Wednesday, 18 July 2018

AI’s application to quarry Straitgate Farm – determination date delayed for 5th time

This whole thing is becoming a farce.
It’s now three years since Aggregate Industries’ first planning application to quarry Straitgate Farm, and we’re still facing one empty extension after another with no end in sight ...
... it’s not clear what, if anything, AI has progressed since its previous extensions. At the end of last year, information was still outstanding on ecology, hydrogeology and highways. Six months on, work is still outstanding on ecology, hydrogeology and highways.
If AI hasn’t put things on hold, it’s clearly no longer in any hurry.
And plainly it’s not, because yet another extension to the determination date has been agreed between AI and DCC – this time to 31st December 2018; previous extensions can be found here, here, here and here. The farce continues.

B3174 Exeter Road closed

The road surface of the B3174 – Aggregate Industries’ proposed haul road for its Straitgate Farm quarry proposal – can’t cope with the existing traffic, let alone up to another 200 HGVs a day; the Exeter Road is currently closed for resurfacing, and will be for this week and part of next.

The road already has to cope with 7000 or more vehicles a day during weekdays. These vehicles are now having to find an alternative route through the narrow lanes of adjoining villages.

AI’s traffic count on this road has only recently been undertaken. Readers may remember that last year, the previous "count" put forward by AI bore no relation to reality; its consultant could not explain why.

We have previously posted that AI's haulage plans could cause the same road damage as 17 billion car movements, that the heaviest 44-tonne HGVs – the one's that AI would be using – "are up to 160,000 times more damaging to road surfaces than the smallest vehicles", that:
Aggregate Industries is wanting to shift 1.5 million tonnes of as-dug sand and gravel from Straitgate Farm to Uffculme. This equates to some 105,260 HGV movements, which - according to the above - could generate the same road wear and tear as up to 17 billion standard car movements. Has AI factored road repairs into its costings yet?
Of course, for Devon County Council, the irony is that - by adopting a Minerals Plan with a Preferred Area for sand and gravel quarrying that can only be processed 23 miles away - this situation is entirely of its own making; a 2.5 million mile own goal.

Monday, 16 July 2018

Safer lorry design, lies, and Boris Johnson’s resignation letter

The issue of safer lorry design has recently been brought to the fore again – as unlikely as it may seem, in Boris Johnson’s resignation letter.

This blog normally steers clear of politics – it’s just too depressing – but, and as widely pointed out by Full Fact (the UK’s independent factchecking charity),, the FT and others, "Boris Johnson lied about EU safety regulation in his resignation letter". His letter claimed:
It now seems that the opening bid of our negotiations involves accepting that we are not actually going to be able to make our own laws. Indeed we seem to have gone backwards since the last Chequers meeting in February, when I described my frustrations, as Mayor of London, in trying to protect cyclists from juggernauts. We had wanted to lower the cabin windows to improve visibility; and even though such designs were already on the market, and even though there had been a horrific spate of deaths, mainly of female cyclists, we were told that we had to wait for the EU to legislate on the matter.
If a country cannot pass a law to save the lives of female cyclists – when that proposal is supported at every level of UK Government – then I don’t see how that country can truly be called independent.
Where we are not supporting European Parliament proposals, it is simply because they will not produce practical changes in cab design and could lead to additional bureaucracy for Britain.
And it was Johnson who expressed concern at this lack of support:
If these amendments, supported by dozens of cities across Europe, can succeed, we can save literally hundreds of lives across the EU in years to come. I am deeply concerned at the position of the British Government and urge them to embrace this vital issue.
Social media has not taken kindly to Johnson's recent retelling of events:

The UK did eventually support the proposal, and the European Parliament voted to amend its laws:
... widening lorry design specifications to increase driver visibility and reduce the chance of serious injury in a low-speed collision.
These rules are not mandatory – older lorry designs will still be allowed on the road.
However, the EU truck safety and efficiency law was delayed until 2019. The European Transport Safety Council warned:
These changes could prevent up to 900 deaths a year on European roads, so any delay will cost lives.

Tuesday, 10 July 2018

50th anniversary of the devastating floods in East Devon

Tipton St John Memories

"10 July 1968 saw one of the worst natural disasters East Devon has ever experienced", starts a press release last month from the Environment Agency:
A summer storm flooded homes and businesses across the south west, thousands were driven from their homes and tragically a number of lives were lost.
The impacts of the flood were immense; bridges collapsed causing roads to close. Sidmouth, Colyton, Honiton, Newton Poppleford, East Budleigh and Ottery St Mary all had significant flood damage whilst The Otterhead reservoir was completely washed away.
We've referred to this event before in Straitgate Farm, the subject of a 1968 Public Inquiry:
It was the time of Harold Wilson and The Beatles, the invasion of Czechoslovakia and the Vietnam war. On 10 July five inches of rain fell and Ottery St Mary flooded, as did other parts of East Devon. Several people drowned. By coincidence a Public Inquiry was sitting on the same day at County Hall deciding the fate of Straitgate Farm.
Tipton St John, downstream of Ottery St Mary, was also badly affected, and lost its bridge:
The little humpback bridge at Tipton crumbled instantly when the full force of water hit it. During his visit to Tipton the following Monday, the Duke of Edinburgh chatted to villagers in the Golden Lion Public House, including Mrs D. M. Alderdice and her daughter Margaret, who had the honour of serving the Duke with a half pint of bitter. Miss Alderdice later said that the beer glass would be inscribed to commemorate the Duke’s visit.
Tipton St John Memories

A Bailey Bridge was subsequently put up by the Army to keep the road open.

Some years later, also in the month of July, Ottery St Mary flooded again. We posted:
Ottery St Mary has a history of flooding: in recent years, August 1997, September 1997, September 1998, October 2005, November 2005, October 2008, and now 7 July 2012.
Aggregate Industries need to be aware just how much it can rain here, and how much water they would have to manage if they quarried Straitgate Farm.

