Friday 20 December 2019

Merry Christmas



Christmas is almost upon us and another year has passed in the Straitgate affair.

This pantomime has been running since 1965, and, as we posted, Aggregate Industries' planning application will now enter another decade.

Over the last two years, one of the subjects that has challenged Aggregate Industries and Devon County Council has been the 🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🐄🚶and how they would need to regularly cross the B3174 Exeter Road to replacement grazing as a direct result of the company's proposal to quarry their pasture. If we were to frame the problem in Christmas cracker terms:

Why did the cows cross the road? Where else could they go?

It's not a joke, but because it’s nearly Christmas, by unpopular demand here are some that are. Don’t blame us, blame the internet.

Why did the cow cross the road? To get to the other side.
Why did the sheep cross the road? To get to the other side.
Why did the chicken cross the road? To get to the other side.
Why did the farmer cross the road? To get his animals back.

Two cows were talking in a field. The first cow said to the other, "Have you heard about the Mad Cow disease going around?" The second cow replies, "Yeah, makes you glad you’re a penguin, doesn’t it?"

Two cows were talking in a field. The first said "moo" and the second said "baaaa." The first cow asked the second cow, "why did you say baaaa?" The second cow said, "I’m learning a foreign language."

Why canʼt you tell a cow a joke? They already herd it.
What do you call a cow with a sense of humour? A cowmedian.
What do you call a cow after she has given birth? Decaffeinated.
What has four legs and goes "Oom, Oom"? A cow walking backwards.

Why do dairy farmers get along with their cows so well? They work well with udders.
I asked a farmer if it’s easy to milk a cow. He said, "Sure. Any jerk can do it."
This guy keeps making cow jokes... how dairy!?!

Anyway, this subject's been milked dry, so – Merry Christmas and a Happy Moo Year to all readers!

PS. If Aggregate Industries and Devon County Council have had nightmares over the cows – this video of surreal bovine choreography is unlikely to help. Someone suggested this is what cows do when no one's looking, and perhaps they're right. It’s had 55 million views. Enjoy.



A quiz



Here's a little quiz – based on a subject we’ve touched upon before: You have two cows. Cows have been important throughout the ages. Who might have come up with these lines?
Thou hast two cowes, blisful matir for to seke, Thy cowes art but a milde wight and meke.
A cow, a cow, my kingdom for a cow!
It is a truth universally acknowledged that a man in possession of two cows must be in want of a wife.
You have two cows. That's a maximum combined energy output of 1.062*1020J.
You have two cows. You shall milk them on the beaches, you shall milk them on the landing grounds, you shall milk them in the fields and in the streets, you shall milk them in the hills...
You have two cows. One of them is descended from Turgon, son of Fingolfin, son of Finwë, and dwelt in the hidden city of Gondolin, that in Quenya is called Ondolindë, which is The Rock of the Music of the Water. The other is the daughter of... (continue for 300 pages)
You have two cows. Not a lot of people know that.
A large black monolith appears and then you have two cows.
Listen, don't mention the cows. I mentioned it once, but I think I got away with it all right.
You have two cows. Huge, inflatable cows floating above London.
You have two cows, but they were born to run, so you set them free.
U have 2 cows. It's alright, they moo in mysterious ways
"What are those things, Spock?" "They're cows, Jim, but not as we know it."
This show was brought to you by the letters C, O, W, and S, and by the number 2.
You have 42 cows.
You have two cows. Your sole object in life is to find suitable bulls.
You have two cows. One of them is a mole.
Your two cows are the milkmen. Moo moo ga moob!
This is Ground Control to Major Cow, you've really made the grade. And the papers want to know whose grass you eat.
You're just some bovine that I used to know.
You have two cows. One of them used to produce ordinary milk, but then it got cancer and started to produce illegal crystal milk. The other says "bitch!" a lot. You win a gazillion awards for your cows. 
You have a printing press that creates cows. You print tons of cows for everyone, then wonder why there are no pastures left.
You have five cows, named Alpha through Epsilon. They give you an excuse to rail against modernity.
You have two cows. You feel guilty, but you have no clue why.
You have two cows. Being female, they suffer.
You have two cows. I won’t tell you how many I have. I would rather hide in a fridge.
You have two cows. I can’t tell you how many I have. In times of universal deceit, telling the truth is a revolutionary act.
Most of the answers can be found here.

Tuesday 17 December 2019

AI’s application to quarry Straitgate Farm – determination date delayed for 9th time


In October, we posted AI’s planning application to quarry Straitgate Farm will now enter a new decade. Devon County Council and Aggregate Industries have this week agreed a further extension for determining the application to quarry Straitgate, "from 31st December 2019 to 31st March 2020".

Aggregate Industries launched its application to quarry Straitgate Farm back in 2015.

In June, we posted Straitgate determination date extended for 8th time, and listed some of the issues the company could be struggling with. We won’t go through these again. None appear resolved.

Monday 16 December 2019

Speeds of 80MPH + recorded on B3174 Exeter Road – and still no safety assessment

Aggregate Industries’ Transport Assessment to support its plan to quarry Straitgate is worth scrutinising. It contains data about the B3174 Exeter Road that the company would no doubt rather not publicise.

We’ve already posted about how Aggregate Industries’ consultants have been economical on reporting road accidents, but the Transport Assessment is also economical on the subject of speed.

