Wednesday, 12 June 2019

CEMEX quarry plan in Suffolk – underlines AI’s reckless stance to water at Straitgate

Concerned residents in Suffolk have directed us towards a planning application submitted last month by CEMEX to quarry Lime Kiln Farm, an extension of Wangford Quarry. The site has been proposed by Suffolk County Council as a Preferred Area for gravel extraction in its draft Minerals Local Plan, despite being in the Suffolk Coast and Heaths AONB – where "planning permission should be refused for major development other than in exceptional circumstances" NPPF 172.

Readers will remember Aggregate Industries’ attempts not so long ago to win consent in the East Devon AONB – to process material from Straitgate at their existing plant adjacent to the East Devon Pebblebed Heaths. Approval would have meant a continued blight on Woodbury Common, and would have introduced nitrate-rich agricultural soils into an area sensitive to any nutrient change. After concern from Natural England, AI withdrew its application and has now relocated the plant.

But we’ve digressed. The reason for this post was to contrast the difference between CEMEX and AI in relation to protecting nearby groundwater supplies.

CEMEX has submitted a range of documents in support of its application to extend Wangford Quarry and to quarry up to 1 million tonnes of gravel over some 11 years. The small number of documents submitted by CEMEX contrasts with the huge jumble of fragmented reports AI has been forced to submit in its multi-year quest to win consent to quarry Straitgate Farm – a clear indication of the number of constraints the company faces here in East Devon.

One of the CEMEX documents is a Hydrogeological Assessment – again, a brief affair compared with the tomes supplied by AI’s consultants Amec Foster Wheeler for Straitgate. Interestingly, CEMEX’s consultants rely on "(Brassington, 2007)" – a reference to academic literature by Professor Brassington, a leading authority on groundwater, who recently wrote a damning report concluding that 'ANY quarrying at Straitgate would cause problems'. For the Wangford extension, the salient features are a public water supply 280m away, no private water supplies located within 2km, and a proportion of the site within an Environment Agency Source Protection Zone 2. Groundwater levels have been monitored close to the proposed site since 2002 and show a typical range of 0.6 to 1.4mAOD. In contrast, at Straitgate, which also has a SPZ2 designated across part of the site, groundwater levels have been monitored since 2013 and fluctuate in some areas by no more than 24cm and other areas by as much as 6m.

CEMEX’s report is in stark contrast to the risks AI is prepared to take with the "fragile groundwater system" at Straitgate. The conclusions from CEMEX's consultants, JBA Consulting:
Quarrying involves activities that have the potential to affect the hydrogeological environment of the area. These activities have been identified and an assessment of their potential effects made.
The operational phase potentially poses the greatest risk to the groundwater regime because it will involve constant earthworks and frequent vehicle movements. There will also be minimal vegetation and no soil within the excavation area.
The main potential impacts to the hydrogeological environment are: alteration of recharge pattern, reduction in groundwater quality and increased groundwater vulnerability.
Proposed mitigation measures include the use of a Pollution Prevention Plan and the limitation of all workings to at least 1m above the highest water table.
Yes, that’s right. For this very level Suffolk site, where the maximum groundwater level is relatively easy to model, CEMEX still proposes that working will be limited to "at least 1m above the highest water table". CEMEX's Non-Technical Summary reiterates:
Historically quarrying has always left 1 metre of undisturbed sand and gravel between the bottom of the quarry and the surface of the groundwater. It is proposed to continue to do this when quarrying Lime Kiln Farm. This will, however, reduce the depth of dry, or unsaturated, sand and gravel that lies above the groundwater. In turn, this means that it is easier for potentially polluting liquids, such as fuels and lubricants, to reach and pollute the groundwater if they are spilt. 2.7.4
In contrast, at Straitgate, AI is proposing to leave a 0m unquarried buffer above the maximum water table; a maximum water table the exact position of which is still unknown, and where – as AFW admitted before whitewashing its reports – "there is the possibility for steps in the water table related to faulting" and "there is also likely to be other unmapped local faulting".

The aquifer underlying Straitgate supplies water to more than 100 people, to livestock farms, wetland habitats in ancient woodland, mediaeval fishponds, and a Grade I manor house. Dr Rutter is "concerned that there is a very steep hydraulic gradient across the site... Variations in the shape of the water table cannot be contoured based on the number of piezometers used". Prof Brassington says "an unquarried buffer of at least 3 m [should be] left above the maximum water table to minimise the negative impacts".

If AI doesn't propose to leave an unquarried buffer above the maximum water table to safeguard water supplies – a buffer typically employed by CEMEX, Hanson and others, as we posted in Quarry companies struggle to dig in the right direction, let alone to the nearest cm – what does it propose? AI's cunning plan is to rely on groundwater levels falling by at least 1m over the summer months – and clearly in some areas they don’t – before digging down to the maximum water table, and backfilling with overburden before groundwater levels rebound in the winter. Prof Brassington says it’s "untried anywhere else in the country" and "too difficult for typical machine operators". We’ve posted on the scheme before in No wonder AI wants to keep Straitgate’s groundwater data secret, Seasonal working scheme for Straitgate can't work as AI describes and AI was asked a very simple question.

If that doesn’t ring warning bells, consider that the authors of this "revolutionary" scheme – at AI and consultants AFW – are both no longer with their respective companies.

What if this experiment screws up drinking water supplies and mediaeval fishponds? Who would sort out the mess, given AI’s legal assurances for alternative water supplies are “unfit for purpose”? Let’s hope the EA and DCC have some good answers. They could never say they weren’t warned.