Monday, 9 July 2018

Without more boreholes, and years of further groundwater monitoring, AI and its band of consultants are just groping in the dark

The problems of water – whether it’s to do with flooding, ponding, or maintaining the quality and flow-rates of springs, streams, and private water supplies – has been, and still is, one of the biggest issues for Aggregate Industries to resolve in its planning application to quarry Straitgate Farm.

AI maintains that any quarry would be worked dry, that it would have:
a working base that coincides with, and never drops below the maximum recorded winter water table XD28
So it was therefore necessary for its consultants:
to determine what the maximum winter groundwater level would be, so as to ensure that all working under normal operating conditions would be above this level. 6.1.13
But this obviously leaves no margin for safety, no margin for inaccuracies in AI’s model, no margin for errors in digging, no margin for future land-use pollutants, and no margin for climate change. Leaving 1 metre unquarried above the maximum water table – typical elsewhere where groundwater is at risk – would go some way to resolve this, but AI wants it all.

AI’s problem, however, is that it doesn’t know where the highest winter water table is with any degree of accuracy, even less so with all the problems highlighted in the posts last month – here, here, here, here, here and here. The more time goes on, the more AI and its groundwater model seems to fall apart – out by up to 6.8m in one place!

For AI’s experts this must be embarrassing. It must also reflect on their professional competence; because if they can be wrong by as much as 6.8m in one area, how wrong could they be elsewhere?

You have to also ask: if these measurements had not come to light, and AI’s unorthodox scheme had already been given the nod, what problems would we now be looking at?

Plainly, the proposed depths and extraction area will have to be modified – but without new boreholes, new piezometers, and years of further groundwater level monitoring, AI and its consultants are just groping in the dark.

There are simply too many unknowns for groundwater levels along the eastern side to be extrapolated, or for 'localised adjustments' to be made. AI's consultants will have to produce something more robust – something which can only come from more measurements, not more guesswork.

Why is the maximum groundwater level so difficult to model? Well, it doesn't help that AI drilled insufficient boreholes back in 2013. It doesn't help that only 6 locations were used to model the proposed extraction area – 6 data points is hardly enough to model a handkerchief, let alone 60 acres. It doesn't help that the site is on the side of a hill. It doesn't help that, in Amec’s words, the site has "unmapped local faulting" and "steps in the water table related to faulting". There are now 13 boreholes around the proposed extraction area – but clearly that doesn't help enough either.

The issue of water at Straitgate is so important to private water users, flood-prone communities, ancient woodland, listed mediaeval fishponds and Exeter Airport, that the matter needs to be resolved before determination – as DCC has already made clear:
The surface water management is inextricably connected to Flood Risk Management/Airport safeguarding and the need to maintain and recharge watercourses. This issue is so important in terms of the likely significant impacts of the proposal the MPA would wish to ensure that a SWM scheme can be designed to meet all of the requirements identified in advance of the determination of this application. 17
Why is the issue so important?

Flooding is one reason: Readers may remember the flooding in 2008, when the four watercourses from Straitgate caused flooding downstream; one flooded more than 50 properties, prompting the EA to build a flood defence scheme – 11/2338/FUL. The EA's FRA wrote:
The aim of the proposed relief channel is to reduce fluvial flood risk to properties at Thorne Farm Way which was last flooded from the Thorne Farm Stream in October 2008. This event resulted in the flooding of 55 properties in Thorne Farm Way.
But the EA recognised that if the scheme suffered "an over design event" this still:
may result in flooding to Thorne Farm Way
What would increase the risk of an over design event? Well, having a quarry upstream – with ineffective infiltration areas, heavy machinery causing soil compaction, and removing a million tonnes of groundwater storage capacity for evermore – is hardly going to help. As AI has previously admitted:
One of the potential consequences of climate change is the increasing number of heavy rainfall events; our sites cover large catchment areas and there is an increasing risk of sites breaking permitted discharge consent limits...
And in 2012, after discussions with the EA, DCC had to concede in email correspondence that:
... the scheme for Thorne Farm does not take account of any increased surface water flows that may occur as a result of quarrying upstream of that site.
Later that year, unaware of what was being planned upstream, the Environment Secretary, Caroline Spelman paid the scheme a visit – after another bout of flooding.

Hugo Swire MP followed and felt it important "that we double our efforts" to prevent a repeat, having commented earlier on the Straitgate proposal:
It would seem somewhat regressive having spent a large amount of public money on flood prevention to then allow for a scheme which may contribute to future flooding.
AI of course didn't want to remind people about all this. Despite the relief scheme, despite visits from the Environment Secretary and MP, despite being on the EA's Historic Flood Map, the historic flooding section of its Flood Risk Assessment 'forgot' to mention it was a watercourse from Straitgate that flooded 55 properties in 2008. Funny that.

But it’s not just flooding. Exeter Airport has had things to say about AI’s plans too. In 2012:
Under the Air Navigation Law, it is a criminal offence to endanger an aircraft or its occupants by any means.... To ensure aviation safety it is suggested that no ponds or body of water be allowed as part of this development.
The Environment Agency has also previously expressed concern that:
A possible change in recharge and runoff patterns (e.g. an increase in runoff and decrease in aquifer recharge during high intensity rainfall events ) as a result of removal of part of the unsaturated zone, with the potential to impact on: eastward flowing groundwater; the flow of springs; local private water supplies; the volume of groundwater draining to Cadhay Wood CWS and Cadhay Bog CWS. An increase in the possible risk of contamination of groundwater as a result of the removal of part of the unsaturated zone. 7.104
What problems can councils have if this type of thing isn’t sorted out before determination? Look at what happened in Cheshire a few weeks ago, where – with less than 24 hours notice – a council pulled a planning meeting to determine an application by Sibelco for a sand quarry – due to newly presented groundwater concerns:
The applications have been deferred due to a late representation which raises issues with respect to hydrology and hydrogeology.
After waiting years for AI to get its act together with Straitgate Farm, DCC is unlikely to want that.


