Sunday, 31 July 2016

No prizes for guessing which company is behind this headline

"Corporate influence has trumped the protection of marine wildlife here, with local planners and now the Scottish Government giving in time and time again to the Glensanda super-quarry operators"
The MPA was meant to help conserve the common skate, an ancient and highly endangered fish known as the "giant panda of the sea".

It's good to see Aggregate Industries taking a proactive approach in protecting biodiversity:

Thursday, 28 July 2016

"A single woodland nut...

...chewed by a dormouse, had a central part to play in a High Court dispute over a controversial housing development in South Devon", ran a story in the Plymouth Herald and PlanningResource this week.

It is simply staggering that at the Blackhill / Venn Ottery Quarry Liaison Meeting earlier this week, a representative from Aggregate Industries was merrily talking about wanting to start earthworks at Straitgate Farm in the Spring/Summer of next year - start grubbing up 2km of ancient hedgerows - when virtually no appropriate mitigation planting is in place - for a species protected by European law; for a species on the brink of extinction.


At the same meeting, another AI representative claimed that applications to work Straitgate Farm and extend Blackhill for another 5 years were still "likely to be resubmitted" - but that was some months away yet; slightly different timing from what the company was previously saying. He also claimed that if Blackhill wasn't permitted, the company would seek to truck Straitgate material 23 miles to Hillhead - not Rockbeare - for processing; some 2.5 million miles in total; something the company had previously said "may be feasible, but would generate a massively greater quantity of CO2 emissions" 8.48; something obviously at odds with how environmentally-friendly the company says it is:

And what of Penslade near Uffculme? Well, apparently:
Penslade is 10-12 years away - we're not even thinking about that yet
Which is a strange thing for AI to say, because Straitgate has little over 3 years' worth of material - even if the company could win 1.2 million tonnes above the water table. Or is staying above the water table not what AI intends at all?

Thursday, 21 July 2016

DCC approves scheme to haul sand & gravel 74,000 miles to be processed in AONB

In terms of minerals applications, you could hardly come across a more ludicrous, unsustainable proposition with Aggregate Industries' Houndaller / Blackhill planning application - hauling 1400 loads of as-dug sand and gravel 26 miles to be processed in an AONB; 74,000 HGV miles in total.

How Planning Officers came to recommend this application - can be found here.

How six Conservative Councillors on the DMC came to approve this application (three Councillors voted against, four Councillors abstained) - can be found here.

Cllr Christine Channon was one who spoke passionately against it, and asked the the Committee "Are you really convinced that there are exceptional circumstances" to allow major development in an AONB?

Of course, there are no exceptional circumstances, but curiously, despite government guidance to the contrary, the officer’s report questions whether 40,000 tonnes is indeed major development:
Although Government guidance categorises all mineral development as “major”, it is questionable whether the temporary continuation of the status quo is truly a major development in terms of its impact.
Let’s remind ourselves that there are just 5 months left before processing is due to cease at Blackhill on Woodbury Common; operations should be scaling down. Let’s also remind ourselves exactly how many times DCC has now permitted extensions to operations at the plant, since modification orders were served in 1999 to restrict workings at Blackhill and millions were paid to AI in compensation:
2002 Permission granted to quarry Thorn Tree Plantation at Blackhill
2008 Permission granted to process Marshbroadmoor material at Blackhill
2011 Permission granted to process Venn Ottery material at Blackhill
2016 Permission granted to process Hillhead material at Blackhill
So, 17 years on, with DCC’s track record, when exactly will operations at Blackhill cease? When will the East Devon Pebblebed Heaths be restored for the benefit of nature and people? When will DCC finally make a stand against a multinational cement conglomerate?

Thursday, 14 July 2016

Has AI finally given up on Rockbeare?

Those who have been following the East Devon minerals debacle for some time might remember that as recently as 2014 Aggregate Industries was saying that the derelict concrete products plant at Rockbeare was being set aside as an alternative location to process any material from Straitgate.

Since that time, and although sand and gravel was once processed at Rockbeare, AI has claimed that the site is no longer suitable for processing on a number of fronts - lack of space for stockpiles and silt storage, lack of process water, even great crested newts.

However, at the Examination in Public in May, when pushed on the issue by the Inspector, AI said it "wouldn’t wish to rule out the site" and would "look again" at Rockbeare if permission for Blackhill on Woodbury Common was not extended beyond 2016.

And yet, only a month later, a planning application - which had obviously been in preparation for some time - landed on the desk of East Devon District Council from Waycon Precast Ltd, who wish to relocate from Plymouth and lease the site from AI: "16/1464/MFUL Replacement of existing manufacturing building with new factory building for precast concrete manufacturing".

How this would help AI "look again" at the site is unclear. How this would help AI "to find an alternative solution for when [Blackhill's] permission expires" is also unclear.

Or has AI finally given up on Rockbeare?

AI's scheme to haul material over 50 miles for processing in AONB rec'd for approval

What hope is there if completely unsustainable schemes, such as the one put forward by Aggregate Industries to transport material from Hillhead to Blackhill for processing (when mobile plant could have been deployed on site), get recommended for approval? 