An indication of things to come

In a post earlier in the year, Construction, demolition & excavation waste – largest waste stream in UK economy, we pointed to figures from the Minerals Products Association – the trade body representing Aggregate Industries and others, who claims "the need for resources and waste materials to be used more efficiently and effectively has never been so strong" – telling us that 120 million tonnes of construction, demolition and excavation waste is created each year – the largest waste stream in the UK economy – of which 26 million tonnes continues to be dumped in landfills.

The UK Green Building Council says "construction is still getting the circular economy wrong":
In the UK, construction, demolition and excavation account for 60% of both material use and waste generation. Humanity is on course to triple material extraction in the next 30 years and triple waste production by 2100.
Clearly the construction industry can't keep on like this. Fortunately there are signs – in these three recent stories – that some things are slowly moving in the right direction:

CDE recycling is set to receive a boost in the South West. A new £4m recycling plant has been set up on the outskirts of Bristol in response to demand. The materials recovery facility is set to be the most efficient and effective plant in the South West, processing construction and commercial waste, producing 'zero waste to landfill'.
The contractors that choose us are the ones that have environmental management systems at the forefront of their procurement so their sites have to be as close to ‘zero waste to landfill’ as possible. This new plant is the only one in the south-west that can process construction and demolition waste to that degree.

Meanwhile, Tarmac has become the first company in the UK to develop a new rubberised asphalt using recycled waste tyres. Some 40 million waste tyres are produced every year in the UK. The new material has been trialled in Coventry. Coventry City Council's senior highways engineer said:
We are delighted with the rubberised asphalt trial; we hope we can use more of the product across the city in the future to help divert waste tyres from landfill and incineration to reduce the carbon footprint for road construction projects in Coventry.
The Tyre Recovery Association, added:
While there has been significant progress in reusing and recycling waste tyres in the UK, there is still an over-reliance on the export of used tyres to countries such as China, India and Pakistan, who are importing fewer tyres as they become self-sufficient.
The UK needs a second disposal route for used tyres. Tarmac’s commitment to developing rubberised asphalt provides an excellent opportunity to achieve this and deliver environmental savings for this under-used waste stream.

Finally, in an indication of the recycling rates in construction waste that can be achieved – Station demolition achieves 95% recycling rate:
100% of the brick, timber and concrete removed from the site during the demolition work has been recycled for reuse elsewhere in the construction industry.

UK commits to ‘net zero’ emissions by 2050; Ottery declares climate emergency

The UK is set to become the first G7 country to legislate for net zero emissions. One architect of the Paris climate agreement said:
Theresa May, desperate to leave a positive legacy, said:
Now is the time to go further and faster to safeguard the environment for our children. This country led the world in innovation during the Industrial Revolution [through the use of fossil fuels], and now we must lead the world to a cleaner, greener form of growth.
Environmental groups welcomed the news, but were concerned that it wasn’t far or fast enough, and that the UK would retain the ability to use international carbon credits. The acting energy minister, said the government did not "intend" to use such credits but had kept it "as an option". The Committee on Climate Change had warned "it is essential that the commitment [to net-zero] is achieved without use of international credits". The chief scientist for Greenpeace UK said:
As the birthplace of the Industrial Revolution, it is right that the UK is the world’s first major economy to commit to completely end its contribution to climate change, but trying to shift the burden to developing nations through international carbon credits undermines that commitment. This type of offsetting has a history of failure and is not, according to the government’s climate advisers, cost-efficient.

As part of the declaration, Ottery Town Council will set up a working group consisting of "councillors, residents, experts, scientists, businesses and young citizens" to recommend actions, policies and changes "to make Ottery St Mary a carbon-zero town by 2030".
Anyone interested in joining the group or has interest or knowledge of environmental issues, the science behind climate change and the local geography and economy should email the assistant town clerk.
Ottery St Mary’s new Mayor said:
Ottery St Mary has been at the forefront of environmental actions for a very long time. We have enjoyed the benefit of several excellent green groups: Recycling in Ottery almost 25 years ago, followed by Otter Rotters and most recently the Plastic Free Ottery group.
It is, therefore, entirely appropriate Ottery will become one of the first towns to comprehensively address this crucially important issue.
I look forward to Ottery St Mary Town Council engaging with local people - especially with younger people - to fully play our part in tackling the great threat of climate change.

Friday, 7 June 2019

Bussels No 7A and its link – or not – to the MWWT at Straitgate

So, there are now two independent hydrogeology experts who have serious problems with Aggregate Industries’ scheme to quarry Straitgate Farm; two independent hydrogeology experts who have discredited AI’s hydrogeology reports and found fault with their conclusions. How many more experts will be needed before the Environment Agency sits up and takes note?

Whilst, incredulously, the EA is prepared to accept AI's highly unorthodox working scheme – despite evidence that AI's model of the water table has already failed dramatically – both Dr Helen Rutter and Professor Rick Brassington point to the proposal's serious risk to drinking water supplies to over 100 people, 3 farms and a Grade I Manor House. Prof Brassington says:
any proposals to quarry at Straitgate Farm will impact on the fragile groundwater system and cause the flows of springs to decrease and the quality of the water also to deteriorate 5.7
With the Boeing 737 Max scandal, there has been much talk recently of "regulatory capture", or:
what happens when a government agency’s relationship with the industry it oversees becomes too close for comfort; instead of acting primarily in the interests of the public, it puts the needs of businesses first.
Let’s hope that’s not the case with the EA, who works closely with the aggregate conglomerates – here being just one example.