This heatwave is just the start. Britain has to adapt to climate change, fast – writes Simon Lewis, professor of global change science at University College London and the University of Leeds
Water, housing, farming … almost every aspect of public life needs to change. Why isn’t this top of the political agenda? Climate change is a greater threat to the UK than EU directives, terrorism, or a foreign power invading. Much of the world is in the grip of a heatwave. Britain is so hot and dry that we have Indonesia-style peat fires raging across our moorlands. Montreal posted its highest temperature ever, with the deaths of 33 people in Quebec attributed to the scorching heat. And if you think that’s hot and dangerous, the town of Quriyat in Oman never went below a frightening 42.6C for a full 24 hours in June, almost certainly a global record. 
While Donald Trump and many conservatives like to argue that climate change is a hoax, James Hansen, the 77-year-old former Nasa climate scientist, said in an interview at his home in New York that the relevant hoax today is perpetrated by those leaders claiming to be addressing the problem.
A study published by the UK National Oceanographic Centre (NOC) has warned rising sea levels could cost the world economy £10trillion ($14trillion) a year by 2100. The startling report argued failure to meet the United Nation’s (UN) 2C warming limits could have catastrophic consequences. The scientists behind the study fear hundreds of millions of people who reside in low coastal areas are most at risk from rising sea levels.
‘Striking association’ found between nine-year-old’s hospital admissions and local spikes in air pollution
MPs have criticised government proposals that could see some fracking planning applications considered under the Nationally Significant Infrastructure Projects (NSIP) regime or allowed as permitted development rights as 'hugely harmful to local democracy'.
“It’s catastrophic and that’s what we’ve forgotten – our generation is presiding over an ecological apocalypse and we’ve somehow or other normalised it. We need a peaceful public uprising. We need people to say we’ve had enough. We do that every time there’s a terror attack. We need a similar movement for nature. We need people to stand up and say we want action now.”
Factors such as climate change, loss of habitat, use of pesticides and disease are to blame, the report said. Prof Fiona Mathews, chairwoman of the Mammal Society said: "This is the first time anyone has looked across all species for about 20 years.
Research by a team at the University of Exeter examined data from 300 sites across England and Wales which detailed numbers, breeding trends and population changes in relation to climate, habitat and woodland management. Dr Cecily Goodwin, who led the research, said the study “used nest box site surveys and volunteers and found that over 21 years at hundreds of sites across the country, dormice had declined by 72 per cent”.
The Mind Matters research conducted by Construction News last year uncovered shocking figures for mental health within the industry, revealing one in four construction workers surveyed had contemplated taking their own life, rising to one in three amongst junior staff and graduates. A further survey by recruitment specialists Randstad also found that almost a quarter of construction workers were considering leaving the industry within a year, many due to stress and poor mental health. To be haemorrhaging human resource at such a rate is clearly unthinkable and unsustainable – especially given the existing skills-gap challenge of an ageing, predominantly white and male workforce. 

Friday, 29 June 2018

Lafarge charged with ‘complicity in crimes against humanity’

At the beginning of June, we posted in LafargeHolcim: “a long history of questionable business practices” that it was expected that the company’s French unit would be placed under formal investigation over allegations of financing terrorism in Syria.

Yesterday, LafargeHolcim made the headlines across multiple news channels – including the BBC, The Telegraph, The Guardian, the FT – when it was confirmed:
LafargeHolcim’s French unit was placed under formal investigation in Paris over allegations the cement maker was “complicit in crimes against humanity” — one of the few companies in the world to face such an allegation.
An allegation of complicity in crimes against humanity is extremely unusual, according to lawyers and those involved with the case. 
The Paris-based non-government organisation, Sherpa, said: “This is . . . a decisive step forward in the fight against the impunity of multinationals operating in armed conflict zones. That the courts are finally recognising the scope and seriousness of these allegations is absolutely historic.”
It was announced the company was to be formally investigated by French judges on Thursday over sanctions violations, endangering the lives of others, financing of terrorism and complicity in crimes against humanity.
The former managers under investigation include LafargeHolcim's first chief executive, Eric Olsen.
A panel of three judges in Paris ordered Lafarge to hand over €30m (£27m) to authorities as a security deposit ahead of the trial.
A source close to the inquiry said investigators also suspected that Lafarge sold cement to Isis.
LafargeHolcim is the parent company of Aggregate Industries.

Wednesday, 27 June 2018

What ‘benefit’ is left for AI at Straitgate Farm?

With all the groundwater modelling problems posted below, it’s obvious to everybody and his dog that the available resource at Straitgate Farm is no longer what is claimed, and should be recalculated. It wouldn’t be the first time. This site has a long history of surveys, boreholes and test pits, and has already seen the available resource fall to just 6% of what was first expected.

Plainly, it’s important that any quarry planning application details not only the intended depth of extraction, but also the amount of resource being clawed from the earth. This is the 'benefit' of the application that planners must 'weigh' against a proposal’s adverse environmental impacts. Without an accurate figure, how can the 'benefit' be assessed? How can the 'planning balance' be determined?

The amount also acts to cross-check an operator's intentions, that it is not planning on digging deeper than it should, that it is leaving sufficient material in place for hydrological purposes. Because not every mineral operator can be trusted, not even Aggregate Industries.