Locals warn of how fast vehicles travel on the B3174 Exeter Road. Not only locals. Devon County Council’s Head of Planning, in an email in 2017 released after a Freedom of Information request, recognises that this is "such a fast straight road."

But, according to Aggregate Industries' traffic consultant Horizon, this is not so. In February 2018, in an email to reassure the Council's highways department about the cattle crossing, Horizon wrote:
The suggestion within the safety audit that speeds could be in excess of the national speed limit (60 mph) is therefore incorrect, although it should be noted that the audit teams comments were based on data that was older and located to the east of the site.
Subsequent to that, Horizon commissioned a new traffic count – after the previous one was found to be fiction. What were its conclusions? The Transport Assessment says:
1.1.7 The 85th percentile vehicle speeds were below the signed national speed limit with those recorded during the working week lower than those recorded at the weekend.
and that furthermore:
4.3.8 A full standard visibility splay of 215 m can be achieved at the junction of Birdcage Lane with the B3174 Exeter Road. This is appropriate for a 60 mph road, although the highest 85th percentile vehicle speed recorded during the seven day survey was 58.2 mph eastbound and 57.1 mph westbound. It is noted that both the highest percentile speeds were recorded on a Sunday, the weekday 85th percentile speeds ranged from 56.0 to 56.8 eastbound and 54.7 to 55.5 westbound representing a lower vehicle speed during the operational periods of the proposed quarry.
So, no indication of problems there. But this doesn’t tell the whole story. The 85th percentile speed tells us about the speed that 85% of drivers drive at or below. What about the rest? If you analyse the traffic count data over the 5 day working week, in Appendix C, you will find that:
1933 vehicles were travelling faster than 60mph.
275 of those vehicles were travelling at 70mph or more.
85 of those vehicles were travelling at 80mph or more.
Local people may not be surprised by these numbers, but it does rather undo those assurances in that email from Mr trust-me-I'm-a-traffic-consultant. Remember too:
  • Aggregate Industries' plan to quarry Straitgate would put up to 53% more trucks on this road;
  • the B3174 Exeter Road is as little as 5.3m wide, according to Horizon;
  • as a direct result of Aggregate Industries' proposal, cows would need to cross the B3174 Exeter Road for replacement pasture on the south side of the road;
  • vehicles would need to stop for the cows, as we've posted, just beyond the brow of this hill;




We posted about the cows in Bovine movements revisited – more than 2 years on. But what are the safety implications? Well, we might not know – at least not before this application is determined.

The FOI shows that at the request of the Highways team, Devon County Council formally asked Aggregate Industries for the provision of a Stage 2 Road Safety Audit. The same FOI also shows the company, in the words of the Council, "pushing back" on performing such an audit before determination.

Why, if Devon County Council requested it, has no Stage 2 Road Safety Audit been performed? What has Aggregate Industries to hide? The safety aspects of this proposal obviously need to be properly assessed. Not only to know if the operation is workable, but so that all concerned can make an informed decision – with ALL the facts – when the application is finally determined. Currently, no such assessment has been made. According to this document:
Rural roads account for 68% of all road deaths, and 82% of car occupant deaths in particular, but only around 42% of the distance travelled. Of all road deaths in Britain in 2010, 49% occurred on National Speed Limit rural single carriageway roads (DfT, 2010).
The provision of a Cattle crossing over the B3174 may have severe impact on the operation of the B3174, which in the absence of assessment is not known.

Quarry workers five times more likely to die from COPD

If quarry companies controlled dust emissions – for workers and others living around their sites – articles like this would not keep appearing:


The health impact of dust from quarries has been known about for decades, and what's been done? According to a HSENI inspector:
Industry has been working on the preparation of a strategy to deal with dust and limit the exposure to the workforce. It is now time to have these strategies fully implemented.

Monday 9 December 2019

AI’s TA fails to assess impact of cows on queueing traffic

Aggregate Industries’ Transport Assessment is at Revision E. It’s been played about with since it was written in July 2018 – bits added, bits taken away. It is the third TA from Aggregate Industries for the company's proposal to quarry Straitgate Farm. As we posted in Transport Assessments & HGVs: How consultants create an alternative reality, these documents are supposed to be "thorough assessments of the transport implications of development."

One of the transport implications of this development is that the tenant dairy farmer would have to take cows across the B3174 Exeter Road to seek replacement pasture, should Aggregate Industries take land away for quarrying and soil storage. We recently posted about the cows in Bovine movements revisited – more than 2 years on.

Aggregate Industries has provided this helpful map to show where the cows would cross:



You might have thought therefore – given that Aggregate Industries has spent more than two years dealing with the issue – that its consultants would have actually assessed the transport implications of this development, and particularly what traffic queues might result from cattle crossing this road.

Aggregate Industries' Transport Assessment recognises that:
3.2.5 It is noted that when the herd is moved it is done so in batches that restrict the traffic delay period to 15 minutes. Therefore on average the delay to a vehicle using the B3174 as a result of herd movement is between 10 – 15 minutes at any one time.
But Aggregate Industries hasn’t wanted to feed the number of vehicles using this road into the mix. It hasn’t wanted to answer a number of very important questions: What number of vehicles would typically be held up by 150 cows crossing at milking times? What traffic queue lengths could result? Would the road system still function safely, for example if vehicles backed up onto the Daisymount roundabout? Would this have any impact on the A30?

