Monday, 31 October 2016

Hillhead ROMP

Planning conditions for quarries are meant to be reviewed every 15 years to ensure that they comply with current environmental standards; the process is called a Review of Old Mineral Permissions or ROMP. To this end, Aggregate Industries submitted a ROMP application for the Hillhead complex at Uffculme in 2014. Following a request by DCC for an Environmental Statement, application DCC/3655/2014 was finally validated last week and is open for consultation until 24 November. The Supporting Statement from consultants David Jarvis Associates can be found below.

Hillhead (or more precisely the Houndaller part of it) is where the bulk of Devon’s permitted sand and gravel reserves lie - some 4.23 million tonnes. Some of this will be heading for Blackhill, before permission for processing there expires on 31 December 2016: DCC approves scheme to haul sand and gravel 74,000 miles to be processed in AONB.

Permission for extraction at Houndaller was due to expire at the end of 2018; DCC saw that as "Potential constraints on the maintenance of the sand and gravel landbank..." 2.5.6.

AI obviously doesn't want to lose those reserves. In September 2014, David Jarvis said "The applicant proposes to extend the timeframe for development under condition B1 from 31st December 2018 to 31st December 2033" 3.3. Two years on, AI apparently needs even more time, and now "The applicant proposes to extend the timeframe for development under condition B1 from 31st December 2018 to the 21st February 2042" 5.4.

So in 2014 when "The applicant considers that the extension of the timeframe for mineral extraction in the Houndaller Extension by 15 years is appropriate in this instance, due to the volume of mineral remaining on the site and the potential rate of extraction", in 2016 it's now "The applicant considers that the extension of the timeframe for mineral extraction in the Houndaller Extension to coincide with the development timeframe with operations over the rest of the Hillhead mineral site is appropriate in this instance, based on the volume of mineral remaining on the site and the potential rate of extraction".

How will Houndaller be worked?
AIUK intends to continue operations broadly in accordance with the previously permitted working scheme, restoration scheme and conditions attached to permission ref. 4/06/53/98/1487. Sand and gravel will continue to be extracted at the working face by hydraulic excavator and will be transported to the mobile processing plant by dump trucks travelling on internal haul roads, only crossing Clay Lane to access the mobile processing plant area. The mobile processing plant will be located to the north of the plant area (below Viridor’s weighbridge offices). Returned water from Pit C will be used in the mobile plant until such time as it is at full silt capacity. Ponds 7 and 9 will be used for water thereafter. 5.1
Is there anything of note for people living around Straitgate Farm? Well, just the usual disrespect of Planning Conditions that we’ve come to expect:
Following a monitoring visit in April 2016, it was noted in a letter dated the 11 July 2016 by Planning Officers from Devon County Council that the Houndaller Extension was not being worked in accordance with Condition B2 and B6 of ROMP permission 4/06/53/98/1487. The requirements of these conditions relate to the order of development in defined phases and approved plans. 5.15
People living around Straitgate worried that AI won’t even leave 1m of unsaturated material unquarried to protect drinking water supplies might also find the bit on groundwater interesting… the bit that starts:
Throughout the lifetime of the development, some 2 m thickness of unsaturated material will be retained beneath the quarry floor…" 7.77

LAA LAA LAA LAA LAA - who can keep track of the changes?

The NPPF introduced a requirement for mineral planning authorities to prepare annual Local Aggregate Assessments. By August 2016, DCC had produced its 5th Devon LAA 2006-2015. This document is currently at version 2. How many more versions there might be or when they will be issued is unknown. The LAA is obviously not a document that DCC wants the public to read or keep up with; nobody, other than the author, will be able to keep track of what changes between each version or each edition.