In fact, especially not AI. In 2015, the resource figure acted to cross-check the company’s intentions for Straitgate Farm, exposing the fact that the company planned to dig deeper than both DCC and the EA had understood, exposing the fact that a 1m unquarried standoff above the maximum water table would not be left in situ – despite assertions to the contrary, including to the EA.

Such assertions meant the resource figure didn’t stack up and that AI was overstating what was recoverable by at least 500,000 tonnes. When AI failed to give clarification in a Reg22 request, DCC was forced to push further "for absolute clarity":
Given the importance of this point, to you as the proposed operator, and evidently to the MPA and the EA who were both of the understanding that you had agreed to this restriction. I am now asking you to clarify in writing whether you are intending to work to the proposed levels set out in the Amec technical Note to the Policy Team and the EA (and on which their recommendation was clearly based) or whether you wish for the MPA to consider your proposal as working to the highest measured level of the winter water table without the 1m standoff. You will understand the importance of this point and the need for absolute clarity in your response as it has serious implications for the further progress of this application.
Nevertheless, nothing came from this, but seven suits did subsequently turn up at the EA. Only later, however, were we able to reveal that AI’s idea of a 1m standoff was not the 1m that the EA and DCC understood, but was in fact nothing, a big fat zero; a fact that AI hurriedly confirmed in a resource statement the following year, less than two weeks before the Examination hearings for the Devon Minerals Plan.

In 2018, AI is still intending to leave a big fat zero to protect surrounding water supplies, relying on an unorthodox seasonal working scheme – which the posts below have already shown to be flawed.

AI says its application for Straitgate is for the "extraction of up to 1.5 million tonnes of as raised sand and gravel." As raised, or as-dug, sand and gravel includes a 20% waste component, so that’s actually up to 1.2 million tonnes of finished, saleable, useful product. That same figure is quoted in the Minerals Plan.

But there’s not 1.2 million tonnes of saleable resource available to AI at Straitgate – not unless AI’s excavators go below the water table, not if any material is to be left to protect springs and water supplies, not if permanent water bodies are to be avoided.

It is one thing being loose with resource figures for a Minerals Plan, it is another thing if those same loose figures are still being wheeled out for a planning application. Especially when they’re wrong. Imagine an application for up to 1200 homes, and the builder in reality is only able to deliver less than 900 – and even those risk standing in water.

We’ve long argued that there is nowhere near the resource at Straitgate that is being claimed, but ever since ECC (AI’s predecessor) bought the farm back in 1965 with the promise of 20 million tonnes, the farm’s available resource has been on a steep downward trajectory; we posted that Straitgate has already been a disaster for AI and made comparison with You have two cows.

In more recent times, AI’s geological survey in 2011 confidently predicted 7.25 million tonnes being available, but DCC’s Minerals Plan consultation the following year cut that to 3.6 million tonnes after "the site appraisal found that there is likely to be a significant impact on the water environment (and consequently on biodiversity) if mineral extraction occurred in the eastern half of the [site]". In 2015, AI’s request for a scoping opinion was still talking about 2.8 million tonnes (above and below the water table), but that was cut to 1.66 million tonnes (above the water table, to include some overburden) by the time the planning application was submitted the same year. But even that was too much, and by the time the Minerals Plan was adopted there was "Up to 1.2 million tonnes from extraction above the protected water table": 17% of what AI put forward in 2011; 6% of what was thought possible in 1965.

But the decline hasn’t stopped there. After the extraction area was reduced last year, the available saleable resource – according to AI’s own figures – fell to 1.1 million tonnes.

And after all the recent issues with groundwater modelling that amount is plainly not available now either.

How much worse can it get? Well, considering that the proposed extraction area will have to be reduced again and the proposed quarry floor will also have to be raised, AI is now looking at less than a million tonnes in total; arguably less, ironically, than DCC belatedly accepted in 2016:
Given that Aggregate Industries has stated the quantity by which their original resource figure would be reduced by compliance with the requirements of Table C.4 of the Plan, I consider that it would improve clarity of the Plan if the currently-modified reference to “Up to 1.2 million tonnes” be replaced by “Approximately 0.9 million tonnes”.
But that prompted AI to rush out the resource statement referred to above, talking about PERC Standards being "rigorously applied", and DCC backtracked, rolled-over, and removed the 1m buffer to protect people’s water supplies in the process:

People will rightly question whether AI's scheme at Straitgate is still financially worthwhile. Even back at the 1968 public enquiry, ECC was making the case that:
... for financial reasons it is necessary that approval should be obtained for large sites... only large projects could carry the cost of restoration...
... no aggregates operator would consider (for example) trying to develop a sand and gravel deposit of less than one million tonnes
But AI obviously lives in an alternative economic world. It must do, if it not only thinks it can still make a go of a sub-million tonne site with its colourful variety of constraints, but that it can also stomach the costs of hauling the winnings a 46 mile round-trip for processing – some 2.5 million miles in all. Of course, when AI pulled the last application for Straitgate, and dreamt up this bonkers plan, diesel was sitting at £1/litre; now it’s 25% higher, and the construction industry has hit the skids. But hey, that’s life.

The NPPF says that, when determining planning applications, local planning authorities should:
give great weight to the benefits of the mineral extraction
but also:
ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety...
So what amount of material would outweigh the adverse environmental impacts of carving up an East Devon farm? Obviously, even with great weight, 1 tonne of minerals would not have enough benefit; neither would 10,000 tonnes. So what amount would? Councillors eventually determining this application, and local people bearing the brunt of AI’s plans, have a right to know.

Clearly, therefore, and to act as a cross-check of the company's true intentions, AI needs to produce a revised resource statement – since its application for Straitgate Farm and associated 'benefit' is not what it was, and is not what is claimed.

Thursday, 21 June 2018

Would the S106 water monitoring plan for Straitgate be as successful as Blackhill’s?

