Tuesday, 28 February 2017

Even access onto Birdcage Lane wouldn’t always be straightforward for AI

The tiny lane that Aggregate Industries wants to put its thundering 44-tonne HGVs down for the next 10-12 years has now been closed for the best part of a week.

One of AI's trees came crashing down across power and phone lines last week.

It wasn't many years ago that another one of AI's trees closed the lane for a similar period, whilst the company cleared up the mess.

And if it's not fallen trees that AI would have to contend with on Birdcage Lane, it would be horse-riders, cyclists, ramblers, joggers, dog-walkers, even sheep:

Discharging silt-laden water into Sussex river cost Interserve Construction £60k

If Aggregate Industries ever won permission to quarry Straitgate Farm, local people should keep an eye on the four watercourses emanating from the site - two of which flow through ancient woodland. This is what happened to one construction company recently:
...the Environment Agency discovered a brown discharge downstream of the site after a member of the public reported seeing discoloured water. Further investigations by the regulator found local damage to the watercourse, a tributary of the River Rother in Burwash, East Sussex.
Giving evidence at Lewes Crown Court, the agency told the judge that this was an isolated incident, lasting just 25 minutes, and the overall performance of Interserve Construction was ‘good’ throughout its 18-month contract with South East Water. The agency said there was no evidence that local wildlife was adversely affected by the discharge.
David Willis, environment manager at the agency, said: ‘We take these incidents very seriously and do everything within our powers to safeguard the environment and people that may be affected.’
Interserve was fined £54,000, with costs of £5,955.
Of course, the costs associated with polluting drinking water sources for over 100 people would be in a different league altogether.

“Years of hard work have gone into preparing and consulting on this important document…”

The press release from DCC continues:
... and it’s pleasing that the Devon Minerals Plan has now been adopted. This extensive work has helped shape the plan we have today. All mineral development will need to comply with the plan, which aims for the county’s minerals to be managed sustainably to support economic growth in Devon and contribute to global supply of key industrial minerals.
But if that really is the case - that all mineral development will need to comply with the plan - why is Aggregate Industries bothering with a planning application for a 2.5 million mile haulage scheme - the details of which are about to land in our inbox?

Grayling: 'have a long, hard think about diesel'

The Transport Secretary is talking about cars, but with the issue of air pollution and its impacts on health increasingly in the headlines, focus is turning to all modes of transport.

As more becomes known about the effects of air pollution, and the number of illnesses and deaths attributed to it, the headlines and calls for action will only increase. One can only speculate what the headlines might look like in 10 years time, and how a planning decision to put 2.5 million HGV diesel-polluting miles on Devon roads would be regarded then.

We should obviously all be making less polluting, more sustainable transport choices - aggregate companies included. Indeed, more aggregate is being transported by rail.

But just as supermarket buyers are considering dropping lines - such as asparagus from Peru - that are environmentally unsustainable, mineral planners should not be supporting plans to transport millions of tonnes of sand and gravel half way across a county for processing purposes alone.

There are thousands of air pollution–related early deaths each year. Whilst Grayling talks cars, a former minister 'urges the government to focus on large commercial vehicles to improve air quality':
Foster cites the recent think tank Respublica’s report: ‘Air Necessities: place-based approaches to a pollution crisis’ as further evidence of the polluting impact of road vehicles, especially HGVs and buses.
“The Respublica report paints a clean picture of the costs incurred by poor air quality, contributing to the unacceptable 40,000 air pollution–related early deaths,” states Foster.
“Something needs to be done now... Despite noises from the government about people choosing their next car with air pollution in mind, they would be better off focussing on the big stuff, namely HGVs and buses,” he continues.
“The report makes it clear that together just 6% of vehicle miles driven by HGVs and buses are responsible for 48% of nitrogen oxides. Whereas with smaller vehicles, 94% of vehicle miles account for only 52% of roadside pollution.”
Foster says that factoring in the fact that HGVs and buses account for less than 2% of vehicles in the UK, the polluting impact of large vehicles is disproportionately extremely high – and hence his plea for a change to government thinking.