And changes do creep in. Take the Second Draft of the 4th Devon LAA 2005-2014 released in December 2015. This is what it said on the issue of gravel:

We posted some comments in Cozy relationships: We said
Take one look at DCC’s 4th Local Aggregates Assessment published late last year. Some of its conclusions are supported by references. When one of those references - backing the flawed argument for both 'southern' and 'northern' sites because the "proportion and size of gravel decreases from south to north" 2.5.4 - is taken from AI’s own undetermined-catalogue-of-errors planning application for Straitgate, you know you're in trouble.
We’ve already dealt with the issue of Gravel at Hillhead, and the fact that this didn’t stop Hillhead Quarry operating for decades, the fact that this doesn’t stop Hanson working Town Farm Quarry near Burlescombe, the fact that this won't stop AI from applying to quarry Penslade if its application for Straitgate founders, and the fact that this hasn't stopped DCC from relying on Penslade to cover the sand and gravel shortfall indicated in its Minerals Plan.
Indeed, one of the planning applications DCC received last year was the "variation of existing permission at Blackhill Quarry to allow for importation of sand and gravel from Houndaller (Hillhead) Quarry for processing to end of 2016 (awaiting validation)" 2.5.7.
But some people in DCC gave up listening to anybody other than the quarrying industry years ago. Consultation with the public has been a charade. In reality, Devon’s new Minerals Plan has been shaped by the minerals industry, for the minerals industry. Silly of us for thinking it could be any other way.
But how wrong we were. Some people were listening. Because by the Fourth Draft of the 4th Devon LAA 2005-2014, published shortly after our post, we find the reference to that undetermined-catalogue-of-errors planning application for Straitgate has gone, and a Table 5 inserted:

DCC is of course getting carried away with itself because, however much the Council might have prejudged matters, Straitgate Farm and Penslade are not, as Table 5 says, Pebble Bed Quarries. Furthermore, the percentage figures will still have been supplied by AI, and we know by now that numbers are not the company's strong point.

Nevertheless, the Hillhead ROMP application plainly indicates that AI is unwilling to see the Houndaller permission expire, and apparently sees merit in working the reserve - whatever DCC says about "the very low proportion of crushable gravel at Houndaller".

Wednesday, 26 October 2016

Safer HGVs to be deployed in Cambridge

After the posts 'Banning HGVs is likely to negatively impact road safety' and Safer Trucks, positive news from one operator:
The safety of our staff, communities, clients, contractors and the people we work alongside is of utmost importance to Mick George. The introduction of these Econic chassis further underlines our determination to minimize the risk to vulnerable road users. The enhanced field of vision which this vehicle offers will be a real advantage to our drivers when navigating through cities or in complex situations, while its two-step low entry minimizes the possibility of injury when accessing the cab.
Vulnerable road users welcomed the recent decision by the Mayor of London:
There are around 35,000 of the zero star-rated ‘off-road’ HGVs currently operating on London’s roads, and they were involved in around 70 per cent of cyclist fatalities involving HGVs in the last three years. It is this type of vehicles the Mayor has pledged to remove from London’s roads by 2020.
But the MPA, the trade association and lobbying body for the aggregates, asphalt, cement, concrete industry still doesn't get it. It continues to tweet like a broken record, whilst the fatalities continue.


It’s important to know who we’re up against. Aggregate Industries relied on consultants SLR for its last planning application for Straitgate. It didn’t go well. That application was characterised by a catalogue of errors, omissions and fabrications, such as this and this and this and this and this and this and this.

SLR’s been off the scene for some time now. Perhaps they were pushed? Perhaps they didn’t want the work anymore? Whilst AI obviously doesn’t mind having its dirty washing hung out online for all to see, perhaps it was too much for SLR?

If SLR doesn't return, the next application could see AI team up with David Jarvis Associates again. They've not only worked with AI on Venn Ottery and Blackhill, but claim to have "worked on over 285 quarries worldwide". They part authored a Quarry Design Handbook, required reading surely for anybody thinking of digging a large hole in the East Devon countryside. If AI had followed this guidance last time, it might have avoided some of the problems with site access:
… from the outset, it is necessary to establish who owns or controls the surface of the land within the proposed site boundary (including buildings, structures, uses or rights). No assumptions should be made and all documentation checked and verified… Ownership, and/or control (e.g. a lease or public land allocation or contract) needs to be established for ALL of the land which may be required for the proposed quarry operation including, for example, the mineral extraction area, access roads… 2.3
Local people might find pages 121-125 on public consultation interesting, the bit about "Engagement with people at a local level can bring the following benefits..." etc. It will be interesting to see what sort of job these experts make of Straitgate; interesting to see how much of that Quarry Handbook gets deployed.