The provision of a Cattle crossing over the B3174 may have severe impact on the operation of the B3174, which in the absence of assessment is not known.
In the absence of such an assessment, we previously used numbers from a Highways England traffic count commissioned in November 2015 to show that queues of over 100 vehicles from the cattle crossing make AI’s plans unworkable:
During the 15 minutes crossing times, over 100 vehicles can be travelling on the B3174 Exeter Road, in one direction or the other. If we assume an average queuing vehicle length of 7.5m, including gaps, this means that traffic queues could stretch to the A30 Daisymount Junction and half way to Ottery.

This does NOT take into account the HGVs – up to 216 movements a day – that would be generated by Aggregate Industries' plans to quarry Straitgate Farm.

This does NOT take into account the extra development in Ottery St Mary since 2015. This does NOT take into account the plans for the Tipton St John school relocation and the additional 150 houses needed to pay for it. This does NOT take into account the extra traffic generated by the "Massive new service station and drive-thru McDonalds" planned for the A30 Daisymount junction. So, let's therefore call it a best case scenario.

Why hasn’t this assessment been done by Aggregate Industries? Why hasn’t Devon County Council called for it – in the more than 2 years of to-ing and fro-ing? Was there a worry of what it might reveal?

Or was the Council labouring under the illusion that the statement 1.1.8 in Aggregate Industries' TA – "there will not be a need to intensify livestock crossings over the B3174 Exeter Road above that already stated as the baseline" – could, in some post truth world, be relied upon?

Has the Council forgotten that 56 acres of pasture would be removed in Phase 1 alone – 40% of the land available on the northern side of the B3174, where the milking parlour is located? Does the Council not realise that few dairy farmers could cope with losing such a portion of productive land and still remain viable? According to the Supporting Statement, Phase 1 would not be restored until Phase 3:
3.4.10 Soils and overburden from [Phase 3] would be direct placed back into phases 1 and 2 to complete restoration in these areas.
And that’s only Phase 1. In total, 105 acres of pasture is proposed for quarrying and soil storage:
The application site covers an area extending to some 42.5ha, with mineral extraction proposed to take place within 22.6ha with the remainder of the site occupied by temporary soil storage bunds, mitigation planting and site management and access areas. 2.1.10
Given such a situation, what farmer would not be forced to intensify livestock crossings to access replacement land – even if it were across a road – rather than twiddle their thumbs and watch their business go down the pan?

‘UK aggregates recycling on the rise’

Latest industry findings from BDS Marketing Research, the leading consultancy for the heavy buildings materials sector, indicate that the market for recycled aggregates continues to strengthen. In 2018, estimated volumes produced at stationary recycling plants from construction, demolition and excavation waste reached 50 million tonnes.
Commenting on the latest findings, report author Andy Sales said: ‘We have seen further evidence of the importance of recycled aggregates to the construction industry in 2018. Growth over the last two years in their production has been in contrast to a fall in the output of primary aggregates over the same period. Recycled aggregates can represent a more sustainable, economic or local alternative to the use of primary materials.’
According to BDS, the market for recycled aggregates remains very fragmented with no individual producer holding a market share in excess of 5%. This is in contrast to the primary aggregates market where the leading five suppliers share around 70% of the market between them.

UK construction activity continues to fall

Hundreds of industrial waste dumps in Devon – many in former quarries

Defra's figures show there are 301 historic landfill sites in Devon - of which 293 contain industrial waste.

Wednesday 4 December 2019

Wow. ‘Only AI can be trusted to provide data on cows’

In the recent post Bovine movements revisited – more than 2 years on we explained how Aggregate Industries has found itself in a pickle with cows, how its proposal to quarry Straitgate Farm would result in increased livestock movements across the B3174 Exeter Road to access replacement grazing.

Aggregate Industries' Transport Assessment has been tasked with looking at the implications of such movements. One line on the subject of the "Dairy Farm Operation" – with our emphasis – reads:
3.2.7 Should further data be issued directly to either the Mineral Planning Authority or Highway Authority without prior knowledge of the applicant and landowner (Aggregate Industries UK) then it is recommended that this information is treated as invalid unless it is specifically derived from the agreed data set initially provided by the Tenant Farmer which represents the worst case.
In other words, only Aggregate Industries – purveyor of everything truthful – can be trusted to provide the numbers when it comes to cows. What a joke.

What's Aggregate Industries worried about? That Devon County Council's planners can’t decide for themselves how valid or invalid information might be? That someone might spoil the show? That someone might let the cow out the bag, and tell it as it really is?

Remember, this is the company that conveniently forgot to mention the 150 cows in the first place. This is the company that has already produced a whole raft of fiction for the rest of the planning application without batting an eyelid.