'Don’t blame potholes on HGVs', cry the RHA & FTA

After the LGA warned that Pothole levels are likely to surge because of spike in number of heavy lorries, trade bodies RHA and FTA have gone on the offensive.

Well, they would wouldn’t they? The RHA rejects scapegoating of HGVs; the FTA says Lack of investment, not freight transport, to blame for potholes. Both press releases contain an assortment of alternative facts:
Larger lorries do not cause increased damage to the road surface...
Many of our worst roads have little or no HGV traffic while many of the best are used by HGVs all the time. 
...there are an increasing number of 60-tonne lorries operating on continental roads causing very little, if any damage to the road network.
For the LGA to make this sort of statement, instead of discussing the issue with the freight industry, is simply a cheap attempt to make headlines and pass over responsibility for an issue which sits in their remit.
But all this rather goes against a report from the Metropolitan Transport Research Unit entitled "Heavy Goods Vehicles - do they pay for the damage they cause?"
... damage to road surfaces rises extremely rapidly as axle weights increase, broadly in line with the 4th power law. For example, the heaviest HGV axle does over 150,000 times more damage than a typical car axle.
The largest HGVs, including all articulated vehicles and the heaviest rigids, impose high external costs which, even using the DfT 2006 Mode Shift Benefit (MSB) estimates, are not recovered by a very considerable margin... A minimum estimate is that less than 40% of these costs are being charged at present – an underpayment of about £5billion a year...
And the empirical evidence, in this case collected from two very similar bridges in California:
the bridge carrying heavier vehicles clearly and repeatedly required a significantly larger number of repairs over the decades the two were studied...
backs up what, for most people, is simply common sense.

Monday, 20 February 2017

AI's haulage plans could cause the same road damage as 17 billion car movements

The LGA warns that pothole levels across the UK are likely to surge due to a spike in HGV numbers:
The Local Government Association... says chronic government underfunding has left the local roads network facing an "unprecedented crisis" and this new increase in lorries could push the network "over the edge".
Councils are warning 2017 could be a tipping point year for potholes, with the repair bill... projected to rise to £14 billion by around 2019... more than three times councils' entire annual revenue spending on highways and transport...
"Motorists should literally be bracing themselves for a surge in potholes. Our local roads network faces an unprecedented funding crisis and the latest spike in lorries could push our local roads network over the edge. Lorries exert massively more weight on road surfaces than cars, causing them to crumble far quicker.
Road damage rises steeply with axle weight, and is widely acknowledged to be proportional to the fourth power of the axle weight. This means that doubling the axle weight increases road damage 16 times, and in the case of the heaviest (44-tonne) trucks... HGVs are up to 160,000 times more damaging to road surfaces than the smallest vehicles.
Aggregate Industries is wanting to shift 1.5 million tonnes of as-dug sand and gravel from Straitgate Farm to Uffculme. This equates to some 105,260 HGV movements, which - according to the above - could generate the same road wear and tear as up to 17 billion standard car movements. Has AI factored road repairs into its costings yet?

Of course, for Devon County Council, the irony is that - by adopting a Minerals Plan with a Preferred Area for sand and gravel quarrying that can only be processed 23 miles away - this situation is entirely of its own making; a 2.5 million mile own goal.