The water regime in and around Straitgate Farm is not only complicated but important: There are springs and streams. There is groundwater and surface water. There are over 100 people reliant on the site for their drinking water. There are farms reliant on springs to water their livestock. There are wetland habitats in ancient woodlands. There are communities downstream vulnerable to flooding. There is even a Grade I Tudor manor house dependent on the water – including for its tearooms and mediaeval fishponds.

Clearly, based on previous posts, Aggregate Industries and its consultants are still a long way from producing an accurate hydrological picture of this sensitive area.

But overlooking that for a moment, could we trust AI to respect the water? Could we trust AI not to derogate it? Not to pollute it? Could we trust AI to do what it says it will do?

In an effort to win the keys to quarry Straitgate, AI has proposed a water monitoring plan:

That’s fine then, you might think. How sensible. What could possibly go wrong?

Plenty. Take a look at DCC's latest monitoring report for nearby Blackhill Quarry, and AI’s compliance – or rather non-compliance – with the Section 106 agreement for hydrological monitoring for that site:

If AI can't be bothered to fulfil its Blackhill obligations, what hope is there for Straitgate? What hope for people who lose their drinking water supplies? What hope for people whose supplies become contaminated? What hope for timely action, when the last three hydrological monitoring reports for Blackhill have either been submitted late or not at all, when surface flows haven't been measured since 2011? What use is the wording below, if AI doesn't comply with Section 106 agreements?

And there's the wider issue. There would be very many planning conditions for any quarry at Straitgate. Who’s going to monitor and enforce them all? Because we evidently can’t trust AI. And a warning from DCC obviously does no good either, judging by the previous year’s monitoring report for Blackhill:

That's the same monitoring report, by the way, that reminds us of the one metre left unquarried above the maximum level of the water table to protect groundwater at Thorn Tree Plantation at Blackhill; Thorn Tree being a site that did not have the same groundwater sensitivities as Straitgate; one metre being the level of protection that AI thinks it can do without at Straitgate; Straitgate being a site where the maximum water table is still unknown:

AI’s infiltration plans can’t work either – with groundwater this close to the surface

The issue of surface water management is critical at Straitgate Farm if any quarrying is to be permitted.

Surface run-off must not increase flooding downstream, it must maintain stream flows and groundwater recharge, and must not create permanent bodies of water that might attract birds and cause a birdstrike issue for planes landing at Exeter Airport. DCC warned in 2015:
The surface water management is inextricably connected to Flood Risk Management/Airport safeguarding and the need to maintain and recharge watercourses. This issue is so important in terms of the likely significant impacts of the proposal the MPA would wish to ensure that a SWM scheme can be designed to meet all of the requirements identified in advance of the determination of this application. 17
And again in 2017:
The MPA will wish to have it demonstrated that the applicant has engaged with the LLFA, the EA and the Airport to design a scheme that can accord with all of their various requirements. 2.18
Over the years countless consultants' reports have been written on the subject; they are not always consistent. Take the Updated Flood Risk Assessment for example:
Flows from the spring line adjacent to the Site may become more responsive to rainfall events as the removal of part of the unsaturated zone will decrease the time taken for water to recharge the aquifer. 3.5.4
Whilst this response a few months later from the same group of consultants said the opposite:
This increase in the proportion of rainfall passing to groundwater recharge will act to slightly flatten the hydrographs of the watercourses during storm events... reducing downstream impact. 2.11.3
It’s bad news when even the consultants are confused.

AI’s current answer to surface water management at Straitgate is to have infiltration areas along the eastern boundary of the proposed extraction area, shown in blue on the maps below:
Quarrying operations will be excavating down to... 3m along the eastern boundary... 2.18.3

The proposed infiltration areas at the Straitgate Quarry [sic] have been designed to meet national guidance on design events (1 in 100 year with climate change). 2.18.5
All runoff can be infiltrated via the provision of the storage volumes specified in the void base for each phase to allow for infiltration into the BSPB. 6.1.9

But from recent posts – in particular AI has ‘forgotten’ one 1990 borehole – that puts groundwater 2.8M ABOVE MWWT – you can see that, as things stand, this can't work.

Surface water would obviously not soak away in these infiltration areas in the way that AI and Amec hope, not if groundwater is as close to the surface along this boundary as these piezometers have recorded: PZ2017/02: 1.72m, PZ2017/03: 0.43m, SG1990/021: 1.26m.

So unless the intention is to flood downstream communities, and have long stretches of ponding along the eastern boundary (meaning a run-in with Exeter Airport), AI’s flooding consultants will need to go back the drawing board.

Tuesday, 19 June 2018

And what impact will “rapid infiltration” have on the MWWT?

You may have noticed a pattern to the previous few posts:
They all relate to Aggregate Industries not knowing with any certainty where the maximum winter water table at Straitgate Farm lies, which is a problem, because it is this surface that AI proposes to dig down to, it is this surface that must be known if environmental impacts are to be understood, it is this surface that must be known before any quarry planning application can be determined.

We've pointed out some of the problems in the posts above, but it’s actually worse than that.

Look at this table of infiltration rates derived from tests undertaken at Straitgate Farm:

AI is having enough trouble determining the maximum winter water table beneath the existing geology, beneath poorly draining clayey material, material that according to the table above has a "negligible infiltration rate".

AI proposes to open up 22.6 hectares of this area, to expose the Budleigh Salterton Pebble Beds for sand and gravel extraction, and reckons the disturbed overburden material, will have a "much enhanced infiltration rate"; i.e. there will be less surface water and more groundwater. Amec confirms:
Not only that, but during the:
What effect would this "rapid infiltration" have on the MWWT? Well, it’s obviously going to increase groundwater levels, but by how much we have not been told.