But paragraph 3.2.7 already has a problem with truth. Currently dairy herd movements across the B3174 do not need to occur daily – in fact hardly ever. However, the Tenant Farmer's Land Agent has NOT agreed that the numbers they provided are "worst case", in fact – as we've already posted – far from it:
In the event that no cow tracks were installed at Straitgate, and in time that no additional cubicle housing were erected to house the dairy herd these movements would need to occur daily.
Aggregate Industries has not offered to provide cubicle housing. So much for the validity of that claim. But it's the paragraph preceding 3.2.7 above that we wanted to focus on here, where the company and its traffic consultants actually claim to know better than the Tenant Farmer – again, our emphasis:
3.2.6 Whilst the crossing times have been advised by the Tenant Farmer it should be recognised that the herd will move at the speed of the dominant cow and therefore crossing times may be less than those stated (the 15 minute delay representing the maximum period before the Farmer splits the crossing and is therefore unaffected by the speed of the cows). Dairy herds of similar size have been observed at other farms in Devon crossing a similar distance, without splitting the herd, in 4 minutes.
How valid is this information? Do Aggregate Industries and Horizon Consulting have expertise on such matters? Have they been trained in dominant cow theory, or are they talking bull? Given that Horizon raised the matter, let's look at what's said about dominant cows:
4. The majority of the dominant cows are at the front of the herd, but a significant number are present throughout the herd including the rear group: It is important that cows have space at all times to keep their distance and avoid forced interaction with cows around them of similar or higher dominance. Response: Don’t put pressure on the rear cows in the herd.
5. Dominant cows set the walking speed of the herd. Pressure on the rear cows on the track or by the backing gate causes the rear group to compact because they won’t overtake the dominant cows in front of them. The front cows are almost unaffected and so don’t walk any faster - they continue at their own speed. Response: Don’t put pressure on the rear cows in a herd.
The message seems clear: don't hurry cows – they go at their own speed. Anyone who's watched cows will know this for themselves. The timings put forward by the Tenant Farmer will no doubt have also included time for setting out and clearing away any barriers, and clearing muck off the road.

With Aggregate Industries' 4-minute claim in mind, let's look at cows crossing a road elsewhere in Devon, to watch the dominant cow theory in action:



Aggregate Industries and friends would of course recommend that this information is treated as invalid.

Tuesday 3 December 2019

Plymouth’s Drakelands mine changes hands again

It was only in September that the Plymouth Herald reported "Plymouth’s Drakelands mine has a new owner – but it is unlikely any tungsten will be dug out of the ground." We posted on the subject at the time, but warned:
Will that be the last of mineral working in the area? Don’t hold your breath. In August, planning application DCC/4149/2019 appeared for land south west of Drakelands Mine, Sparkwell, for "exploratory trenching for mineral exploration."
Yesterday, Hargreaves Services plc announced it had sold the mine at Hemerdon to another party, who has "a view to recommencing tungsten mining operations in due course":
Following the announcement by Wolf on 10 October 2018 that it had ceased trading, Hargreaves has been in discussions with the Official Receiver, acting as liquidator of Wolf, and other interested parties including Devon County Council, the Environment Agency and various landowners regarding the future of the tungsten mine.
Earlier this year, Drakelands Restoration Limited ("DRL"), a wholly owned subsidiary of Hargreaves, acquired various freehold and leasehold properties and an assignment of the minerals lease whilst discussions over the site's future progressed. DRL has been reimbursed for the costs of safeguarding and maintaining the site during the period of those discussions.
The Board is pleased to announce that it completed the sale of DRL to a third party, Tungsten West Limited ("TWL"), for £2.8m in cash on 29 November 2019. The sale proceeds will be paid to Hargreaves today. As a result of this transaction, TWL has acquired control of the Hemerdon mine with a view to recommencing tungsten mining operations in due course.
Industry experts have put the cost of reopening the mine "at about £40million."

Monday 2 December 2019

AI: We will make Straitgate farmland ‘better accessible and utilised more efficiently’

LOL 😂

You have to admire the creativity and chutzpah of the traffic consultants working on behalf of Aggregate Industries, the company with plans to quarry and store soil on 105 of the 145 acres at Straitgate Farm – 72% of the land available to the farm on the northern side of the B3174.

As a result of Aggregate Industries' plans, cows would need to cross the B3174 for replacement grazing. Up to four crossings a day would be required, since the milking parlour is on the northern side of the road. Our recent Freedom of Information request revealed that Aggregate Industries and Devon County Council have been bogged-down with this issue for more than 2 years.

Although we raised the matter in our response to the Council in March 2017, one of the Council's highways team nevertheless emailed Aggregate Industries' traffic consultants – Horizon Consulting Engineers – in September 2018, and asked:
Also does the tenant current use any of the fields that are to be used for the extraction for grazing? This could affect future movements of livestock.
Horizon's reply came in November 2018. Here's one paragraph from it – with our emphasis:
In terms of the current grazing patterns, yes the quarry will affect a couple of the fields on the northern side of the B3174 as a result of the first quarry phase – but as discussed at our previous meeting the construction of the cow tracks (as requested by the Tenant Farmer) will enable the movement of the livestock to the remaining fields on the northern side in a more efficient and less damaging operation. Fields which are therefore currently used less, due to the distance from the main sheds, then become better accessible and utilised more efficiently. The provision of the cow tracks and gates for the Farmer (at their request) therefore become the mitigation to maintain the baseline livestock movements.
You have to laugh! The person who wrote that either hasn't got a farming clue, or is blatantly trying to mislead the Council.