Record noise nuisance on your phone

The Noise App has been designed to simplify noise reporting and investigation.
Since it was launched in 2015, the app has processed more than 50,000 noise reports and is used by 100-plus organisations including police forces, councils, housing associations and construction companies.
Because it is hassle free, with no expensive or specialist equipment needed, it is popular with residents and the professionals investigating noise problems.
It is another one of the "publicly-funded apps helping to streamline services, save money and make citizens’ lives easier". One council says the Noise App "has revolutionised how we deal with noise nuisance cases". You can understand why. As another council using the Noise App said, in an article describing how a couple were fined £18,000 after complaints about noise:
If a complaint is made to the council, we have a duty to investigate it, and wherever possible we try to resolve the issue amicably.
As we posted in Noise, dust, statutory nuisance, the leaflet produced for Buckfastleigh Town Council - in response to complaints about Whitecleave Quarry - clarifies the law on noise:
Local authorities have a wide range of legal powers to act against noise. They have a duty to deal with any noise they consider to be a ‘statutory nuisance’. You have a right to request monitoring at your property or other location where noise affects you.
There is no specific decibel level or limit to determine nuisance. If it is found to be 'statutory nuisance' the authority must serve an abatement notice – which is an order to deal with the nuisance. This order may demand the noise stops altogether.
A quarry in Cornwall was served such an abatement notice last year. The same article in which this was reported gives examples of How loud is loud?

Thursday, 16 February 2017

Eric Olsen: “Tackling #climatechange requires a shift in the way we do business”

No-one would disagree with this statement from LafargeHolcim's CEO.

But when subsidiary Aggregate Industries thinks it can foist a 2.5 million mile #CO2 polluting haulage plan onto the county of Devon, perhaps he should put his own house in order first.

Industry undertakes

The industry believes that there is an urgent need for a UK Minerals Strategy to ensure medium and long-term demand is supplied to support economic growth and delivery of the Government’s emerging UK Industrial Strategy and the National Infrastructure Delivery Plan.
The industry cannot ensure that objectives are achieved without engagement and understanding from others such as Government, planning authorities and regulatory agencies, environmental NGOs and the wider public to maintain a resilient supply chain for these vital materials.
An action plan has been produced. There's a range of things that industry undertakes to do. Here's one:

Perhaps someone should have told Aggregate Industries that industry undertakes to reduce the need for long distance mineral transport, not plan multi-million mile haulage schemes across Devon.

Monday, 13 February 2017

This is what a haul road looks like

It takes material from the quarry face to the processing plant.

It does not look like Birdcage Lane.
It does not look like Exeter Road.
It does not look like Daisymount Junction
It does not look like the A30.
It does not look like Junction 29.
It does not look like the M5
It does not look like Junction 27.
It does not look like the A38.
It does not look like Clay Lane.

A sand and gravel quarry haul road does not ever look like 46 miles on public roads, for 52,600 round trips over a period of 10-12 years.

Devon’s new Minerals Plan has taken 10 years to prepare, since the first workshop in 2007.

A decade of consultations, delays and public expense - for what?

For Devon County Council to deliver Straitgate Farm as a Preferred Area for sand and gravel quarrying that can only be worked with a 2.5 million mile haulage plan using the above public roads.

If that’s the Council’s idea of Minerals Planning, then Devon would be better off without it.

No-one would want to see a repeat of what happened in Aberdeenshire on Friday: Dad and little girl cheat death after car rammed through wall and mangled beyond recognition by lorry.

After all, we've already had scenes like these - here and here - on local roads in 2016:

Devon Wildlife Trust tweets about Dormice

Friday, 10 February 2017

People can decide for themselves 'if the whole bloody system is functional or bent'

In December, we made a complaint about the Devon Minerals Plan to the Secretary of State for Communities and Local Government, and requested a holding direction. The basis of our complaint was that extensive haulage plans from Straitgate to a processing site beyond the immediate area had at no time been the subject of a Sustainability Appraisal.

A SA is required under Strategic Environmental Assessment Directive 2001/42/EC for each Local Plan proposal. The SEA Directive is to ensure that "an environmental assessment is carried out of certain plans and programmes which are likely to have significant effects on the environment." This directive is transposed into the NPPF, which says that "a sustainability appraisal which meets the requirements of the European Directive on strategic environmental assessment should be an integral part of the plan preparation process, and should consider all the likely significant effects on the environment, economic and social factors."

During the Minerals Plan process, there was a stand-off between operator and council over processing locations. Aggregate Industries insisted it could only process Straitgate Farm material at Blackhill, not Rockbeare; DCC was pushing for the reverse. No alternative processing locations were ever considered.