One section of Prof Brassington’s report was devoted to how – based on the the agency's own policies – the EA should be responding to this application:
it is strongly suggested here that the EA has not recognized that the hydrogeology and groundwater resources of this area are very sensitive and fragile. 5.5 It is expected that the EA should object strongly to this proposal. 5.6
A major bone of contention is the location of the maximum winter water table. AI proposes to quarry down to this level. It clearly doesn’t know exactly where it is.

AI and its consultants Amec Foster Wheeler (now Wood) quote the MWWT to cm precision, yet in places it is clearly out by almost 3m. The EA is of the view that the MWWT can be re-guesstimated using recent elevated levels "immediately before operation of the quarry begins" – despite infiltration plans being unable to work with groundwater so close to the surface – but it has at least pushed AI/AFW to provide tolerances, errors in +/- m, for this surface: numbers first asked for in 2016, which have still not been provided, at least publicly.

AFW say the winters of 2013 and 2014 – conveniently and coincidentally when AI first started monitoring the area – can be relied upon to derive, model, guess, the maximum water table:
Monitoring over the exceptionally wet winters of 2013 and 2014 allow this surface to be defined with confidence. 6.2.2
Both Dr Rutter and Prof Brassington disagree. Prof Brassington says:
...the MWWT is not a representation of the maximum water table readings for the proposed quarry site
Prof Brassington points to the records of Salston Stream – included in AFW’s hydrogeological assessment – which indicate that groundwater levels would have been higher across the site in both 1976/77 and 2000/01.

How then were AI/AFW so sure that 2013/14 could "allow this surface to be defined with confidence"? AFW pointed to other borehole records around the area, compared historic readings with those from 2013/2014, and then employed some smoke and mirrors:
Whilst it is recognised that 2013 and 2014 are considered to be extremely wet years in terms of rainfall, the observed groundwater level data themselves do not provide sufficient context to establish whether the observed groundwater levels might be considered to be close to the historical maximum. Therefore additional historic data for both rainfall and groundwater levels have therefore been obtained from the EA and reviewed to better understand the historical fluctuations in groundwater levels. 4.2
AFW looked at the records for the Salston Stream – one of the four watercourses emanating from Straitgate. It looked at the baseflows – the stream flow sustained between precipitation events:
Daily flow data for the period 1976 to September 2016 have been examined for the nearby weir at Salston, located 2.5 km downstream of the Straitgate site. It is clear that very high baseflow occurred in the winter months of 2012/13 and 2013/14, reflecting high BSPB spring flows (and therefore high groundwater levels). The only previous periods characterised by similarly high baseflow were the winter periods of 2000/01 and 1976/77. 4.2.8

Clearly, however, the baseflows recorded in 2000/01 and 1976/77 – as Prof Brassington points out: "1976/77 being over 11 Ml/d and 2000/01 some 7.5 Ml/d compared with 6.5 Ml/d for both 2012/13 and 2013/14" – were not convenient to AI/AFW’s argument. And here's the clever bit: In the next line – when AFW pointed to borehole Bussels No 7A, for which there are long term records – AI's consultants effectively dismissed both 2000/01 and 1976/77 at one stroke:
The nearest CEH groundwater index well with similar geology is located at Bussels No.7A, constructed in the Permo-Triassic sandstone in the Exe Valley. Groundwater levels in the winter of 2012/13 and 2013/14 rose c. 0.3 m above the previous long-term maximum level recorded in 2000/01. 4.2.8
No mention of 1976/77, but how very convenient for AI. Where actually is Bussels No 7A?

Miles away. Is it representative of monitoring boreholes around Straitgate, which are 6-12m deep? No. Bussels No 7A is 91.44m deep. Dr Rutter says "I don’t consider it relevant":
this well is over 90m deep and unlikely to respond to recharge in the same way as the shallow groundwater.
At Bussels No 7A, "annual fluctuations are normally between 1 and 2 metres." Boreholes around Straitgate see annual fluctuations as much as 6 metres.

AFW also pointed to records from "four EA observation boreholes … within the Otter Valley" to substantiate its claims. However, as Dr Rutter says:
the report suggests that all of the EA monitoring wells show that 2013/14 represented the historical highest GWL. Longmead stopped recording in 2012, and West Hill Village Hall has a short record, therefore this conclusion cannot be drawn from either of these. Salston Cottages looks as if there were similar high levels around 2000/01, and other earlier years… Woodbury Common appears to be the only one that you can say definitely had higher levels in 2013/14. But again, without some comparison of groundwater level responses between this well and the site piezometers, it is not possible to say if this well is representative.
But based on Bussels No 7A, and the other dodgy assortment of borehole records, AFW then made the grand claim – a claim that dictates the total resource and total profit that can be recovered by AI from Straitgate, the raison d'être for the whole planning application – that:
These data provide supporting evidence for using the exceptionally high groundwater level conditions in the winter months of 2012/13 and 2013/14 as indicative of peak (winter) groundwater levels.4.2.9

Another case of outright deception from AI’s consultants, or just a simple lack of professional nous? Either way, it won’t bring any comfort to the many people who rely on the area for their drinking water, who will no doubt ask the question: Can any of the conclusions in AI's hydrogeological and flood risk assessments – for example, when the word "unlikely" is used – be trusted?

When AI and its consultants say ‘unlikely’ what does that mean?