This claptrap is even formalised by Horizon in Aggregate Industries' Transport Assessment:
5.5.8 The provision of cow tracks, with additional gated field access points, will improve the accessibility to existing grazing land, via the efficient movement of livestock, and potentially reduce damage to grazing associated with the movement of the herd between fields.
You wonder how farmers have managed in the past – without the benefit of such wisdom.

Overlooking that for one moment, let's dispose of one lie straight away: The "couple of fields... of the first quarry phase" is shown below. Some 56 acres – 9 fields in all – would be affected by quarrying and associated soil storage from the off:
Initially, the applicant will need to resume some 22.5ha to facilitate the first stage of the proposed development (Phase 1). In addition to the area required for mineral extraction, this area will include the land required for temporary soil storage bunds and access. 2.1.10


As for the "provision of the cow tracks and gates" making land "become better accessible and utilised more efficiently".... well, do we really need to explain? Perhaps we do.

Firstly, no farmer these days can afford to let land be under-utilised.

And however many tracks and gates are provided – however whizzy – however fast they deliver cow-to-field – they do not provide replacement grazing. Even if the tracks and gates were gold-plated, smelt of roses, and provided all manner of sensory pleasures to the cows, they are not going to make up for the amount of pasture lost to Aggregate Industries – almost 40% in Phase 1 alone, they are not going to be "the mitigation to maintain the baseline livestock movements". Sorry to disappoint, but anyone with half a brain can see that. Horizon Consulting claim they provide "civil engineering, geoenvironmental and geotechnical consultancy services" – perhaps they should stick to that in the future.

This photo, taken last week, shows the northern-most field at Straitgate – furthest from the main sheds.


Goodness. How on earth did those cows get there without the help of Aggregate Industries & friends? 🤔

Thursday 28 November 2019

What Strava tells us about AI’s haul route

Birdcage Lane is hardly used by anyone, argues Aggregate Industries' Transport Assessment. Someone apparently counted vehicles on Birdcage Lane at "peak hours", and came to the answer of one.


What a perfect place to put up to 216 44-tonne HGVs a day. Who on earth would notice?

But Birdcage Lane’s low frequency of traffic is what makes it so attractive to pedestrians, joggers, ramblers, dog-walkers, cyclists, horse riders, and even five-time Olympic runners. It was why, with the backing of highway consultants Vectos, another site access point was suggested to eliminate pedestrian and HGV conflict.

Aggregate Industries' Transport Assessment is silent on the pedestrian use of Birdcage Lane, save for:
1.1.6 To reduce the potential interaction of pedestrians and HGV’s in a rural environment a footway will be provided along Birdcage Lane to the point where the new section of Permissive footpath is proposed.
This would have a "1.2m maximum width" and be overgrown in no time. But it’s the thought that counts, and we should consider ourselves lucky.

In the past, Aggregate Industries' consultants have disputed that Birdcage Lane is used by pedestrians:
The roads adjacent to the application sites are not ideal for pedestrian use. 
4.1
It was of course nonsense. Aggregate Industries, if asked, would no doubt still dispute that these quiet lanes have amenity value. Show us the proof, they might say. And modern technology does.
Strava: a social fitness network, that is primarily used to track cycling and running exercises, using GPS data.
Click on the screenshot below to show the pedestrian use of Birdcage Lane:

Aggregate Industries' consultants should clearly have been counting bipeds and quadrupeds as well. But then again, that wouldn't have given them the answer they wanted, would it?

Strava also tells us about the B3174 – the road that Aggregate Industries wants to use to haul sand and gravel. The company's previous TA said the B3174 was unattractive to cyclists. The latest TA is silent on the matter of cyclists and the interaction with up to 216 HGV movements a day, save for:
3.2.13 There are no designated cycle routes within close proximity of the proposed mineral extraction site, however proficient cyclists may utilise the network of quiet lanes.
Clearly they use more than just the quiet lanes. The screenshot below shows cyclist use of the B3174:

Plainly – and this won't be the last example – Aggregate Industries' Transport Assessment has been found deficient. Consultants have not assessed ALL road users around the site. How very remiss. How very unsurprising.

Wednesday 27 November 2019

Another accident on B3174 Exeter Road



There was yet another accident just outside Straitgate Farm last night – again highlighting the dangers of this road, and its unsuitability for Aggregate Industries' plans for up to 216 HGV movements a day.

Of course, the company’s Transport Assessment paints a picture of sunshine and roses. It claims:
3.2.28 In summary one serious and two slight collisions have occurred on the examined section of highway network over the five year period.
If only it were so. We have posted about various accidents that have come to our attention over just the last 3 years – here, here, here, here, here, here, here, here, here, and here. No doubt there will have been many others.

Tuesday 26 November 2019

HGV movements at Straitgate would be 70% higher than UK’s biggest mining project

Aggregate Industries' proposal to quarry Straitgate would generate up to 216 HGV movements a day.

To put that number in context, let's look at the biggest mining project in the UK: the Sirius Minerals project to extract polyhalite at its mine at Dove’s Nest Farm in the North York Moors National Park.

