SLR Report Template (Arial 11pt) Mine NTS... · 2018-07-20 · remains in force until the adoption of the Minerals Development Framework. 27. The Development Framework seeks to reconcile

Drakelands Mine

Variation of Condition 3 of Planning Permission 9/42/49/0542/85/3

to allow the continuation of approved operations to 5 June 2036

Volume 2C - Non Technical Summary

SLR Ref: 403.01939.00022

Version No: ISSUE November / 2015

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Wolf Minerals (UK) Limited i 403.01939.00022 Non Technical Summary November 2011

SLR C:\Users\clowden\Desktop\1511_R_NTS_FINAL.docx

CONTENTS

INTRODUCTION .................................................................................................................. 1

APPLICATION SUBMISSION PACKAGE ............................................................................ 1

PLANNING AND EIA ............................................................................................................ 2

THE SITE .............................................................................................................................. 2

THE PROPOSED DEVELOPMENT ...................................................................................... 4

PLANNING POLICY ............................................................................................................. 5

ALTERNATIVES .................................................................................................................. 6

AIR QUALITY ....................................................................................................................... 6

LANDSCAPE AND VISUAL IMPACT ASSESSMENT ......................................................... 7

ECOLOGY ............................................................................................................................ 8

WATER................................................................................................................................. 9

CUMULATIVE IMPACTS ................................................................................................... 11

FIGURES

Figure 1 Site Location ......................................................................................................... 3 Figure 2 Application Site and Ownership Boundaries ..................................................... 4

Wolf Minerals (UK) Limited ii 403.01939.00022 Non Technical Summary November 2011

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Wolf Minerals (UK) Limited 1 403.01939.00022 Non Technical Summary November 2011

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INTRODUCTION

1. This document comprises a Non Technical Summary (‘NTS’) and has been prepared by SLR Consulting Limited (‘SLR’) on behalf of Wolf Minerals (UK) Limited (‘the applicant’). The NTS forms part of a package of documents being formally submitted to Devon County Council (as Mineral Planning Authority, ‘MPA’) in support of a planning application in respect to land at Drakelands Mine near Plympton.

2. The applicant is submitting a planning application to ‘vary’ a condition attached to planning permission ref. 9/42/49/0542/85/3 dated 5th June 1986 (and subsequently ‘modified’ on 29th November 20101). Planning condition 3 of that permission requires that; “All mineral working and tipping shall cease by 5 June 2021…”. Thus the current planning permission is due to expire in circa six years time. Due to the start of mineral extraction not commencing until 2015, the mineral reserve will not have been fully extracted by the required end date. The planning application therefore seeks a continuation of the approved operations for a period up to 5 June 2036. The proposed application does not seek to amend the working scheme, method of extraction or processing, or seek to extend or intensify the approved operations. It seeks only to amend the date when mining and associated operations are to cease.

3. In considering the potential environmental effects of the proposal it is important to understand the baseline against which the potential effects are assessed. As the planning permission still has six years to run, the baseline is considered to be the position that the mine will have reached at the end date of currently permitted operations in June 2021, and not how it appears today. This is an important point, as the mine has now started operations and will have made substantial changes by the scheduled end date. This is explained in paragraph 1.47 of Chapter 1 of the ES, whilst Chapter 2 provides a description of how the site will change over the coming years.

APPLICATION SUBMISSION PACKAGE

4. This NTS comprises Volume 2C of a larger multi volume submission submitted to Devon County Council to accompany the planning submission. In addition to the formal planning application forms and statements, the full submission comprises:

Volume 1- Planning Statement;

Volume 2- Environmental Statement; o Volume 2A – ES Text; o Volume 2B – ES Technical Appendices; and o Volume 2C – A Non-Technical Summary of the ES.

5. The NTS has been produced as a separate, standalone document in line with best

practice prescribed by the Institute of Environmental Management and Assessment (IEMA) to accompany the planning submission, being a mandatory part of the ES. The purpose of the NTS is to provide, in non-technical language, a brief summary of the likely significant effects that the proposed development would have on the environment.

6. Paper copies of the ES can be obtained from SLR at the following address:

1 Modification Order confirmed by the Secretary of State for Communities and Local Government on 4 January 2011


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Aspect House Aspect Business Park Bennerley Road Nottingham NG6 8WR

7. The full ES is available in both paper and CD-ROM format, for which a charge of £200

and £25 is applicable respectively. A copy of the NTS is available free of charge on request. In addition, the application documents will also be available to view or download from the Devon County Council website.