In Aggregate Industries' recent planning application for Westleigh Quarry near Burlescombe, to vary the approved working scheme to extract an additional 600,000 tonnes, one of the supporting documents told us what the word "unlikely" means "in reference to the degree of confidence in predicting an impact on ecological interests".

It’s something to bear in mind, when reading documents in support of AI’s application to quarry Straitgate Farm, when consultants say things like:
It is therefore considered that the proposal is unlikely to impact adversely on the quality of groundwater supplying nearby local private water supplies 5.3.44

Birdcage Spring is unlikely to be affected by the excavation

Great Fir Spring… is unlikely to be adversely affected by the dry working proposals
Pitfield Spring… is unlikely to be adversely affected by the dry working proposals

In the Westleigh document, it tells us what unlikely means in an Environmental Statement context:
Unlikely: Probability estimated above 5% but less than 50% 2.9
So, let’s rephrase one of those above statements for Straitgate to reflect that:
It is therefore considered that there is up to 50% chance that the proposal will adversely impact the quality of groundwater supplying nearby local private water supplies
Perhaps that might focus minds at County Hall – more so since AI’s legal assurances for alternative water supplies are "unfit for purpose". Consider for example that Birdcage Spring – which has up to 50% chance of being affected by the excavation and supplies a livestock farm – is miles away from any alternative mains water supply.

We are of course assuming that the consultant’s assumptions – unlikely, highly unlikely or otherwise – have not been swayed by its paymasters. It’s something worth pointing out, because when AI’s consultants say "Cadhay Springs are highly unlikely to be affected by the excavation" – i.e. a "probability estimated at less than 5%" – Professor Brassington, an independent expert authority on groundwater, author of scientific papers and textbooks on the subject, paints an entirely different picture:
the reliance of the Cadhay House and associated businesses on the spring for a water supply means that the EA should object to this proposal 5.5 It is strongly suggested here that any proposals to quarry at Straitgate Farm will impact on the fragile groundwater system and cause the flows of springs to decrease and the quality of the water also to deteriorate. 5.7

Quarry companies struggle to dig in the right direction, let alone to the nearest cm

At Straitgate Farm, Aggregate Industries proposes to quarry down to the maximum winter water table – wherever that might be.

I am concerned that there is a very steep hydraulic gradient across the site, from around 152m in the west to less than 135 m in the east, and the limited number of piezometers used to grid the water table surface. Variations in the shape of the water table cannot be contoured based on the number of piezometers used in the application.
... groundwater resources of this area are very sensitive and fragile [but] if Devon County Council are minded to grant permission for these proposals, despite the evidence given in this report, they are asked to ensure that an unquarried buffer of at least 3 m is left above the maximum water table to minimise the negative impacts.
It’s standard to leave an unquarried buffer or safety margin in a quarry where nearby groundwater supplies are at risk from pollution or degradation.

Quarries on sites less sloping, or where’s there’s less at stake, might leave less than 3m. Some leave 2m or more. At Town Farm Quarry – a quarry that has the same geology that underlies Straitgate, but where only two properties were reliant on private water – Hanson left 1m. Hanson recognised:
The unsaturated zone above the water table affords protection of the aquifer from surface pollution, allowing adsorption, attenuation and degradation of contaminants prior to reaching the water table. Removal of lower permeability clay layers from within the Pebble Beds could also remove some protection from the groundwater. During the operation of the site pollution may arise from the extraction and restoration activities. The pollution may be in the form of fuel, lubricants and other fluids associated with the operator’s machinery. C3.1
Once upon a time, AI also said it was going to leave 1m unquarried above the MWWT. AI confirmed this to the EA and DCC. The EA said:
Aggregate Industries have proposed to stop quarrying a metre above the water-table. We expect DCC to make this a condition of any permission that is granted.
It was a lie. Resource figures put forward by the company showed that AI intended to leave 0m. It took months before the company came clean on the matter.

But it’s not just that. AI claims it knows where the MWWT is to cm accuracy, and furthermore that it could dig to this. That’s also a lie, not least because water levels have already exceeded AI’s guesstimate by almost 3m in places.

But the truth is, quarry companies find it difficult digging in the right direction, let alone to the nearest cm.

Recent site inspections have highlighted that parts of the site are not being worked in accordance with those approved plans in terms of the directionality of the working.
restoration was not in accordance with the approved plans and failed to achieve a natural slope, leading to some areas becoming waterlogged while the ponds had reduced water levels
Unfortunately, AI is no better. At Houndaller in Devon – the site with 4 million tonnes of permitted sand and gravel reserves that the company is currently working – DCC’s monitoring report of 2016 reported:
The site is in contravention with the requirements of Condition B2 and Condition B6. The requirements of these conditions relate to the order of development in defined phases. The working of phase 4 should not have commenced until the "majority of the restoration, seeding and planting of the following Phases has been completed". 4.3
To "regularise the situation", agricultural land was lost – as DCC's monitoring report 2017 made clear:
To regularise the situation on site the operator submitted an interim restoration plan and a biodiversity statement. The statement provided evidence that the area which had previously been left to naturally regenerate had now developed valuable areas for ecological habitats. It was concluded that it would not be appropriate to regrade this area and return to the approved restoration of agricultural land given that this would then harm established habitats of value. 4.9
The point is, once quarry companies are left to their own devices, anything can happen. We posted examples in What’s the chance that AI would stop digging when it gets to the water table? of how much notice the industry takes of planning conditions and water tables, saying:
To be fair, it’s not just Aggregate Industries that breaches planning conditions – the whole industry is at it.
But what of AI's unorthodox scheme? According to Prof Brassington such a scheme is "untried anywhere else in the country", and:
It is suggested that this operational procedure is too difficult for typical machine operators and so the application should be refused unless there is a much thicker layer of unquarried rock left in place stipulated in the application. 4.20
Clearly, if quarry companies find it difficult to work in the right direction, or in the right phase order, or to the right depth, Prof Brassington has a very valid point.