The project has recently run into problems. Now – earlier than expected in an effort to 'de-risk' the project for investors – the plan is to transport the fertiliser above ground, from the Woodsmith Mine near Whitby to Teesside. According to TeessideLive, Sirius Minerals plan to bring polyhalite to Teesside by lorry – but only 63 journeys allowed a day:

Planning permission is already in place for Sirius HGV vehicles to make 63 return journeys a day, along the A171 and into Teesside.
It was sought by the firm from the outset to cover an interim period between reaching first polyhalite and building the remaining infrastructure needed to transport it underground.
the worst case scenario of 127 daily HGV movements 15.6.5
By contrast, the number of HGV movements that would be generated by Aggregate Industries if quarrying were to proceed at Straitgate are up to 70% higher – part of the route on a B road as little as 5.3m wide.

Rockbeare update

Further documents have now been supplied in connection with Aggregate Industries' planning application DCC/4132/2019 "to continue importation of inert soils and subsoil to allow for revised restoration contours at Marshbroadmoor including a revised restoration scheme at Rockbeare Quarry."


Aggregate Industries, through its agent, says:
The changes deliver a significant reduction in the timescales for restoring Marshbroadmoor and the remaining areas of the Rockbeare site; provide a solution for securing the restoration of the RB2 void and provide long term alternative habitat for nesting sand martins at Beggars Roost.


It’s not clear how these revised proposals answer the concerns of Exeter Airport, which objected on the grounds of aviation safety, given that "any additional tree planting and landscaping works in this area have the potential to further increase the surface penetrations that Exeter Airport already suffers."

Nevertheless, as we previously posted:
Mineral extraction at Rockbeare dates from 1947 and at Marshbroadmoor from 1997. The retrospective application seeks to amend the restoration scheme such that the "final restoration of Marshbroadmoor will be completed by April 2022" and "the timeframe for restoration of Rockbeare… remains up to 21st of February 2042."
Now, "a reduction in end date for the restoration of the Rockbeare site to the 31 December 2028 at the latest" has been proposed.

However, let’s not get carried away. If you look at the recent monitoring reports for Rockbeare – for 2019, 2018 and 2017 – you will see it has been a protracted effort to get Aggregate Industries to restore this site. Throughout these reports you will see the comment:
Mineral Planning Authority was notified on 11 October 2017 that mineral working/tipping operations ceased circa 1995
Yes, 1995. And in 2019 we're still discussing restoration.

Planning conditions for Rockbeare are governed by ROMP 7/11/98/P0050. Given that operations ceased at Rockbeare so long ago, let’s look at what condition "A20. RESTORATION IN THE EVENT OF PRIOR CESSATION OF WORKING" says:
In the event of a prior cessation of winning and working of minerals prior to the achievement of the final agreed levels, as referred to in Conditions A17 and A18 above, which in the opinion of the Mineral Planning Authority constitutes a prior permanent cessation within the terms of Paragraph 3 of Schedule 9 of the Town and Country Planning Act 1990, a restoration scheme, to include details of the aftercare (see Condition 19 above), shall be submitted for approval to the Mineral Planning Authority within 3 months of being so requested by the Mineral Planning Authority. The Approved Scheme shall be implemented within 12 months of approval, or within any such other period as may otherwise be agreed in writing with the Mineral Planning Authority.
So, even if restoration does get completed in 2028, that’s 33 years late. What a relief to know that quarrying is only "temporary in nature". 

Even now, in the latest Monitoring Report, with regard to condition "A2. DEVELOPMENT ACCORDING TO SUBMITTED PLANS", Devon County Council says:
A planning application has been received to address the above however this is yet to be determined. This is due to outstanding issues relating to; mitigation for sand martin nest holes; suitable restoration and infilling of RB2; and, conflict with haul roads and permissive paths in the restoration scheme. The operator is required to address this information on or before 31 January 2020 to avoid enforcement action by the County Council.
But then littering the 2018 Monitoring Report were also threats of enforcement action, as there were in the 2017 report too. Perhaps that’s just the way that Aggregate Industries operates.

AI’s application to continue to work secondary aggregates at Lee Moor approved


The above photo shows the production of secondary aggregates from china clay by-products at Lee Moor, near Plymouth. It is taken from the Devon Minerals Plan. In August, we posted that Aggregate Industries had submitted another planning application to work minerals in Devon:
Planning application DCC/4146/2019 seeks to continue to work secondary aggregates at Lee Moor, near Shaugh Prior on the outskirts of Plymouth. The site is not far from Drakelands – the tin and tungsten mine at Hemerdon that also sits as an unrestored scar on the Devon landscape after the operator went into administration last year.
AI wants to deepen the extraction area of Tip T1 from 256m AOD to 228m AOD, to realise 4 million tonnes and "secure the future of the site until 2049/50"
The previous use of the development site presents a high risk of contamination that could be mobilised during operational phases and pollute controlled waters.
The issue is conflict with the already approved overarching restoration of the Lee Moor complex. Details of which can be found at: https://planning.devon.gov.uk/PlanDisp.aspx?AppNo=DCC/2977/2010
Requiring that the a landform be re‐created for the interim period could be very difficult to justify if not offered by the operator.
The Environment Agency replied:
We take your point.
When the ROMP comes around again, ideally we’d like to see some effort is made towards progressive land‐forming.
This would go some way to addressing those run‐off issues that we highlighted.
And that was that. Three months after being submitted, the application has now been approved with conditions, under delegated powers. This is the officer’s report for anyone interested.

Aggregate Industries – and possibly even the Environment Agency and Devon County Council – must surely wish that every planning application for 4 million tonnes of aggregate could be that simple.