The Environment Agency recognised the issue, writing earlier this year:
... Table 2.2, shows the disturbed overburden material to have a ‘much enhanced infiltration rate’. The applicant should clarify how the infiltration rate of the proposed backfill material compares to that of the in-situ material, and what effect the change between in-situ and disturbed overburden material might have on groundwater levels beneath the site.
How much might enhanced and rapid infiltration raise groundwater levels? Here's a clue from AI's Hydrogeological Assessment:
Taking the most intense daily rainfall event recorded over the monitoring period from 2013 of 59 mm (23/12/2013), ignoring evaporation and overland flow, and assuming a conservative porosity for the BSPB of say 10% and 15% for the overburden, this rainfall event would result in a rise in the saturated rock of 0.59 m for the BSPB or 0.40 m for the overburden 5.3.9
In other words, as little as 6cm of extra infiltration could lead to a 0.6m increase in groundwater levels; likewise 10cm could lead to 1m, 20cm to 2m.

This is a big deal – particularly as water levels in large areas of the site are already higher than expected.

AI’s and Amec’s groundwater predictions are falling apart all over the site

Another post, another tale of groundwater modelling problems – this time PZ2016/001, PZ2016/002, PZ2017/04 and PZ2017/05.

Firstly, PZ2016/001 and PZ2016/002: Why are levels in these two piezometers important? Because they formed the basis of a meeting between Aggregate Industries and the Environment Agency last year, a meeting where AI tried to convince the EA of the merits of its seasonal working scheme – in particular how much unsaturated material would be left in situ during summer working down to the maximum winter water table.

It was agreed following the meeting that AI would
1. Produce a contour map showing the difference between the grid and the recorded maximum water levels across the site
In order to provide clarification to point 1. above, the actual recorded maximum water levels to date for piezometers 2016/001 and 2016/002 (142.1mAOD and 143.1mAOD respectively) were uploaded to a copy of the existing MWWT model… When compared to the original ‘grid’ this effectively pulled the contours down in the central parts of the site revealing the extent of unsaturated mineral that would be left below the working base. A contour map has been produced…
That contour map was the subject of the previous post And these contours are a joke too – with errors the height of houses!

At the meeting, AI acknowledged that:
the maximum water levels recorded at piezometers 2016/001 and 2016/002 may not actually be representative of maximum levels as these piezometers did not exist in the wet years of 2013 and 2014.
But then tried to persuade the EA that:
the data does not suggest that the highest water level [at 2016/001] will be higher than 142.1m AOD… Groundwater level at 2017/002 [sic] seems to be even less responsive and is even less likely to approach the ‘apparently’ conservative elevation of the MWWT at this location.
It was also discussed at the meeting on the 10th August that although piezometers 2016/001 and 2016/002 had only been reading for a short period they followed the same pattern of little difference between summer and winter as did the 'dry' western part of the site. This suggests that groundwater in the middle of the site is still draining rapidly eastwards to where it backs up against the Otter Sandstone and drains to the lower water table. As such it is likely the water level in these piezometers may never reach substantially higher levels.
Has this been the case? Of course not.

This year – which as we have already posted was unexceptional for rainfall – PZ2016/001 reached 142.64m AOD and PZ2016/002 143.98m AOD. This may be below the MWWT, but given that the winter and spring of 2013/2014 saw 35% more rainfall in the South West than 2018, who knows where these levels might reach – certainly not AI, as they have already clearly demonstrated.

But it’s not just AI that’s been found out. Last November, in correspondence with the EA following a request for additional information, AI's water consultants Amec Foster Wheeler – despite not yet having the benefit of borehole data – were trying to convince the Agency that in the northwest of the site "very little (if any) water level fluctuation is observed":
It is worth reiterating that groundwater levels vary very little in the northwest of the site and the BSPB is effectively dry for much of the time.  Groundwater levels do not vary much here because water drains rapidly through the formation to where it accumulates in the east and south east (upgradient of the fault) where large thicknesses of unsaturated material exist to accommodate this flow.
PZ2017/04 and PZ2017/05 – shown on the map below – have now provided a limited amount of groundwater data. Does it back up Amec’s assertions? Of course not. PZ2017/04 has so far shown a groundwater variation of 1.34m and PZ2017/05 1.88m – which is plainly neither very little fluctuation nor material that is effectively dry for much of the time.

As we’ve said before, AI and Amec appear prepared to say anything in order to win approval.

Thursday, 14 June 2018

And these contours are a joke too – with errors the height of houses!

By now you might be thinking that Aggregate Industries’ model of groundwater at Straitgate Farm couldn’t get any worse. You’d be wrong.

The contour map below was supplied by Amec last year to back up AI’s seasonal working scheme and satisfy concerns from the Environment Agency. It is a work of fiction.

The map has been given the Amec Foster Wheeler seal, but the contours started life on the AI map below: "Isopachs of average summer unsaturated mineral". It was one of the reasons why we questioned whether these things were being put together by competent experts – because:
To ensure the completeness and quality of the Environmental Statement, the developer must ensure that it is prepared by competent experts.
Anyway, AI would have us believe that the contours show the difference between the maximum winter water table and the average summer low groundwater levels. It was supplied to the EA to show that AI can be trusted to dig down to the MWWT during the summer months without affecting surrounding drinking water supplies or wetland habitats in ancient woodland; to show that in the drier months there would always be 1m separating its excavators from groundwater levels.

You may not believe it, but the contours were derived from just 6 locations. You have to admire the creativity; local people have referred to these contours as "The Himalayas".

But, yes, you’ve already spotted the problem: the average summer low is not the summer maximum. AI is looking at the best case summer water levels – the best case for the company that is: the very lowest levels recorded that would allow its seasonal scheme to succeed. The contours are meaningless as an indicator of the validity and safety of AI's scheme. If maximum summer water levels had been used, AI's model would fall apart; we have already posted on the subject:
... 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
Anyway, it's worse than that.