PLANNING AND EIA

8. European legislation (the Environmental Impact Assessment Directive or ‘EIA Directive’ for short) requires that, before granting ’development consent’ for projects authorities should carry out a procedure known as environmental impact assessment (or “EIA”) of any project which is likely to have significant effects on the environment. In the UK, development consent includes the grant of planning permission.

9. An ES is a report of an EIA that is required to be submitted with a planning application.

10. Under the EIA legislation, the planning application for Drakelands Mine is to be accompanied by an ES.

11. It is not always necessary to address every environmental aspect in the same amount of detail. An integral aspect of the EIA process is to clearly identify or ‘scope’ the main environmental issues, as this allows for more detailed and targeted assessment to be carried out. SLR submitted a request to the MPA for their opinion as to the issues that needed to be addressed in the EIA and the MPA responded on 5 June 2015. They indicated that certain aspects did not need to be considered, such as:

Transport;

Archaeology/Cultural Heritage;

Noise; and

Vibration (from blasting).

THE SITE 12. The Drakelands Mine site is located within an area characterised by historic and

current quarrying and mining operations. The city centre of Plymouth is located approximately 10km to the south west with the suburban town of Plympton approximately 4km to the south west. There are a number of scattered farms and residential properties within 2km of the site boundary in all directions, with the small villages of Sparkwell and Hemerdon to the southeast and south respectively.

13. The permitted mine covers an area of approximately 260 hectares (ha) and can be divided into three main areas. The first area lying within the southern portion of the mine site comprises the open pit workings where the mineral is extracted. The second area comprises the process plant and lies to the north of the mineral working. The final area which covers a significant area of Crownhill Down to the north of the process plant comprises the Mine Waste Facility (‘MWF’) where mine wastes and tailings from the processing operations are deposited.


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Figure 1 Site Location

14. Chapter 2 within the ES (Volume 2A) provides further information on the application

site and its environs. Figure 2 overleaf illustrates the extent of the planning permission and land controlled by the applicant.


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Figure 2 Application Site and Ownership Boundaries

THE PROPOSED DEVELOPMENT

15. Planning permission authorising “the winning and working of tungsten and tin at Hemerdon Mine, Plympton, Plymouth and for the associated tipping of waste on Crownhill Down” (referred to in this ES as the ‘approved operations’) was granted on the 5th June 1986 (ref. 9/42/49/0542/85/3). On 29th November 2010, the Council issued a formal Modification Order pursuant to s.97 of the Town and Country Planning Act


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1990 which prescribed some new planning conditions, whilst retaining some of the original ones. Allied to this, a unilateral undertaking pursuant to s.1062 was executed.

16. The permission granted in 1986 was granted (through condition 4) for a period of 35 years from the date of issue. Following the Modification Order, the new condition 3 requires that “all mineral working and tipping shall cease by 5 June 2021”.

17. Substantive development of the mine commenced in April 2014 following planning approvals granted by Devon County Council in relation to changes to the design and form of the processing plant and surface water management lagoons.

18. The extant planning permission is due to expire in circa six years time, thus significant reserves of tungsten will still remain in the ground once the permission expires. For this reason a new end date to the permission is required which will enable the continuation of mineral extraction, processing and mine waste disposal operations and avoid the sterilisation of a nationally valuable mineral resource.

19. The planning application, made pursuant to Section 73 of the Town and Country Planning Act 1990 (as amended) seeks to amend condition 3 of the modified planning permission 9/42/49/0542/85/3 to allow a continuation of the approved operations for a period up to 5 June 2036; this represents a further 15 years from the current expiry date of 5th June 2021. This timescale is needed to allow for the mineral resource to be extracted, and also provides the necessary flexibility over production to reflect the unpredictable nature of tungsten markets. In this respect it should be noted that the production of tungsten is heavily influenced by global markets (unlike aggregates for example).

20. The planning application does not seek to amend the working scheme, method of extraction or processing, or seek to extend or intensify the approved operations.

21. Chapter 3 within the ES (Volume 2A) provides more details of the planning application.

PLANNING POLICY

22. Chapter 4 of the ES sets out how the proposed development has been considered against relevant national and local planning policy.

23. National planning policy is set out in the National Planning Policy Framework3 (NPPF), which is accompanied by the web-based Planning Practice Guidance4 resource relating, amongst other things, to minerals matters. Many sections of the NPPF are not relevant to this proposal since the application site is not located within a sensitive area subject to land use planning constraints (e.g. a National Park an Area of Outstanding Natural Beauty (AONB), or a Site of Special Scientific Interest). The site is not located within a Green Belt. Whilst scheduled monuments are located within the mine site, none are directly affected by these development proposals.

