term”.
The Department would re-iterate that there are other sites that need to be considered which might provide the same products with less potential environmental and human issues.
This response appears to make no comment on the restoration proposals. To complete the paragraph selectively quoted by the DTI above: “The restoration scheme is designed to restore the existing quarry and other completed areas at the earliest opportunity with ultimate restoration following the final extraction phase”.
During the preparation of the restoration scheme DAL liaised with DAFF. The restoration scheme provides for biodiversity opportunities. Discussion with other wildlife interest parties has guided the scheme.
A prescription for restoration is set out in the ES in Section 9.3.
The DTI’s assertion that there are other sites that need to be considered has not been the subject of assessment by the DTI, either for the quality, quantity or commercial viability of the mineral, never mind environmental and human issues. There are no published reports.
On the contrary, DAL have assessed other sites for the quality of the mineral and have produced a report on the subject which highlights the scarcity of rock resource in the Island. A presentation was made to a number of Government bodies on the subject, including DTI and DLGE, in July 2003. Copies of that presentation were made available to the various Departments.
The DTI’s claims are considered to have no basis in fact.
The Department has not checked the figures in this section out in detail but it appears that the background noise levels in the quarry and in close proximity are typically low indicative of its rural setting.
The proposal is not to exceed 55dB[A]. The Department is advised that Mineral Planning Authorities in the UK aim to establish a noise limit at the nearest noise sensitive property that does not exceed the local background level by more than 10dB[A]. From what the Department can ascertain, the 55dB [A] proposed limit is more than 10 dB[A] above the background level. The Department would recommend that these levels be tested for accuracy prior to the determination of this application.
The remit for noise assessment and control lies with DLGE, EPU. A consultational response has been received from EPU, which has been responded to in full by Vibrock, the applicant’s acoustic consultants. A copy of both documents is attached.
Vibrock’s response commences by saying “Obviously we are very disappointed at Mr Renton’s comments, particularly given that he feels it appropriate to use BS 4142 and a mis-quoted WHO criterion instead of recognised minerals planning guidance.”
The Vibrock's response goes on to deal in detail with points in the EPU letter and concludes by stating: "This proposal meets the relevant criteria of the relevant document i.e. MPS 2." "It is not a correct approach to quote documents that are not relevant to minerals sites to forward a case in terms of noise." "The MPS 2 criteria are met and hence no noise nuisance will occur".
The Department notes that the subject of 'flyrock' is not discussed or mentioned in this section. This is the possibility that rock will be projected beyond the limits of the operating quarry when the rock face is blasted. It is a serious issue and can have significant impact beyond the limits of the operating quarry when the rock face is blasted. It is a serious issue and can have significant impact considering the proximity of human habitation and therefore should have been addressed within the document. The Department is also aware that measures can be taken to ensure that this possibility is minimised but there is always the possibility that 'rogue' conditions might promote this event. A proposed methodology to address this important aspect, should, in the Department's opinion, be included in the statement.
The guidance now being followed on the Island with respect to Health & Safety at Quarries is the UK Quarries Regulations 1999, Approved Code of Practice. Blasting related matters are covered in Part V of the Regulations and the attached Appendix 2 of the ACOP sets out procedures to be followed.
This is an operational Health and Safety matter and not one which requires to be addressed in the ES.
Done [IoM] Ltd currently employ a reputable and experienced firm of blasting contractors, Ritchies, part of the Edmund Nuttall Group. Island Aggregates, if planning permission were granted, intend to continue with that organisation.
The present operator has had no fly rock incidents at the quarry.
As recognised by the DTI in their statement above, measures can be taken to ensure this possibility is minimised. It is considered to be extremely misleading, given the measures set out in the ACOP, Appendix 2, to promote a perception of risk posed by "rogue" conditions. These conditions, as any competent person would know, relate to soft, clay bands, or voids in the rock mass, through which explosive energy may be channelled. This situation is known in limestone areas. In our professional opinion this situation is extremely unlikely in the harder, metamorphosed rock strata at Dreemskerry.
The DTI quote data on blast charge weights provided in the ES and make detailed reference to the ES Technical Appendix on Blasting prepared by Vibrock, contrary to their earlier statement that they have not delved into technical appendices. The DTI do not state whether they have engaged blasting specialists to appraise this document, but make a number of comments regarding the provision of technical data.
The owner of the property, Rockside, neighbouring the quarry, M J Noel, made representation at the Public Meeting regarding vibration and its monitoring. DAL and Island Aggregates made a public commitment at the Commissioners meeting to monitor blast vibration in liaison with Mr Noel, who, due to his particular technical background in geophysics, intimated that he had an understanding of these matters. DAL understand from Vibrock that a production blast was satisfactorily monitored at eight locations and a regression line produced. The contents list of Vibrock's report lists this as Figure 1 and for the avoidance of doubt a copy is attached.
The rock strata at Dreemskerry are noted to be consistent over the scale of the points of measurement. There is no reason to infer effects on propagation of blast induced vibration.
In conclusion, it can be seen that there are a number of issues contained within the application document that need to be fully addressed before, in the view of the Department, the application can be fully assessed.
The DTI has taken upon itself to comment on matters which fall under the remit of DLGE, both planning matters and environmental protection matters.
The DTI has made comment on operational aspects, it is assumed having consulted with its mineral and/or other advisers. We refer particularly to comments on quarry design, slope stability, noise and blasting.
DAL directs this response, on behalf of the applicant, Island Aggregates, to the Director of Planning and trusts that the points raised by the DTI are addressed to DLGE's satisfaction, regardless of the DTI's remit in this matter, which we consider to relate to the custodianship of the minerals of the Isle of Man and their use to the benefit of the Isle of Man Government.
In conclusion we quote from the DTI's response:
With Dreemskerry nearing practical exhaustion there will still be a requirement for up to 80,000 tonnes p.a. of this mineral if development on the Island continues at the same rate. This mineral will have to be sourced somewhere and the options are thought to be as follows:
a] from the extension of Dreemskerry Quarry as per the application b] from the possible extension and increase in output of Cringle Quarry c] from increased operation at South Barrule Quarry d] from offshore sources e] from off-Island sources
It is clear that a], b] and c] all have potential planning issues needing to be determined. The Department is investigating the opportunity of offshore extraction and this route is also likely to be fraught with potential environmental issues. The final solution is not felt to be a tenable solution as the additional cost of importing this quantity of stone would directly impact on the economic development of the Island.
Options b] and c] do not have potential planning issues needing to be determined. There is no application for an extension to Cringle Quarry lodged with DLGE at this time. There is no application for planning permission or otherwise regularising operations at South Barrule Quarry.
Options d] and e], are classed as fraught with potential environmental issues and not tenable, respectively.
That leaves Option a] Dreemskerry Quarry, to be determined on its merits, as set out with respect to stone quality, need and environmental issues in the Environmental Statement submitted with the application. That there is an established need is clearly stated by the DTI above. That is an Island wide need, let alone a local need in the north of the Island, a need which Dreemskerry Quarry does, and should continue to meet into the future.
Dalgleish Associates
On behalf of Island Aggregates Ltd.
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