More to the point, what hope is there for the climate or air pollution if planners back schemes where HGVs loaded with as-dug sand and gravel are required to make round trips of over 50 miles - just for processing - before any onward distribution? And where’s the corporate responsibility? It obviously means nothing when AI says:
We have long recognised the consequences of CO2 emissions and how both the manufacture of our products and their use in the built environment contribute to climate change... there is a real focus and drive to minimise the environmental impact of all we do.
But it’s not just the 52 miles for each round-trip. Under the Town and Country Planning Act, "the winning and working of minerals or the use of land for mineral-working deposits" is classed as "major development". This proposal is therefore major development in an AONB, and clearly there is public interest in protecting AONBs. The NPPF says:

Where’s the "Great weight" and "except in exceptional circumstances and where it can be demonstrated they are in the public interest" in the 'planning balance'? There are obviously no exceptional circumstances; AI's argument that the material is needed for Blackhill's restoration falls down when you consider that the 6,000 tonnes of silt generated would contribute a negligible 1.4% to the void that supposedly needs filling.

On the issue of importing nutrient-rich material, Natural England has now withdrawn their previous objection to the proposal:
On the basis of the further information supplied in the new technical note submitted with this consultation, Natural England advises that overall, we are satisfied that the proposed activity does not represent a significant risk over and above how the quarry has operated to date.
But it’s perhaps telling that Natural England also says:
Finally, it should be noted that the advice contained in this response relates to the specific set of circumstances detailed in this application and associated documents. Therefore such advice may not be appropriate in a different set of circumstances and all applications we are consulted on are assessed on their individual merits.
Indicating that whilst 40,000 tonnes might not represent a significant risk, '1.2 million tonnes' from an intensive dairy farm is another story.

The application, DCC/3816/2015, will be decided at the DMC meeting next Wednesday 20 July 2pm. The Officer's report says:
1.3 It is considered that the main material issues in the consideration of this application are whether the nature of the imported material would have significant environmental effects on the adjacent protected sites, the impact of the development on the Area of Outstanding Natural Beauty (AONB) having regard to whether the proposal is a “major” development, and the traffic and sustainability implications of hauling material to Blackhill Quarry from Houndaller (Hillhead) at Uffculme.
6.6 A number of representations have made reference to Paragraph 116 of the National Planning Policy Framework... Although Government guidance categorises all mineral development as “major”, it is questionable whether the temporary continuation of the status quo is truly a major development in terms of its impact.
7.4 A recent appeal decision in Devon has indicated that the Planning Inspectorate tend to take “major” to be a dictionary definition and whilst it is doubtful whether the “exceptional circumstances” statement provided by the applicant would have been sufficient to have supported a proposal with any greater impact, there would be no increase in the impact on the AONB from the current proposal and no extension to the life of the site. Both AONB/Landscape considerations and the continuation of the supply of minerals carry “great weight” in the NPPF but the presumption against mineral extraction in AONB’s is unclear about the weight to be given to ancillary operations which are already in existence.
The "recent appeal decision in Devon" referred to? A small scale farm-based AD facility that "would involve no more than 2 vehicles per day"; not the 88 HGV movements per day for this scheme.

The report concludes:
7.6 The very short term nature of the proposal, the fact that it would not extend the life of the Blackhill processing plant beyond the end of 2016 and would not lead to traffic levels above those already permitted, would suggest that the proposal would not have any significant adverse impact on the locality. It is therefore recommended that permission should be granted to vary the source of materials until the expiration of the current permission in December 2016 to give the applicant the time to find an alternative solution for when this permission expires.
The last line at least indicates that whilst officers recommend this application for approval, Aggregate Industries should clearly be looking for a new plant outside of the East Devon AONB from 2017 onwards.

DCC puts a line through the 1m - another round of consultation begins next month

DCC has tabled a modification to the draft Minerals Plan in an effort to make the allocated resource at Straitgate consistent with the depth of any future quarrying:
reference in Table C.4 to the depth of unsaturated zone above the water table to be maintained at Straitgate Farm has been altered to enable consideration of the appropriate depth through further investigation and discussion with the Environment Agency... 3.3
As referred to in the previous post, the Environment Agency recently commented that:
the applicant appears to be basing the present resource assessments on the basis of a hydrogeological model (highest water level) that has not been formally agreed.
We are... still waiting for a robust assessment of the risks that would result from this modification to the operation.
DCC has not, however, revised the resource down from 1.2 million to 900,000 tonnes to accommodate this, as the Council stated it would in April:
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”. 
DCC has instead, surprise, surprise, sided with the mineral operator again, and put a line through the 1m standoff from the maximum water table level intended to protect water supplies:
The development of this site will only involve dry working, above the maximum winter (wet) level of groundwater with an unsaturated zone of at least 1m maintained across the site. The depth of working above this level will be determined through monitoring and analysis of historic data, in agreement with the Environment Agency. MM58 Table C.4
This change has been made despite the 1m being stipulated by the EA:
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.
Anyone with water supplies around Straitgate Farm must be getting increasingly nervous at the way DCC continually backtracks. It is standard to leave at least 1 metre where private water supplies are at risk - for very good reason; even more so when over 100 people rely on the area for their drinking water.

DCC propose holding a consultation on the main and additional modifications for the draft Minerals Plan for a period of eight weeks from Monday 1 August 2016:
Following close of the consultation, all representations received will be forwarded to the inspector for his consideration prior to publication of his report. 5.2