In the meantime, Amec Foster Wheeler continues to be retained on groundwater matters, and continues to collect groundwater data from 13 boreholes across the area. Amazingly, this has now been going on for almost 4 years; read into that what you will.

It’s anybody’s guess how much money AI has sunk into the Straitgate project so far. Quarry companies worldwide would surely like to know what financial magic AI uses to make the numbers stack up - with less than 1 million tonnes of sand and gravel and a 50 mile round trip for processingBut then all miners start with rosy outlooks - just look at Wolf Minerals, and the problems it’s now having with its tungsten mine near Plymouth.

Friday, 21 October 2016

AI hasn't thought about school children either

Birdcage Lane is the location Aggregate Industries proposes to access any quarry at Straitgate Farm. Early plans have indicated this narrow lane being opened up for two-way 44-tonne HGVs - similar to the ones in the photograph below - but without provision for pedestrians: joggers, dog walkers, ramblers and the like; thoughtless when there are so many public footpaths around.

But the junction at Birdcage Lane and Toadpit Lane is also used by school buses for King’s and Colyton every morning and afternoon to pick up and drop off school children. This has been the case for at least the last 10 years. It is our understanding that Stagecoach also uses the junction for stops on request. 

Perhaps it’s not looking like the safest place to site an 'up to 200-a-day' HGV hub after all.

Thursday, 20 October 2016

The absurdity is... Straitgate was never needed for the Minerals Plan

The absurdity of allocating Straitgate Farm in the Devon Minerals Plan is clear for all to see - when 1) you consider that there’s less than a million tonnes of resource at Straitgate (if drinking water supplies are to be protected in line with the Environment Agency’s advice) - and 2) you consider item 56 in the Inspector’s report:
To meet the anticipated shortfall, the Plan identifies two new potential areas of production. These are known as Straitgate Farm and West of Penslade Cross. Potentially, some 9.2 million tonnes would be available from these two sites. I appreciate that this figure is in excess of the requisite 7.7 million tonnes; also that a possible contribution would come from prior extraction. However, a degree of flexibility would be appropriate. I do not find that the provision would be excessive.
In other words - in a Plan running to 2033, a Plan that should be looking towards more sustainable secondary and recycled building materials, a Plan for a county where sand and gravel production has been in decline for the last 25 years - DCC has needlessly allocated an additional 1.5 million tonnes of sand and gravel; more than the total available at Straitgate Farm.

If that's not bad enough, then let's consider sustainability and the fact that Aggregate Industries is now talking about a 50 mile round-trip for each load of as-dug material from Straitgate, taking it all the way to Uffculme for processing; to the area next to Penslade Cross, to the area where the majority of the sand and gravel resource in the Minerals Plan is allocated. Sounds like madness, doesn't it?

Now consider the job of the independent Inspector, as detailed in paragraph 182 of the NPPF:
The Local Plan will be examined by an independent inspector whose role is to assess whether the plan … is sound… namely that it is:
Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
How Straitgate, with all its constraints, all its problems with processing and access, could be deemed the most appropriate strategy is unfathomable; laughable.

With hundreds and hundreds of consultation responses comprehensively ignored over the last four years, Aggregate Industries and the other mineral companies may as well have written the Plan themselves.

Monday, 17 October 2016

Inspector endorses Straitgate as a Preferred Area - but what about processing?

In the end, what was the point? All the representations - except from the mineral companies of course - made no difference at all. The Inspector has issued his Report on the Examination into the Devon Minerals Plan, and says:
I conclude that, with the recommended main modifications set out in the Appendix, the Devon Minerals Local Plan satisfies the requirements of Section 20(5) of the 2004 Act and meets the criteria for soundness in the National Planning Policy Framework. 111
So, three cheers for the Minerals Officer. Well done. After years of delay, years of not listening, years of expense, he can finally report:
County Councillors will be recommended to adopt the Devon Minerals Plan in accordance with the Inspector’s recommendations shortly.
But it's a farce. The Inspector has endorsed Straitgate Farm as a Preferred Area, "areas of known resources where planning permission might reasonably be anticipated", without knowing how the site would be accessed or where the material would be processed.