24. At the heart of the NPPF is a presumption in favour of sustainable development, which should be taken as “a golden thread” running through both plan making and decision taking. The NPPF identifies three elements to sustainable development: economic, social and environmental. It is considered that the proposed developments would

2 Town and country Planning Act 1990

3 Department of Communities and Local Government. March 2012

4 http://planningguidance.communities.gov.uk/

http://planningguidance.communities.gov.uk/


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create various economic and social benefits without resulting in significant impacts upon the environment.

25. The NPPF does not change the fundamental principle that applications for planning permission must be determined in accordance with the adopted development plan unless material considerations indicate otherwise.

26. The Minerals Local Plan specifically governs mineral development within Devon and remains in force until the adoption of the Minerals Development Framework.

27. The Development Framework seeks to reconcile the development needs of society

against safeguarding the environment and amenity of local communities. In so doing, the Development Framework sets out a series of Policies which seek to guide developments in terms of acceptable limits and design, whilst ensuring interests of archaeological, cultural heritage, ecological interest and importance are protected, and that the local amenity and environment of communities are not derogated through pollution to air, land or water.

28. Through the EIA process, it has been possible to demonstrate that the development

proposals would not conflict with the stated aims and policies of the Development Framework. This is explored in greater detail within the Planning Statement which also accompanies the planning application.

ALTERNATIVES

29. Chapter 5 of the ES sets out how alternatives to the proposed scheme have been considered. The EIA Regulations require that an outline of the main alternatives studied and an indication of the main reasons for this choice, taking into account the environmental effects should be included in an ES.

30. In the context of the application for the continued operation of the mineral operations to

2036, no alternatives present themselves. In this respect, the site is already an operational mineral site, and by the time the current planning permission expires in 2021 the operation will be well established.

31. Under the do-nothing scenario, the mine would not have fully worked the tungsten

deposit resulting in the sterilisation of a nationally valuable mineral resource, together with the loss of employment for the workforce.

32. In view of this, with the exception of the do-nothing scenario (which having invested

heavily in the project, the applicant is not prepared to consider) the applicant has not considered any alternatives as part of the EIA process.

AIR QUALITY

33. Chapter 6 of the ES considers the potential for the proposed development to impact upon air quality in the vicinity of the application site.

34. The chapter describes the scope, relevant legislation, assessment methodology and

the baseline conditions at the application site and the surroundings area. The assessment considers any potential significant environmental effects that the proposed development would have on the baseline environment (as represented by the status of approved operations at the expiry of the extant planning permission in 2021); the mitigation measures required to prevent, reduce or offset any significant adverse


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effects; and the likely residual impacts after these mitigation measures have been employed.

35. The operation of the Reduction Kiln and Mine Waste Facility (MWF) is regulated under

the Environmental Permitting (England and Wales) Regulations by the Environment Agency (EA). Detailed air quality assessments were undertaken by SLR to support the Environmental Permit application process. The EA reviewed in detail the air quality risk assessments in relation to these installations to ensure there would be no unacceptable risks to the environment or human health prior to granting the Environmental Permits. Permits for the facility were issued in 2013 and 2014 for the MWF and Mineral Processing Facility respectively (Permit Numbers EPR/FB3639EX and EPR/GP3531EX). The EA will continue to regulate these installations in accordance with Permit conditions throughout their operational life.

36. The assessment has found, using atmospheric dispersion modelling, is that there are

no predicted exceedences of Air Quality Objectives or Environmental Quality Standards for the protection of human health and the environment associated with the proposed continuation of approved operations.

37. The air quality effects are direct and for the life of the operation. The significance of

impacts is not predicted to increase over that currently approved by the extant permissions and relevant Environmental Permits. The overall effect as a result of emissions to air from the continuation of approved operations is not considered significant.

LANDSCAPE AND VISUAL IMPACT ASSESSMENT

38. Chapter 7 of the Environmental Statement considers the potential landscape and visual implications of the proposed development. The assessment follows recognised guidance issued jointly by the Landscape Institute and Institute of Environmental Management and Assessment.

39. This assessment included a baseline study of the existing site and its surroundings, a

study of the landscape and visual characteristics of the development and an assessment of the residual landscape and visual effects likely to be generated after mitigation has been considered and their significance.

40. Overall no significant landscape or visual effects are predicted as a result of the

continued working at Drakelands Mine between 2021 and 2036.