Monday 25 November 2019

Professor who criticises AI’s plans for Straitgate awarded Whitaker Medal

The Professor of Hydrogeology who said 'ANY quarrying at Straitgate would cause problems' is to be awarded the Whitaker Medal "in recognition of an outstanding contribution to hydrogeology."
Professor Brassington received the prestigious award in London today.


Devon Climate Emergency Response Group


The Devon Climate Emergency Response Group – made up of Devon’s councils, emergency services and business groups – has set up a Net-Zero Task Force who "want your ideas on how to reduce carbon emissions as quickly as possible."

The Net-Zero Task Force has been tasked with delivering the Devon Carbon Plan.
The Carbon Plan will lay out in stark terms what every resident, organisation and business has to do to reduce emissions and help safeguard the planet for the next generation.
This Call for Evidence is open to everybody, and submissions can be made through the Devon Climate Emergency website, and every submission will be reviewed by the Task Force.
Evidence can be submitted through to early 2020.
Of course, one idea for the Devon Carbon Plan for a start would be for Devon County Council to adhere to their own existing climate change policies. Look at page 36 of the Devon Minerals Plan, for example:


How is Aggregate Industries’ multi-million-mile haulage plan for Straitgate supposed to fit with that... and our existential crisis?


Nick Lowles, from UK-based anti-racism group Hope not Hate, which commissioned the survey, said the findings showed that the public were "way ahead" of politicians in recognising the scale of the climate crisis. "They understand the scale of the problem and want governments to take the strong and decisive action that this emergency requires."

Plans to turn Incinerator Bottom Ash into secondary aggregates in East Devon

Planning application DCC/4135/2019 will come before Devon County Council's Development Management Committee this week, proposing:
Change of use from In-Vessel Composting Facility to Incinerator Bottom Ash (IBA) Recycling Facility to import and process up to 90,000 tonnes of IBA per annum, Former TEG In Vessel Composting Site, Stuart Way, Hill Barton Business Park, Exeter
The processing of IBA has been a long running issue in Devon. Readers may remember the plans to process IBA at Buckfastleigh’s Whitecleave Quarry, which we posted about at the time, and which were rejected at appeal. Plans were then in play to build a processing plant in Plymouth – which came to nothing. Now the material – currently shipped to the Netherlands – is set to be processed in East Devon.

Concerns have been raised by local residents on noise, traffic, visual impact, dust and the nature of the material to be processed. According to the officer’s report:
6.5. The application proposes processing up to 90,000 tonne of material per annum, with this figure derived through the current contracts of the applicant and potential future operations: 60,000 tonnes from the Plymouth energy from waste facility – this is currently operational with IBA being transported to the Netherlands; 15,000 tonnes from a Bridgwater energy from waste facility – this facility is consented, and construction has commenced; and 15,000 tonnes from Hill Barton energy from waste facility – this facility is consented.
6.6 It is understood that the IBA generated by the Exeter energy from waste facility is currently contracted to be managed in Avonmouth.
The IBA will be processed into aggregates (IBAA) which will "reduce the need for land-won aggregates":
6.30. The primary benefit of the application would be the management of a waste material and production of a secondary aggregate within Devon that would reduce the need for land-won aggregates and the use of natural resources, an approach supported by the Aggregates Hierarchy in the Devon Minerals Plan.
Each year, "approximately 7,450 tonnes of metals will be recovered" and "67,500 tonnes of IBAA will be exported from the site".
6.30. Plymouth City Council require 95% of the IBA produced at the Plymouth energy recovery facility should be recycled to optimise the use of the IBA in the most sustainable way. Details to secure the use of the treated bottom ash as an aggregate for local infrastructure and engineering projects has also been approved by Plymouth City Council, which includes a marketing strategy.
To put that IBAA figure in context, figures for 2017 – still the most recent available – showed that Devon’s land-won sand and gravel sales were 598,000 tonnes.

Friday 22 November 2019

Bovine movements revisited – more than 2 years on


With Xmas fast approaching it must be time to talk about the cows again. We’ve had some fun with the issue of cows before: You have two cows being one example, this helpful suggestion being another.

Aggregate Industries may know something about the the quarrying industry – although given what a pigs-ear it’s made of its application to dig up Straitgate Farm that’s questionable – but it's got into a real mess with the cows. Incredibly, more than two years on, according to information released recently through a Freedom of Information request, the subject is still taxing both Devon County Council and Aggregate Industries: the cattle crossing issue is still not resolved, and safety assessments of cows crossing this road have still not been made.