On access, he says: "It is proposed to gain access to the area off the B3174 Exeter Road at or close to the track serving Little Straitgate" 67 - but that idea has already been junked on safety grounds; so much for his report saying "I see no reason in principle why a safe access could not be constructed" 68.

On processing, he says: "Rockbeare Hill Quarry is favoured by the Council. The prospective developer states that there are a number of problems including water availability and the capacity of the silt beds. Nevertheless, it is an option that could be explored if Blackhill Quarry could not be used. 4" 71. However, if the Inspector had checked the apparent planning permission referenced in footnote 4, below, he might have been forced to conclude differently.
4Availability at Rockbeare Hill Quarry would also need to be determined in the light of an apparent planning permission for a building for precast concrete manufacturing (see representations 51/MM32/U, 33/U and 57/U).
The apparent planning permission was the one approved by EDDC on 19 September 2016, the one detailed in our representation ref 51/MM32/U etc:
... despite AI saying at the Examination hearings that the company would “look again” at Rockbeare if needed, the site was subject to a planning application from a third party shortly afterwards, “16/1464/MFUL Replacement of existing manufacturing building with new factory building for precast concrete manufacturing”, which was approved by East Devon District Council on 19 September 2016.
So, if the Inspector thinks "To my mind, the position at Blackhill Quarry is protected by the terms of the Devon Minerals Plan" 72, and if Rockbeare is not actually "an option that could be explored", where does he think the material could be processed?

Because if it was all so very easy, all so very where planning permission might reasonably be anticipated, why is Aggregate Industries and its merry band of consultants still scrabbling around after all these years, still trying to cobble together a cogent planning application?

Cllr Claire Wright's blog on the subject can be read here.

Birdcage Walk

At the start of all this, that was the name that Aggregate Industries' experts SLR mistakenly called Birdcage Lane. But maybe they were onto something, because that’s what the Ramblers call the circular walking route, here and here, that incorporates Birdcage Lane; the narrow lane now proposed by AI to access any quarry at Straitgate Farm.

We recently reported that plans for this new site access had made provision for two-way 44-tonne HGVs, but none for pedestrians. This was surprising given the number of footpaths that lead onto this lane; a lane also widely used by cyclists, horse-riders, joggers and dog walkers.

But it’s clear, here and below, that's it not just Ramblers who use Birdcage Lane as part of a circular walk:

This long but pleasant walk initially following Toadpit Lane & Birdcage Lane offers many beautiful views and takes you along the tranquil banks of the Otter. At Birdcage you follow an ancient perhaps pre-Roman track with spectacular views of Hembury Castle .
What a shock walkers on this quiet country lane would get if a 44-tonne aggregates HGV suddenly bore down on them - if there were no pedestrian provision. Really, what was AI thinking?

Because, as LafargeHolcim say themselves, in two simple words: Pedestrians First.

Saturday, 15 October 2016

Safer Trucks

All the world and his dog welcomed the decision by the Mayor of London to ban 35,000 HGVs with the worst driver visibility from London by 2020; we posted something on the subject last week.

HGVs make up less than four per cent of the miles driven in London, but were involved in 78 per cent of cyclist fatalities and 20 per cent of pedestrian fatalities in 2015.
They have produced a video and infographic:

Despite the statistics, despite the casualties, despite the evidence, the Mineral Products Association - the trade association acting on behalf of Aggregate Industries et al. that claims that "MPA members are absolutely committed to improving road safety for all vulnerable road users... This is not just talk..." - has already begun lobbying furiously against the changes, bizarrely complaining that banning the most dangerous HGVs - the ones with the worst driver visibility - would hinder road safety, complaining that:
We are very disappointed that the Mayor has unilaterally decided to ban 35,000 HGVs without any obvious discussion with industry on the implications of his decision.
In fact, the MPA is so disappointed - so disappointed that its multinational friends will have to spend some money and introduce HGVs with better visibility cabs helping both drivers and vulnerable road users - that this is how many times they've tweeted the @MayorofLondon since the news broke:

Thursday, 13 October 2016

Tarmac work leaves homes without clean water for five weeks

More than 100 people wholly rely on the Straitgate Farm site, through wells and springs, for their drinking water. They have voiced their concerns to DCC many many times over the years. Their concerns have fallen on deaf ears - most recently demonstrated by DCC removing from the Devon Minerals Plan the 1m buffer above the maximum water table that was intended to protect private water supplies.