41. The physical changes to landscape elements and features is considered to be slight, resulting from the deepening of the mineral void and raising of height at the MWF, within an established mineral development site, where there would be no lateral enlargement or disturbance to any other elements or features and no change to the processing plant or final restoration scheme.

42. The changes to aesthetic and perceptual aspects are also considered to be slight,

relating to the continuation of plant and vehicle movement and alteration to form, but with no removal, addition or change of other aspects such as scale (which remains medium to large).

43. The overall landscape effects upon the application site and the Landscape Character

Type (LCT) within which the application site is set are considered to be slight/moderate as the published character type is relatively large in comparison and the scale of


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change is limited; the LCT would continue to be described as a gently rolling, sloping mix of moorland, farming and quarrying activities and much altered landform in some locations.

44. The effects are adverse in nature; there would be no new key characteristics

introduced, but the continuation of quarrying in the long-term is nevertheless a detracting element. After final restoration is complete effects would be neutral, as the site is completed in accordance with the permitted scheme.

45. In terms of cumulative landscape effects, the presence of open cast mining is already

one of the key characteristics of the LCT. The continued working at Drakelands Mine, to the ongoing operations at the Lee Moor complex would not give rise to changes in landscape character of such an extent as to have major effects on its key characteristics or transform it into a different character type. It is not considered that the development “tips the balance” through its additional effects.

46. The visibility of the application site is influenced at a local level by the screening effects

of vegetation in the surrounding area, in particular along roadsides, whilst the higher ground on the moorland to the north is more open and exposed allowing broad panoramic views. Nevertheless, the mineral extraction void has a very limited visibility over the continued period of working due to the existing and ongoing perimeter screening measures and the situation anticipated by 2021.

47. The Drakelands Mine processing plant had some visibility over the continued period of

working from higher moorland slopes to the north and limited locations at gaps in hedgerows around the farmed, wooded and moorland slopes to the east and west of the site.

48. The MWF would be increased in height over the period of continued working and as a

result would become more visible in certain views, although generally not breaking the skylines and often partially screened by intervening vegetation or landform. Final restoration would be in accordance with the approved scheme.

49. Although there are several sensitive visual receptors in the study area (mainly of a

residential and recreational nature), most of the changes evident from these receptors would be small; change is discernible but the underlying landscape character or view composition would be similar to the baseline. Similar features are typically already present in the existing views.

50. In cumulative visual terms there is both potential simultaneous and sequential visibility

of continued working at Drakelands Mine with the ongoing operations at the Lee Moor complex. However this would not result in a new landscape character or completely transform the views.

51. Finally, the “Special Qualities” of Dartmoor defined in The Dartmoor National Park

Management Plan 2014-2019 are unlikely to be affected by the continuation of working at Drakelands Mine.

ECOLOGY 52. Chapter 8 of the ES assesses the potential impacts on valued ecological receptors

resulting from the proposed changes to the approved scheme.


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53. The assessment provides a summary of relevant policy and legislation, the assessment methodology that has been adopted and the ecological baseline. The scope of the assessment and a detailed assessment of the likely significant effects are then presented, along with details of environmental measures (additional mitigation) to avoid, minimise, mitigate or compensate for any remaining adverse effects (where required). The assessment concludes with a summary of residual effects and an evaluation of their significance, following incorporation of these environmental measures (where required) into the scheme.

54. By 2021 virtually all of the development footprint will have been stripped of soils and

vegetation, meaning that there would not be any direct impacts associated with the loss of habitat.

55. An extensive range of ecological survey work has been conducted within the

development areas in relation to the current planning permission. The survey data has been used to identify Valued Ecological Receptors within the assessment. Twelve designated sites, five habitat types and six species/taxa have been identified as Valued Ecological Receptors.

56. Each Valued Ecological Receptors was evaluated against the proposed extension of

time in accordance with CIEEM guidance.

57. Protected species, notable habitats have been fully assessed, mitigated and compensated for within the current permission.

58. The proposed change of end date from 2021 to 2036 would not have any perceivable

negative effect on ecological receptors beyond that already anticipated.

59. It is concluded that the compensation and enhancement measures that would be implemented from 2021 to 2036 would see a significant positive effect on certain receptors: adjacent non-statutory sites; woodlands; heathland/ grassland and bats.

WATER

60. An assessment was undertaken of the potential impact upon the water environment in the vicinity of the application site, associated with the continuation of operation of the Drakelands Mine.