EA flood defence scheme ‘will be like building a new quarry next to our homes’

The Environment Agency – in partnership with Blackwater Aggregates, a joint venture involving CEMEX UK – has proposed a 20-year quarrying operation as part of a £9m flood defence scheme for a trio of villages in Essex. Villagers are up in arms. One local councillor likened it to "using a sledgehammer to crack a peanut."

The EA says "quarrying operations... will ultimately support in the delivery of a flood alleviation scheme that would otherwise mean the public purse would need to contribute in excess of a further £25 million."

Councillors are not happy, and say that the EA’s proposals to create "1 in 100 year flood storage" would cause "irreparable damage" to the Blackwater Valley and "are out of proportion with what is needed":
It is not clear that the cause of the 2001 flooding was from the River Blackwater near Coggeshall - the flooding was not simply the result of heavy rain.
We are concerned about the proportionality of the plans and that the Environment Agency has seemingly already made its mind up.
The EA says there is "no viable alternative":
We have forged a valuable partnership with Blackwater Aggregates to develop a scheme fit for the communities - a scheme that not only provides flood protection but will take opportunities to enhance the rich flora and fauna and biodiversity features forming the River Blackwater valley and develop new habitats.
Locals say it will leave them with "20 years of noise, dust and pollution."

Thursday, 6 June 2019

Quarry protest at Oxford University

Last week, Warwickshire villagers protested outside St John’s College, following a decision to allow 220 acres of highest grade agricultural land that it owns to be used as a sand and gravel quarry. The protest was covered by two of Oxford University's student newspapers Cherwell and The Oxford Student:
Protesters brandished signs reading "Quarry dust can kill," "Land not sand" and "Quash the quarry" as they stood outside the porters lodge of St John’s College. Primary school children from the area wore air pollution masks and were handing out leaflets to passing students.
A Barford GP told The Oxford Mail that dust clouds that would be created by the quarry would be a "real danger," particularly for the young, the elderly, and people with chest conditions.
The Oxford Student

In that Oxford Mail article, the GP warned:
Dust from the quarry will contain silica, which can be extremely harmful to children, the elderly and those with chest conditions. In the USA and Canada there is legislation governing how near such a quarry can be to residential areas... distances far larger than this quarry will be from the village.
I am especially concerned for the hundreds of children who live nearby, particularly those who attend the nearby primary school and nursery. Over the time of the working of the quarry thousands of children will be affected.
The protestors are right to be concerned. Quarry dust, silica dust, can kill, does kill. The day after the protest, the article Construction must tackle its cancer problem appeared in Construction News:
According to the Health and Safety Executive (HSE), 40 per cent of occupational cancers in the UK are suffered by those in the construction industry.
For some added perspective, the industry employs around 7 per cent of the working population in the country, yet its people account for close to half of all workplace-related cancers.
Exposure to silica dust, released from cutting or grinding certain types of bricks, tiles and concrete, is the second biggest occupational killer, claiming more than 700 lives every year.
Awareness of the dangers of silica dust has increased, but again, it has come too late for far too many.

Industrial development a stage nearer at AI’s former Blackhill Quarry

East Devon District Council's planning committee will meet on 11 June to decide on a first phase of industrial development at Blackhill Quarry – a site in the East Devon AONB, surrounded by habitat of European importance for wildlife, where Aggregate Industries was granted permission to quarry and process material on the basis that the area would be restored to nature.

Quarrying is an industry of broken promises. We have posted about this before:
Why does quarrying have such a bad name? Take a look at Blackhill
Objections mount for CDE’s planning application for Blackhill Quarry
EDDC approves CDE's planning application for industrial units in East Devon AONB
EDDC planning officers have now recommended approval for the first phase of new development. The committee report reads:
The site lies in the open countryside, this part of which is designated as an area of outstanding natural beauty and lies adjacent to the Pebblebed Heaths SAC, where development should be strictly controlled so that it does not detrimentally impact on the character and appearance of the surroundings.
The principle of B2 industrial development for use by Blackhill Engineering has previously been accepted under the previous application and as such the principle of development cannot be questioned under the current application.
The proposed building would be the first in a phased development of the site, it would be of a suitable scale taking into account the limitations imposed at the outline stage in terms of height such that a building finished in green cladding under a dark grey roof would assimilate well into its surroundings.
Many will obviously disagree that such development "would assimilate well into its surroundings", or that it should be permitted anywhere near Woodbury Common. Aside from the profit motives of the applicant, Clinton Devon Estates, many will obviously wonder why such development – with all the additional HGV movements entailed – wouldn't have been more suited to an industrial estate.