Boreholes from this year and 1990 have really put the boot in and exposed the contours across large areas of the site for what they really are – fiction.

Take SG1990/021 – subject of the last post – as an example. Amec has modelled the MWWT in this location to be 136m AOD. AI's isopachs claim that the difference between the MWWT and the average summer low in this location is 4.0m; here is an enlarged screenshot from the map below, the crosshairs mark the position of SG1990/021:

AI is therefore claiming (taking 4 from 136) that the average summer low groundwater level in this location is 132m AOD. The trouble is that borehole SG1990/021 recorded the groundwater level in mid June to be 138.81m AOD6.8m higher, or about the height of a house

Three other locations – indicated below – also show significant discrepancies.

What's laughable is that, if you look at the top contour map, you’ll find AI’s consultants making predictions to the nearest centimetre:
At the nearest point to PZ01 within the excavation, difference is 1.17 m
At the nearest point to PZ03 within the excavation, difference is 4.78 m
At the nearest point to PZ04 within the excavation, difference is 5.83 m
At the nearest point to PZ06 within the excavation, difference is 2.34 m
The reality is that AI and its consultants can’t even make predictions to the nearest metre. Competent experts?? GCSE maths students would make a better job.

We’ve reminded people many times before, but in Dr Helen Rutter’s words:
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.
Here are some of those errors:

Tuesday, 12 June 2018

AI has ‘forgotten’ one 1990 borehole – that puts groundwater 2.8M ABOVE MWWT

If you thought 1.6m under water was bad, how about 2.8m – in the middle of summer? If Aggregate Industries' model of the groundwater at Straitgate Farm wasn't laughable before, it is now.

Last week we posted how AI’s water problems at Straitgate go from bad to worse. We posted how AI’s quarry plans are now under water in four places. We posted how water levels in piezometers PZ2017/02 and PZ2017/03 have this spring exceeded AI's maximum winter water table model by 1.3m and 1.6m respectively.

But it’s worse than that. Look at this map of the various boreholes drilled at Straitgate before 2011. Look at SG1990/021, south of where PZ2017/03 is located.

This borehole was drilled in 1990. The map refers to "W 6.7", where W is the depth of the saturated zone above marl in metres. What this means is that water was recorded 1.3m from the ground surface (3.1+4.9-6.7). This is clarified in "Report on the reserves of Pebble Beds at Straitgate Farm, near Rockbeare", supplied to us by AI some years ago; a report that was based on analysis of 24 boreholes. The full borehole logs show that on 12/6/90 the water level in borehole 21 was 1.26m below the surface.

But it’s worse than that. Whilst AI’s water consultants Amec (now Wood) have modelled the MWWT – the proposed base to any quarry – to 136m in this location, the data sheet below shows the height of the groundwater here recorded as 138.81m AOD – a full 2.8m above Amec’s guesstimate. Notably, this was recorded in mid June, not in winter or spring when groundwater levels would normally be higher.

Not only does this further undermine Amec’s MWWT model, and any tolerance levels the consultants might produce, but it also means that there is again no winnable sand and gravel from this area or from the – as yet undetermined – surrounding area.

But it’s worse than that. AI was in possession of this data all along, not just in a dusty 1990 report, but on the map above – a map that was also supplied to DCC for preparation of the Devon Minerals Plan. Why therefore has the company proposed to dig in this location? If AI’s water consultants knew about it, why have they proposed the same? Was it just a matter of trying to get away with things?

Because SG1990/021 is exactly where Amec has proposed infiltration areas to control flooding and maintain stream flows; and exactly where Amec has proposed, post restoration, and for evermore:
ephemeral water bodies and species-rich wet grassland to be encouraged in low-lying infiltration areas (in the base of the depressions)
The data for PZ2017/02, PZ2017/03 and now SG1990/021 show however that water bodies in this extended area might not be ephemeral at all – not if these infiltration areas have to cope with surface water run-off from 55 acres, not if there's groundwater sitting here less than 0.5m below the surface. And this is a problem, not only for flooding and stream flows, but also because the MD of Exeter Airport was under the impression that:
For the avoidance of doubt, one of our conditions was that the site will not have any new permanent bodies of water and furthermore we have corresponded with DCC in relation to this matter... if the planning authority approves the application without including the conditions requested by the airport, then the airport has the right to engage the CAA to request that the application be called-in for determination by the Secretary of State.
AI will have to further pull in the extraction boundaries and remodel the MWWT accordingly, which will again reduce the available resource.

Friday, 8 June 2018

AI’s water problems at Straitgate Farm go from bad to worse – quarry plans now UNDER WATER IN FOUR PLACES by up to 1.6M

The depth of proposed extraction is one of the most critical pieces of information for any quarry planning application. Why? Because it determines how much resource can be wrestled from the earth, and how much damage will be caused to the surrounding water regime in the process.

Surely by now, three years on from the company’s first planning application, Aggregate Industries should know how deep it could safely dig at Straitgate Farm? You would have thought so, but no – not judging by the latest groundwater monitoring data.

AI has claimed – contrary to warnings from other hydrogeologists – that it’s safe to dig down to the maximum winter water table, but after five years of groundwater monitoring and 18 boreholes it’s clear that the company still hasn’t discovered exactly where that level is.

Determining the MWWT is important because AI plans to work Straitgate dry. It needs to do this to protect surrounding springs, streams and drinking water supplies. We’ve always said that AI can’t model this MWWT with any sort of accuracy – except at the locations measured. That’s why standardly 1m is left unquarried as a buffer to protect water supplies; a 1m buffer that AI has decided local people can do without, so it can bank the profits instead.