If we dispute that the derogation is caused by our working we may, once we have restored your water supply, have the matter referred to an independent arbitrator...
... if it is ultimately found that the cause of the derogation to your supply was not our workings, then it will lie with the arbitrator to require you to reimburse us the expenditure we have incurred in restoring your supply and the costs of the arbitration.
Anyone thinking that the concerns of those using the wells and springs around Straitgate are misguided, wells and springs that have given uninterrupted supply for centuries, should read this article:
People living in a small rural community on the outskirts of [Edinburgh] have been left without clean drinking water and struggling to wash for the past five weeks after their water supply was cut off by a multinational construction company.
The private water supply to five homes along Edinburgh’s Long Dalmahoy Road, between Balerno and Kirknewton, is controlled by Tarmac, which operates the nearby Ravelrig quarry.
Local residents, who range in age from two to 78 years old, have had to endure days at a time without washing and flushing toilets and have been forced to buy in gallons of bottled water for drinking and cooking.
Now they say enough is enough and immediate action must be taken to restore a basic human right.
... neighbours are angry that Tarmac – which is required under planning conditions to "take all necessary precautions to ensure that a continuous and sufficient supply of potable water is available at all times to those premises" – is not doing enough to resolve the situation.
"We are being bullied and ignored by a big PLC business that controls one of our basic rights – to have fresh water. “Without water, normal life quickly grinds to a halt."
What does Tarmac say?
"We are working hard to identify whether the source of this issue is within the boundaries of our site or at the properties themselves, to ensure we resolve the problem as quickly as possible."
Which sounds very much like they are working hard to determine if blame can be shifted elsewhere. 

Who wouldn't be concerned that, judging by what's already been said, AI wouldn't act just the same?

Venn Ottery

Aggregate Industries' planning application to alter the working and restoration of Venn Ottery Quarry DCC/3861/2016 will be determined at the DMC meeting on Wednesday 19th October 2016 at 2.00 pm.

As the Officer’s report says, the application arose because - and we know how hard it is for AI to stick to planning conditions - "the site has been quarried in a slightly different way to that which was approved".

A number of objections - along the lines of "Nothing more than a sinister attempt..." etc - were received by DCC "on the belief that the application would extend the life of the quarrying operations", particularly in relation to Blackhill where the permission to process the Venn Ottery material expires on 31 December 2016. The belief came about because of what AI initially said, as the Officer's report details:
The application states that mineral extraction will be completed by 1 April 2017, but the applicant has now confirmed that the extraction operations at the quarry will finish by 31 December 2016 which ties in with the required cessation of mineral processing at Blackhill.
But if quarrying at Venn Ottery is to finish by 31 December 2016, objectors will surely be confused when they read DCC's first Planning Condition:

Tuesday, 11 October 2016

The Paris Agreement

Paul Polman has made big changes at Unilever since taking over in 2009. Unlike other CEOs, he not only thinks about the issues of climate change and sustainability, but actively campaigns on them too.

Only sustainable infrastructure - one that refuses to trade long-term sustainability for short-term gains - will bring about the transformative change we need. It is key to our ability to deliver the promises of prosperity and sustainability at the heart of the Sustainable Development Goals (SDGs). And to our ability to realise the Paris Agreement on climate change, whose rapid entry into force this week is proof of our collective ambition to further limit global warming and preserve our future.
What he said obviously resonated with somebody at LafargeHolcim, Aggregate Industries' parent:

Of course, given that manufacturing 1 tonne of cement produces nearly 1 tonne of CO2, given that the cement industry alone is responsible for 5% of man-made CO2 emissions, LafargeHolcims’s idea of sustainability - being the world’s largest cement producer - is probably a bit different to Unilever’s.