61. The key surface water features in the vicinity of the application site are the Tory Brook

and its tributaries (including the Hooksburry Stream and the Elfordleigh Stream) and the Smallhanger Brook. The bedrock in the area is mainly comprised of Devonian Slates (locally referred to as Killas) and granite, which are classified as ‘secondary aquifers with permeable layers capable of supporting water supplies at a local rather than strategic scale, and in some cases forming an important source of base-flow to the rivers in the area’.

62. The assessment has considered the potential impacts associated with the continued extraction operations and the potential to impact groundwater levels within the area, as well as the impacts on groundwater levels and quality through the continued development of the MWF. Consideration has also been given to surface water quality and the potential for offsite flooding.

63. The assessment has shown that groundwater levels in the immediate vicinity of the pit would continue be lowered until the cessation of mining. Local groundwater supplies would be subjected to a small amount of additional drawdown between 2021 and the


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cessation of mining, but the impact is predicted to be only temporary, with groundwater levels predicted to recover following cessation of pit dewatering.

64. The Smallhanger Brook would continue to be subject to a reduction in flow in the

vicinity of the pit, with the greatest reductions occurring prior to the expiry of the current planning permission.

65. The continued development of the MWF would also result in a localised drop in

groundwater levels in its vicinity. Again, a large proportion of the change occurs prior to the expiry of the existing planning permission. Development of the MWF would lead to a small reduction in groundwater baseflow to the Tory Brook. However, much of the reduction in baseflow would not be lost to the Tory Brook but would discharge to the Tory Brook via the overland and under-drainage systems associated with the MWF development.

66. In terms of water quality, there would be a minor increase in the arsenic concentrations

in the groundwater down-gradient of the MWF as a result of seepage through the waste rock and minor seepages through the MWF liner. A cumulative surface water metal quality risk assessment indicates that while the discharge is classed as “not insignificant” there are no significant negative impacts associated with the cumulative discharge.

67. Flood risk modelling results indicate that the development does not pose an increased

flood risk to either the Smallhanger or Tory Brooks.

68. The proposed development design contains a wide range of mitigation measures to limit the potential impact on the water environment such as the lining of the MWF and other storage ponds to minimise the impacts on groundwater quality, the provision of settlement tanks to reduce runoff sedimentation impacts, limitation of water abstraction during dry weather flows, flood attenuation tanks on the Smallhanger Brook and run off management within storage basins. Additional proposed mitigation measures outside of the mine design features include the lowering of pumps, installing new boreholes and/or deepening existing boreholes in order to combat potential yield reduction in private groundwater supplies.

69. The predicted residual impacts on the water environment as a result of the proposed development are as follows:

there would be a slight negative impact on local groundwater levels as a result of the pit dewatering and construction of the MWF;

a moderate negative impact is predicted on the springs along the Smallhanger Brook and a slight negative impact on the springs further from the site such as Sparkwell Spring;

the groundwater modelling predicts a slight permanent negative effect on groundwater arsenic concentrations down gradient of the MWF;

the permitted discharges to surface water would have a slight negative impact on surface water quality. There would be and intermittent slight negative impact from sediment transport to the rivers, during high flow events, where the capacity of the on-site attenuation tanks and ponds is exceeded;

there would be a slight negative impact on the Smallhanger Brook flows as a result of pit dewatering and a slight negative impact on Tory Brook flows as a result of abstraction from Loughter Mill;

there would potentially be a slightly positive impact on flood risk on the Tory Brook as a result of the construction of the MWF.


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CUMULATIVE IMPACTS

70. The final chapter of the ES considers the potential cumulative impacts arising as a result of the proposals to continue the operations at the Drakelands Mine after the expiry of the current planning permission.

71. Chapters 6 to 10 of the ES set out the findings of the EIA for a range of environmental

topics, and in particular, the potential significance of identified impacts. It is possible for a number of the environmental topics to impact upon nearby receptors; whilst individually, the impacts may be within accepted limits, collectively, and the impacts could potentially be more significant. These are referred to as “inter-relationships between impacts”. At the same time, potential impacts associated with the proposed development may be acceptable in isolation, but when considered in the context of other developments in the immediate vicinity, may become more significant. These are referred to as “Cumulative Impacts”.

72. The potential cumulative impacts arising through the proposed continuation of

operations have been considered and none have been identified. This is principally due to the existence of the extant planning permission for the mine and that no changes to the approved scheme are proposed.

73. No significant impacts have been identified for any of the environmental topics

considered as part of the EIA. Thus, no receptors are likely to experience any significant accumulated impacts from two or more sources.

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SLR Report Template (Arial 11pt) Mine NTS... · 2018-07-20 · remains in force until the adoption of the Minerals Development Framework. 27. The Development Framework seeks to reconcile