Monday, 3 June 2019

Devon Gardens Trust objects

Following Professor Brassington’s damning report on the impact that plans to quarry Straitgate Farm would have on the "fragile groundwater system" – Professor of Hydrogeology says ‘ANY quarrying at Straitgate would cause problems’ – Devon Gardens Trust, acting for The Gardens Trust in its role as Statutory Consultee, has now objected to Aggregate Industries’ planning application. As DGT explains:
Local planning authorities must… consult the Gardens Trust on planning applications that may affect historic designed landscapes in England and Wales that are on the Register of Parks and Gardens of Special Historic Interest that is held by Historic England.
The NPPF says:
Substantial harm to or loss of: a) grade II ... parks or gardens, should be exceptional; b) ... grade I and II* listed buildings, grade I and II* registered parks and gardens,... should be wholly exceptional 194
We posted last year DGT concerned AI’s plans could turn Grade I Cadhay’s fishponds “into a quagmire”. Today the DGT has again written to DCC expressing its concern about the impact of AI’s plans on water supplies to Cadhay – a Tudor Manor House:
The water supply to the fishponds comes from a spring located just below the extraction site at Straitgate Farm, a mile to the west of Cadhay. The fishponds have relied on the spring as a source of water for over 500 years. If the proposed extraction disrupts the spring and the water supply, the fishponds which are an essential and important feature of the gardens at Cadhay, will be turned into a quagmire, to the considerable detriment of the historic designed landscape.
We have studied the report by Rick Brassington, Consultant Hydrogeologist, dated May 2019, on the Groundwater and related conditions at a proposed quarry near Ottery St Mary. The report considers the likely impact of the proposed quarry at Straitgate Farm on the water supply to Cadhay. The conclusions are much as we feared. The Gardens Trust is therefore extremely concerned about the effect that the proposed extraction of up to 1.5 million tonnes of as raised sand and gravel at Straitgate Farm would have on the water supply to the fishponds at Cadhay. We therefore ask your Council, in the light of the additional information by Rick Brassington, to refuse consent for this application.

Photo: Matt Austin

Thursday, 30 May 2019

Professor of Hydrogeology says ‘ANY quarrying at Straitgate would cause problems’

An extensive and damning new report has been produced which seriously undermines Aggregate Industries’ plans to quarry Straitgate Farm. An expert in hydrogeology, tasked with looking at the plan's impact on Cadhay's drinking water supplies and listed mediaeval fishponds, concludes:
My assessment of the proposed quarry is that it will cause problems to the groundwater system.
The expert is Professor Rick Brassington Eur Geol Eur Ing BSc MSc CGeol FGS CEng MICE FCIWEM, an independent consultant who has more than 50 years of professional experience in hydrogeology, and who has authored more than 30 scientific papers and two hydrogeology textbooks. More recently, Prof Brassington gave evidence at a public inquiry in relation to an application for a sand and gravel quarry on the edge of Hertford. The appeal by the applicant was dismissed – a decision endorsed by the Secretary of State last month, as we posted – based in large part on the risk to public water supplies.

In the case of Straitgate, Prof Brassington recognises that:
The groundwater resources that lie beneath the area around the proposed Straitgate Farm site are fundamental to the lives of more than 100 people in their homes and to the local businesses that they run. 6.6
The Environment Agency has a statutory duty to protect such "precious groundwater resources":

Before looking at Prof Brassington’s report in more detail, let’s remind ourselves what DCC’s Mineral Plan – "the policy framework for decisions by Devon County Council on planning applications for mineral development over the period to 2033" – says on groundwater in Policy M21:
The sustainable development of minerals should seek to conserve and enhance other natural resources, and proposals will be permitted where they would: (a) not harm the quality, availability and/or flow of surface water and groundwater and the integrity and function of the water system, both surrounding and, where relevant, within the site;
Let’s also remind ourselves how AI and consultants Amec Foster Wheeler tried to pull the wool over peoples’ eyes – including the EA – in their most recent response on hydrogeology:
The reduction in thickness of the unsaturated zone during works and post site restoration will not have any effect on groundwater quality. 2.17.7
It’s clear that Prof Brassington couldn’t disagree more. He says "any proposals to quarry at Straitgate Farm will impact on the fragile groundwater system and cause the flows of springs to decrease and the quality of the water also to deteriorate" 5.7.

He says the EA has not recognised that this groundwater resource is "very sensitive and fragile", and says "the EA should… strongly object to the proposal":
The EA states that its policy is to provide protection to sensitive areas where groundwater resources are of fundamental importance. It is strongly suggested here that the number of groundwater sources in the area around Straitgate Farm and Cadhay House where alternative water supplies are not easily available at an affordable cost means that the aquifer that feeds the local springs falls into this category. 5.2 ... it is strongly suggested here that the EA has not recognized that the hydrogeology and groundwater resources of this area are very sensitive and fragile. 5.5 It is strongly suggested here that the proposal will have a large impact on the local groundwater environment that is not recognized in the AMEC reports and therefore the EA should require the application to be refused. 5.9
He says AI’s and AFW’s efforts have been "to ensure that the maximum volume of stone can be removed from the site rather than to provide adequate protection for the groundwater resources" 5.8, and calls on DCC to refuse permission:
For the reasons stated above, Devon County Council is asked to refuse planning permission for the operation of the site. The method of working that is proposed is untried anywhere else in the country and is designed to maximize the sand and gravel dug with no regard to the changes it will inevitably bring to both the quantity and the quality of the groundwater and the springs it discharges through. Both these changes will cause difficulties to the users of these private water supplies. 6.13
Prof Brassington says AI’s unorthodox scheme is "untried and untested" and would not work in practice:
this operational procedure is too difficult for typical machine operators 4.20 [and] will not work in practice when the machine operators will be left to dig with little guidance 4.24.
On the subject of AFW’s guesstimate of the maximum winter water table – the MWWT, the base of any quarry – Prof Brassington says:
...the MWWT is not a representation of the maximum water table readings for the proposed quarry site. 4.16 ...the MWWT elevations proposed are not accurate and are out by almost 3 m in places 4.24.
In contrast to AI’s and AFW’s assumption that "the recent winter months of 2012/13 and 2013/14 [are] indicative of peak levels 4.2.11", Prof Brassington points to base flows from the Salston Stream – one of the four watercourse emanating from the site, whose flows are recorded by the EA – and says:
It can be concluded that the higher base flows in 1976/77 and 2000/01 would have resulted in higher groundwater levels across the site in a similar way that higher levels have been observed in the late winter of 2017/18. 4.23