But what a relief someone at LafargeHolcim is interested in sustainability. Because, once the Paris Agreement on climate change formally comes into force next month, no business in its right mind, no business that wants to be "part of the solution", would think to needlessly haul minerals 2.5 million polluting miles in Devon, would they?

Friday, 7 October 2016

How does a 100 acre quarrying carbuncle fit with EDDC’s newly adopted Local Plan?

There are obviously many reasons why East Devon District Council is so against any quarrying at Straitgate Farm, at the gateway entrance to Ottery St Mary, but this week a reader reminded us of what the newly adopted East Devon Local Plan has to say on measures to enhance the town, such as:
h) Promoting measures to reduce potential future flooding and avoid development on the extensive flood zones to the West and North of the town
i) Enhancing the visual appearance of the Western side of the town, recognising its importance as a 'gateway entrance' to Ottery St Mary 12.5
On the latter, as the reader points out:
Interested how they’re going to deliver on that commitment with a quarry and associated traffic in EXACTLY the area they’ve promised to enhance!

Thursday, 6 October 2016

'Banning HGVs is likely to negatively impact road safety'

That's the bizarre argument dreamt up by the Mineral Products Association, in response to Sadiq Khan's plan to ban 35,000 HGVs from London to make the roads safer for pedestrians and cyclists.
In the past two years HGVs were involved in 23% of pedestrian fatalities and 58% of cyclist deaths in London, despite accounting for just 4% of the miles driven in the city

You couldn't make this stuff up; some people really have been staring at minerals too long. 'Banning HGVs could hinder road safety' - it's amazing what some trade associations will say.

Wednesday, 5 October 2016

Provision for two-way 44-tonne HGVs, but where do pedestrians fit in?

Following the Hi-vis jackets out in force meeting in August, Aggregate Industries’ access plans for Straitgate now centre on Birdcage Lane, the narrow lane labelled Toadpit Lane in the Street View below:

Although pre-application discussions are still ongoing, DCC has insisted that AI would have to widen this lane from the B3174 junction to the proposed site access to facilitate full two-way movement of HGVs.

But despite the discussions, despite the hi-vis jackets, including the one sent by AI to survey Birdcage Lane at the beginning of September, despite the Public Footpaths located at the Birdcage Lane junction, no-one has so far made any allowance for pedestrians. No doubt it suits AI to forget their existence.

Ottery St Mary Footpath 10 from West Hill makes use of Birdcage Lane to connect with Footpath 88 to the north. Footpath 87 along the north side of the B3174 is popular with dog-walkers as part of a 'triangular' circuit encompassing Birdcage Lane.

Why does it matter? Look at Birdcage Lane again. Try to work out how on earth two-way HGV traffic, drainage ditches AND pedestrians could all be accommodated.

Tuesday, 4 October 2016

Dormice make national headlines again

After the news last month - Dormouse numbers halve over last 20 years - this endangered species made national headlines again yesterday, when the UK’s first black dormice was found in Devon.
The discovery was made when staff, trainees and volunteers from the Blackdown Hills Natural Futures project were checking dormouse nest-boxes as part of The National Dormouse Monitoring Programme.
Sadly, Britain’s dormice are under threat of extinction, with changes in the way we manage farmland and woodland making it harder for these delightful little creatures to survive. Dormice need well-managed woodlands connected by hedgerows rich in fruiting plants so that they can spread and prosper. They thrived at a time when we had many more hedgerows, and when hazel trees in woodlands were regularly coppiced providing plenty of nuts for food.
This black dormouse was discovered on farmland which is being managed with nature conservation in mind. The farm’s hedgerows are managed by hand using traditional techniques, bringing great diversity of wildlife including a healthy population of dormice. They are exceptionally rich in wildlife, supporting a wide range of species in addition to a healthy population of dormice.
All the increased publicity will no doubt be welcome for those trying to protect the species; less so for those plotting to decimate 2km of ancient hedgerows and dormouse habitat at Straitgate Farm.

Monday, 3 October 2016

Concerned about Brexit? Well, thank goodness somebody knows what to do…

The Mineral Products Association has identified six areas of priority the Government must incorporate into its response to 'Brexit'...