Natural England’s concerns over importing nitrate-rich material to Blackhill, and the approval of an alternative planning application for Rockbeare, finally confirmed the unavailability of both locations for processing. Despite having been told both of these facts, the Inspector nevertheless concluded:
71. Rockbeare... is an option that could be explored if Blackhill Quarry could not be used.
AI is looking to process Straitgate material at Uffculme, 23 miles away - the only location available to the company. Most normal people would consider a 2.5 million mile haulage scheme to have a significant effect on the environment, yet this was never assessed in the Minerals Plan process by SA or otherwise.

DCC’s SA runs to 100s of pages. We learn that "the purpose of SA is to promote sustainable development by integrating sustainability considerations in to the preparation and adoption of plans."

For Straitgate, we learn things such as:
Straitgate Farm also has nesting House Sparrows and possibly a Schedule 1 bird species - the Barn Owl.
We learn that:
...residency time of carbon dioxide in the atmosphere is 200 years and therefore the impacts will continue to affect the climate for an extended period.
We learn that:
At this site, processing is likely to occur elsewhere which contributes further emissions compared to a site option that has capacity for on-site processing.
What we do NOT learn, however, is that Straitgate Farm - one of DCC's two Preferred Areas for future sand and gravel quarrying - can only be worked with a 2.5 million mile haulage plan.

We made this point to the DCLG. We also made the point, as we did in 2012 along with the Environment Agency and Natural England, that a SA did not inform the choice of sand and gravel sites for inclusion in the Plan. DCC rejected eighteen alternative sites several months before the SA. The SA confirmed that Straitgate was one of the most constrained sites of all the sites considered.

But actually, we needn't have bothered. The DCLG - who has had dialogue with DCC subsequent to our complaint - has now written, without explanation:
I have considered your letter and have found no grounds for concern in the inspector’s report, nor grounds for the Secretary of State to intervene at this time.
The Devon Minerals Plan will now be formally adopted on 16 February 2017. It remains to be seen how a 2.5 million mile haulage plan would fit with the very first objective of this new Plan:
Objective 1: Spatial Strategy
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.

Wednesday, 8 February 2017

Whilst AI has 44-tonne designs for Birdcage Lane...


2. Whilst China's solar power capacity doubled in 2016, the UK backed a new source of fossil fuels. Fracking is highly controversial and supported by just 17% of people in a government survey. Aggregate Industries was one of the first in line to profit from fracking. This week, one aggregates company did the decent thing after a quarry protest in Bolton. A second supplier has followed suit.

Bolton News

[Marine sources] were responsible for supplying 25% of the sand and gravel needs in England and 49% of the equivalent needs in Wales.
The vessels will be the first new aggregate dredgers to be commissioned by the company in the UK for more than 25 years.

... results in significant disturbance through removal of substrate and the generation of sediment plumes through processing of the aggregate. The latter can lead to local burial of habitats and smothering of animals.
4. Let's put Aggregate Industries' plans to destroy 2km of ancient hedgerows and dormouse habitat at just one site in East Devon into context; not all farms are like Straitgate.

Yes, 'consider the possibilities that drones can bring to the world of construction'

We mentioned one of the possibilities in A new level of scrutiny on quarry operators... which cast a new light on an abandoned Aggregate Industries' quarry in Derbyshire.

Here are some of the other possibilities that drones can bring to the world of construction.

Monday, 6 February 2017

AI's asphalt plant at Rockbeare continues to operate without permission

Whilst a 'Towering inferno at an Aggregate Industries Express Asphalt plant in Greater Manchester proved 'awkward' for firefighters' and 'could have been extremely dangerous', the company's asphalt plant at Rockbeare in Devon continues to operate without permission.