What if that MWWT surface were remodelled to accommodate those elevated maximum water table readings? Prof Brassington says that even then:
A revised MWWT would not be acceptable as the groundwater system in the area is vulnerable and any quarrying would cause problems. 5.6
On the subject of groundwater quality, Prof Brassington says:
The proposed quarrying operation will reduce the groundwater recharge and reduce the spring flows. This is likely to lead to water shortages and the hardship that this brings. 6.2
Why? Because:
the aquifer is relatively thin and any reduction in the recharge it receives caused by an increase in runoff from the overburden used to make the protective layer… will make it even thinner thereby reducing the volume of groundwater held in storage. This will reduce the flows of the springs and could easily make them incapable of providing the volume of water required for drinking purposes. 3.25
The reduction in the unsaturated zone will reduce the time taken by percolating waters to reach the water table. As a result, there will be less time for the chemical and biological processes that develop the groundwater chemistry and the spring water will be more acidic and have a lower dissolved mineral content. 6.3
Not only that, but:
... the flows of both the Cadhay Wood Stream and the Cadhay Bog Stream will reduce as well as the various springs that flow into these woodlands. This will have a detrimental impact on the viability of the ecosystems that is expected to be permanent. 3.30 ... reduced flow of the Cadhay Wood stream will impact on the Cadhay mediaeval fishponds. 6.10
On the infiltration areas proposed, to protect Ottery from flooding, Prof Brassington says:
The proposed infiltration areas are sited where maximum groundwater levels have been recorded, as little as 0.43 m below ground surface, seemingly rendering them unworkable. 4.49
It’s all damning stuff, and Prof Brassington is unequivocal in calling for the application to be refused. If DCC nevertheless ignores such advice, putting the profits of a multinational before the security of drinking water supplies for local people, Prof Brassington says that extra safeguards would be needed:
If Devon County Council are minded to grant permission for these proposals, despite the evidence given in this report, they are asked to ensure that an unquarried buffer of at least 3 m is left above the maximum water table to minimise the negative impacts. It has already been demonstrated that the MWWT surface cannot be modelled accurately, neither can the MWWT be reliably adhered to during the operational phase. 6.14
AI, on the other hand – in its profit-hungry-wisdom – has proposed a 0m unquarried buffer above the maximum water table to safeguard water supplies – not "at least 3m". Furthermore:
If Devon County Council do grant permission for these proposals, they are asked to ensure that Cadhay House is included in the Section 106 properties and that this document specifically states that AI will promptly fund without any delay a replacement water supply to all those impacted by their workings. 6.15
Why is all this is so important? Water is of course essential for life, essential for people, businesses and wildlife. The fact that AI and consultants AFW – for the sake of an inconsequential and ever-decreasing amount of sand and gravel, not essential for the local or national community – are willing to play fast and loose with the security of private water supplies to three livestock farms and 100 or more people around Straitgate – plans that Prof Brassington says would "lead to water shortages and hardship" – is shameful.

What’s also shameful is that not only were AI’s legal assurances for alternative water supplies "unfit for purpose", but that AI was not prepared to include Cadhay in any Section 106 agreement covering alternative water supplies and/or compensation in the event of a failure caused by any quarrying at Straitgate Farm. According to DCC:
The view of AI remains that the information provided means that the risk is negligible and therefore does not need to be taken into account in the EA or the s.106.
Of course, if that risk were indeed negligible, it would have been painless for AI to indemnify Cadhay from any losses arising from quarrying activities. The fact that they won’t infers the company is fully aware of the risks and the potential financial exposure. It should be obvious to anyone that disruption of water supplies to Cadhay – a Grade I listed Manor House – would be catastrophic to the upkeep and maintenance of this historic treasure.

Prof Brassington’s report can be found here. It has been sent to DCC and the EA.

Tuesday, 28 May 2019

What do council declarations of ‘climate change emergency’ mean for planning?

We recently posted that DCC has declared a 'climate emergency'. Last week, another press release from Devon County Council announced 'Devon charts a course towards carbon neutrality'.