Consultants Amec (now Wood) claimed the MWWT had been "defined with confidence" but were reluctant to say how confident, in +/- m terms. Now we know why. Because the model – which it was claimed "builds in a conservatism" – has already failed, and AI’s seasonal working scheme has been exposed for what it is – a shambles.

But it’s worse than that. AI has now supplied us with groundwater monitoring data for Straitgate for the last quarter – and for the first time it came with a commentary, presumably from Wood:
Turning to the attached spreadsheet; you will see from the most recent data (Feb-April 2018) that groundwater levels in two of the newer piezometers installed in 2017 (PZ2017/02 and PZ2017/03) have shown higher groundwater levels than expected this winter. Groundwater levels in all other piezometers across the site have levels as expected and have remained lower than the gridded maximum winter water table, so this is thought to be a localised effect in an area where data was limited prior to the installation of the 2017 piezometers.
There could be a number of reasons for the higher than expected groundwater levels in this location such as:
* localised effects caused by temporary backing up behind the BGS fault (where BSPB is faulted against BSPB) which could be of lower permeability (reduction in transmissivity) than envisaged or positioned further west than mapped.
* localised clayey horizons giving rise to confined/semi-confined conditions.
In other words:
Whoops. We’ve got things wrong. We don’t really know why. We have a number of ideas. We hope the problem is localised but without drilling more boreholes we’re just guessing. We say it’s just these two points - but to tell you the truth, we haven’t properly checked the others yet. We’re now not even sure where the BGS fault is.
Hardly instills confidence does it?

How much 'higher than expected' has the groundwater risen in these two locations?

In February, we posted that groundwater levels at PZ2017/02 and PZ2017/03 had reached 134.62m and 138.06m, compared with the modelled MWWT in these locations of 135m and 137m respectively.

The latest data shows these levels have now risen further, and on 3/4 and 10/4/18 reached 136.28m and 138.57m – a difference compared with AI’s MWWT model of 1.3m and 1.6m respectively.

But it’s worse than that. The surface elevation at these positions is 138m and 139m AOD respectively.

There is therefore NO winnable sand and gravel from this area or from the – as yet undetermined – surrounding area. Even plans in 1967 recognised that much.

But it’s worse than that. Even overlooking the 1967 plans, AI has had 12 months warning about all this. PZ2017/03 is next to "Test Hole 4". We posted on this subject last year, how in June 2017 ‘Drillers were really surprised they struck water so quickly’. Given that in April this year, groundwater at this location reached less than 0.5m below ground level (139 - 138.57), it’s not so surprising now.

But it’s worse than that. Two other locations, PZ06 and PZ05a, also exceeded the MWWT model with new maximums of 132.43m and 146.78m reached on 15/3/18. On PZ05a, AI’s consultants hope that:
Water level thought to be below borehole screen and within sump as indicated by 'flatline' hydrograph. Hydrograph not representative of BSPB [groundwater levels]
But thinking so and knowing so is quite different. In any case, PZ05 in the same location has been flatlining for 5 years now. Was that not "representative" either? Does anyone trust these consultants to recognise "representative" groundwater levels based on previous errors?

So, Wood’s assertion that "Groundwater levels in all other piezometers across the site have levels as expected and have remained lower than the gridded maximum winter water table" is obviously incorrect.

But it’s worse than that. These elevated groundwater levels this year were not reached during a particularly wet winter and spring, according to Met Office data, and nothing like the winter of 2014 when the other ‘maximum’ groundwater levels were recorded elsewhere across the site. In fact, in the South West, total rainfall in the winter and spring of 2014 was 35% higher than the same period in 2018. These maps put things in perspective:

Any piezometer installed after 2014 (7 out of the 18) is therefore unlikely to have yet logged a maximum.

But it’s worse than that. These problems occur in and around the Environment Agency’s Source Protection Zone for the water supply for Grade I Cadhay. Furthermore, these elevated levels have plainly only been recorded where boreholes have actually been drilled. For all AI, Wood, or anybody else knows, they could be higher elsewhere. This is why – with more than 100 people reliant on the site for drinking water – precaution should obviously prevail.

But it’s worse than that. This puts a huge question mark over a large area of the proposed quarry. Look at the area around PZ05a, PZ06, PZ2017/02 and PZ2017/03. The MWWT will have to be remodelled to a higher level, and the proposed extraction area reduced. Last year we posted that AI’s extraction plans are now down to 6 fields and 1.1 million tonnes. These changes will reduce the available resource still further – to less than 5% the company thought it had in the 1960s. As it is, the proposed quarry base will have to be lifted across an extended area because the groundwater does not fall by 1m during the summer at PZ05, now PZ05a – and the undetermined area surrounding it – to allow AI’s seasonal working scheme to succeed.

No wonder DCC asked AI "to provide information on other sites either in their control or operated by another company where the proposed working technique is used successfully" in order "to consider whether the proposed working technique is a "novel approach" as set out in the NPPF" that would need financial guarantees. As we said at the time, how telling that AI could not point to a single other site where its unorthodox seasonal working scheme has been tried before.

It’s all a giant mess. How prescient hydrogeologist Dr Rutter was when she warned that at Straitgate:
Because errors are what we’ve got. And without many more boreholes and many more years of monitoring to give a fuller picture of what’s going on at Straitgate, errors are what we will keep on getting.

Who knows, if AI hadn’t been greedy for the last 1m of gravel above the MWWT perhaps none of the above problems would have been revealed? But then we could have been staring at large lagoons of water – and associated birdlife – directly under the flight path of Exeter Airport. We could have been staring at flooding downstream in Ottery St Mary. We could have been staring at all sorts of problems with surrounding water supplies. It doesn’t bear thinking about.

AI and its band of partisan consultants will now have to go back to their drawing boards and get their facts right, or, with the resource reduced still further, give it all up as a bad job.