Last May, AI submitted a planning application, DCC/3867/2016, to retain the plant. AI has been operating the asphalt plant at Rockbeare without planning permission since 2014.  According to its own supporting statement:
3.1 The existing asphalt plant was permitted, in its current location, under planning permission 99/P0568 (see Appendix 1). Under condition 8 of this permission, the asphalt plant was time limited by way of requiring removal of the plant upon cessation of mineral extraction. Condition 8 states:
“Unless otherwise agreed in writing with the Mineral Planning Authority, upon completion of the mineral working at the mineral site, the plant hereby approved shall be removed and the area restored in accordance with details to be submitted pursuant to Review of Old Mineral Permission No.7/11/98/P0050.
Reason: To ensure satisfactory restoration in the interests of visual amenity.”
3.3 Mineral extraction ceased at Rockbeare Quarry (Marshbroadmoor) in 2014. The purpose of this planning application is to seek the permanent retention of the asphalt plant, aggregate store and associated facilities.
Extraction at next door Marshbroadmoor may have ceased in 2014... but since none of this mineral was ever processed at Rockbeare that date seems immaterial. What does seem material is, as AI pointed out in its planning application for Straitgate Farm, that "mineral processing was last carried out at Rockbeare in 1994" [5.36] when "most of the production was used on a daily basis by the on-site asphalt plant and the Charcon Concrete Products Factory (now closed)".
We made the point that if mineral processing - and production of a sand and gravel feedstock for the asphalt plant - is no longer carried out at Rockbeare:
Why should Rockbeare continue to be a suitable and sustainable location for asphalt processing? Why should the community permanently forgo the "satisfactory restoration in the interests of visual amenity"?
The consultation to this application closed in July 2016. DCC has since advised:
The deadline date for the determination of this application has been extended to the 7th March 2017 in order to allow further discussions and consideration of biodiversity off setting which may be required as a result of the land occupied by the asphalt plant not being restored for the benefit of nature conservation, as originally envisaged in the Rockbeare Quarry permission.
As yet, DCC and AI "have not discussed any specific sort of offsetting and where it would be".

Friday, 3 February 2017

"Building hedgerows, habitat corridors & bridges is critical to this species' survival"

Dormice inhabit the ancient hedgerows of Straitgate Farm - the same hedgerows that Aggregate Industries plans to destroy. Virtually no established and appropriate mitigation planting is yet in place: 85% of the trees planted will have to be removed for airport safeguarding purposes [6.6, 6.12] and the hedgerows that have been planted are now in the wrong place.

Dormice, a European Protected Species, are on the verge of extinction. New research tells us why:
The existence of the UK's endangered Hazel dormouse is under threat as gaps in tree canopies are leaving the creatures unable to use their hypersensitive whiskers to naturally cross between habitats, a new study reveals...
Gaps in the tree canopy proved to be a major problem for the dormice meaning that gaps in their habitats need to be connected in order to help preserve numbers. Building hedgerows, habitat corridors and dormouse bridges is critical to this species’ survival...
Dr Grant said: “Although dormice can jump quite large distances, when the gaps between platforms were larger than 10-15cm, the dormice started behaving differently – they would eat less of the food available to them and also spend more time travelling on the floor as opposed to the canopy. This behaviour change would put the dormice in danger as this species is vulnerable to threats on the ground.”
Here's where dormice have been found at Straitgate. AI's plans rip right through their habitat.

Wednesday, 1 February 2017

Venn Ottery Quarry surface water run-off

It’s encouraging to see restoration now proceeding at Venn Ottery Quarry. The roads are quieter and the horse-riders are back out in force.

But surface water run-off from the quarry has been a persistent problem, particularly for the Public Right of Way that runs along the eastern side of the site. Complaints have been raised over the years.

Aggregate Industries has seemingly made no provision for surface water run-off from the quarry, which has now washed part of the footpath away.

At Straitgate Farm, with flood-prone communities downstream, surface water run-off will be critical in any quarry design. At Venn Ottery Quarry even a footpath presents a problem.

EDIT 4.2.17: We’ve since been advised of more serious erosion immediately downstream of the above.