It's certainly a move in the right direction. DCC has pledged £250,000 towards developing a Devon Carbon Plan – a 'road map' to reduce carbon emissions – and has set up a Devon Climate Emergency Response Group. There are also plans for a 'citizens assembly' to ensure Devon’s residents have a voice in the process. DCC’s leader John Hart said:
Only by working together with strategic partners can we develop and implement an effective plan to ensure that Devon is on the right trajectory to meet the IPCC’s carbon reduction recommendations.
But what does DCC’s declaration of a 'climate emergency' actually mean? Others have recently been asking the same question:

In particular, what does a council's declaration of 'climate change emergency' mean for planning? An article by PlanningResource tackles that very question, and quotes Ben Kite, managing director of environmental consultancy EPR, who argues:
What it hopefully does is create an expectation both within an authority and externally that those policies that are already in place and relate to climate change will have an elevated priority. So, if a planning decision is being made or something goes to appeal, those policies will carry a bit more weight.
For example, with DCC declaring a climate emergency you would hope the council might be slightly less eager to dismiss Objective 1 of the Devon Minerals Plan – see below – encapsulated in policies M1, M20 and M22, when it finally determines Aggregate Industries’ planning application to quarry Straitgate Farm and haul the as-dug material a total of 2.5 million miles for processing:
Within geological constraints, secure a spatial pattern of mineral development that delivers the essential resources to markets within and outside Devon while minimising transportation by road and generation of greenhouse gases, supporting the development of its economy while conserving and enhancing the County’s key environmental assets.

“Time’s up for a golden age of corporate greenwashing”

... runs a headline in the Financial Times of all places. It’s a warning to companies such as Aggregate Industries and parent LafargeHolcim, masters of greenwash, experts in speaking fine words about climate change, but in reality doing very little about it.

We’ve posted enough times on this blog about AI’s abysmal record on reducing its CO2 emissions, in direct contrast to the nonsense it publicly spouts. We’ve posted that If AI’s record is an example of corporate action on climate change, we’re all screwed and how AI now emits nearly 1.3 million tonnes of CO2 each year – more than 3x the amount it did in 2006, and 5x the amount it did in 1999, but tells the world:

We’ve also posted about LafargeHolcim: how LafargeHolcim has a way with numbers – CO2 emission numbers; how it claims to be "at the forefront of efforts to mitigate climate change", and yet total net CO2 emissions have continued to increase in 2018, as they did in 2017 and 2016, but nevertheless tells people:

As the FT article says:
Too many still profess to care about the climate, especially those in industries struggling to impress concerned investors and consumers, or hire bright young recruits, yet fail to match the scale of their rhetoric with action.
Aggregate Industries and LafargeHolcim would certainly be on that list. But "Time’s up for a golden age of corporate greenwashing", says the article, pointing to the unusual but notable statement by one CEO, who says people should avoid buying his company’s products. Virgin Group's Josh Bayliss warns:
It’s definitely true that right now every one of us should think hard about whether or not we need to take a flight.
In a warning to polluters like AI – the author of the FT article reckons the climate debate is shifting:
I am willing to bet that companies failing to match their green claims with solid action face far greater risks than they ever have before.
Business Green – where the Josh Bayliss story first appeared – says the "pressure on brands to prove their environmental credentials has ratcheted up several notches since the start of the year":
There has scarcely been a more a precarious time to operate a globally recognisable brand. Consumer awareness of ethical and environmental issues is higher than ever, bringing with it far loftier expectations for the products and services people spend their money on.
About time.

Sunday, 19 May 2019

Ottery’s new mayor

Hearty congratulations are due. One of Ottery St Mary's longest standing councillors and 'servant' of the town has been elected as mayor, reports the Sidmouth Herald.

The new Mayor of Ottery St Mary, Cllr Roger Giles was elected as he has a wealth of experience having been a Councillor of the Town Council since 1991. He has also been a member of Devon County Council for Ottery Rural from 1993 to 2013 and a member of East Devon District Council Ottery Town from 1995 to 2019.
Over and above everything else Roger has done for the community, he has for very many years – long before 2012, when he wrote the article below – also been a vociferous campaigner against a quarry at Straitgate Farm. Roger also served on DCC’s Development Management Committee for many years – a committee responsible for determining mineral planning applications. He therefore knows unsustainable development when he sees it.

What Roger wrote in 2012 is just as applicable today – 7 years on, with no sign of Aggregate Industries having dealt with multiple outstanding constraints including on groundwater and flooding – as it was then:
Bizarrely DCC wants to see a new quarry opened at Straitgate Farm on prime farming land, in attractive countryside, when there is an existing quarry at Hillhead, near Uffculme, with sand and gravel resources that could meet Devon's needs for many decades to come.
DCC admits that there are “significant constraints” to quarrying at Straitgate. In addition to the noise and dust problems that would be caused to nearby residents, DCC refers to “the underlying water table and consequent impacts on private water supplies and nearby wildlife sites” as being significant constraints.
The underlying water table meets the drinking water needs of something like 100 people. That drinking water source might well be lost.
The “nearby wildlife sites” are Cadhay Bog and Cadhay Wood. They have both been designated as County Wildlife Sites containing ancient woodland which are dependent on receiving a regular supply of water from the Straitgate Farm area. Quarrying at Straitgate would almost certainly result in intermittent flows of water causing Cadhay Bog and Cadhay Wood to dry out and be damaged.
Even more worrying is the impact on flood risk in Ottery. The water table at Straitgate Farm is the source of the Thorne Farm Stream, which caused such devastation on much of western Ottery in October 2008. It is also the source of two other streams which caused flooding at Cadhay and Coombelake on the same night.
The likelihood of quarrying at Straitgate is that the present “sponge effect” - gradual absorption and gradual release of rainwater, would be replaced by sudden run-off (and dry spells). It is quite incomprehensible to me that DCC can be so reckless as to press ahead with quarrying at Straitgate Farm when the devastation on the Thorne Farm estate and elsewhere is such a stark and recent memory.
Quite why DCC is considering quarrying at Straitgate, when there is no need, and where there are so many significant constraints is something that you may wish to ask DCC.