As long as it’s done safely, a farmer has as much right to drive cattle on a public highway as an aggregates company has to fill it with 44-tonne HGVs. After all, many of our public roads had their origins in the movement of livestock. And lest we forget, farming needs our support:
Agriculture is an integral part of the Devon economy and wider community, and in difficult and rapidly changing times this sector needs support, to ensure local food production continues to exist and grow for the future.
Not our words, but those of Devon County Council. Natural Devon adds:
Farming is intrinsic to Devon. Today, agriculture and food production accounts for 13% of the county’s economy, compared to 7.6% nationally. As well as providing us with food and drink, over the centuries farming has created diverse and beautiful landscapes and wildlife habitats.
Straitgate Farm – the farm that Aggregate Industries wants to take for quarrying – has indeed been around for hundreds of years; the land has been farmed for thousands. For the last 80 or so of those, it has been a dairy operation. The majority of the land is classified as "best and most versatile". The Devon Minerals Plan reminds us that "a proposal affecting the best and most versatile land should provide for the restoration of the land to its former quality 8.7.9". The Plan also states:
The [Straitgate] site should be restored to enable resumption of agricultural use… The working and restoration phasing should minimise the area of land not in cultivation, as soil is best conserved by being farmed rather than stored where some deterioration may occur. C.4
Aggregate Industries’ Supporting Statement on the other hand warns that, after the mineral has been worked "in a series of phases over a period of between 10 and 12 years 3.2.1", the land will be no good for anything but "light intensity agricultural grazing 3.8.7".

Straitgate Farm has around 150 cows and access to around 150 acres on the north side of the B3174 Exeter Road. Of those, 120 acres are owned by Aggregate Industries, 105 acres of which are the subject of its planning application. The farmer has access to 82 acres to the south of the B3174, which are not owned by Aggregate Industries.

As we told Devon County Council back in March 2017, in our response to the application, and as we posted in Bovine movements the following month: In Aggregate Industries’ rush to get its hands on the sand and gravel, it had forgotten all about the cows:
With less pasture, the dairy herd would need access to more fields, available on the south side of the B3174. What safe provision would be provided for the dairy herd to cross this road four times a day?
It was, in Devon County Council’s subsequent Regulation 22 request and as we posted, the number one thing that AI had to answer. The Council wanted Aggregate Industries "to assess the implications of the farmer moving cattle across the B3174 as a result of the proposal":
It has been suggested that the reduction in available farmland on the Straitgate side of the B3174 means that there will have to be cattle movement across the road to land on the south for grazing and milking. As the applicant is the landlord for the Agricultural Tenancy then the MPA would request a joint statement of the likely impact and number of such agricultural movements on the safety of the public highway. If it is the case that this will happen as a result of the proposal then the impacts should be factored into the safety assessments and traffic calculations.
The new route would include a proposed cattle crossing on the B3174 Exeter Road. The number of daily movements over the proposed cattle crossing at times when the dairy herd is grazing the land south of Exeter Road would be twice in each direction.



The MP got involved. The Leader of Devon County Council advised Hugo Swire MP in 2018:
...the applicant was also asked to provide a joint statement with their tenant with relation to farm crossing movements and how they might be managed.
However (and with this application there’s always a however) neither "a joint statement" or "safety assessments and traffic calculations" have since been provided. More on the latter in a future post, but on the former, as recently as February of this year, Revision C of the Transport Assessment did contain a joint statement, authored by Aggregate Industries but unsigned:
3.2.4 At the request of the Mineral Planning Authority a Joint Statement has been prepared which reproduces the information provided by the Tenant Farmer above and outlines the commitment of Aggregate Industries UK to the proposed mitigation that will negate the need for additional livestock movements across the public highway that currently forms the baseline, a copy of this statement is reproduced within Appendix E for reference.
3.2.5 Although the purpose of the Joint Statement is to assist in formalising the information already provided by both parties the Tenant Farmer has been advised by their Solicitor and Agent not to sign the document. However, the fact that the document has not been signed does not detract from the validity of the baseline information supplied to date by the Tenant Farmer.
Since then, Aggregate Industries has had that unsigned joint statement removed, to be replaced in Revision E with a no-more-binding email instead. The company’s TA now says:
1.1.8 It has been agreed with the Tenant farmer that by the provision of new cow tracks, access points and other appropriate infrastructure, preceding or in parallel with the quarry development, that there will not be a need to intensify livestock crossings over the B3174 Exeter Road above that already stated as the baseline.
1.1.9 The Applicant, Aggregate Industries UK, will work with any current or future operator of the farm to maintain sufficient grazing such that livestock crossings will not need to increase above the baseline stated within the email from West Country Rural Ltd.
That referenced email concludes by saying:
In the event that no cow tracks were installed at Straitgate, and in time that no additional cubicle housing were erected to house the dairy herd these movements would need to occur daily.
So, to be clear: When Aggregate Industries says "it has been agreed", it has not. Aggregate Industries is just relying on a third party email. There is no agreement, no signature, no signed joint statement of the type promised to our MP.

So, to be clear: When Aggregate Industries says "other appropriate infrastructure" – cubicle housing, or whatever – the TA is not offering to supply that.

So, to be clear: When Aggregate Industries says "maintain sufficient grazing", Phase 1 alone of any quarry would take away 56 acres, which – according to 3.4.10 of Aggregate Industries’ Supporting Statement – would not be restored until Phase 3:
Initially, the applicant will need to resume some 22.5ha to facilitate the first stage of the proposed development (Phase 1). In addition to the area required for mineral extraction, this area will include the land required for temporary soil storage bunds and access. 2.1.10
But more of that another day.

So, if land is taken away for quarrying, it goes without saying that the farmer – to maintain a viable operation – would have no choice but to regularly take the cows to the other side of the road for replacement pasture, cows that would need to be returned to the parlour to be milked, crossing the B3174 Exeter Road up to four times a day in the process. It's what farmers do elsewhere in the county, and the country – see the post below.

Where does that leave us? At the end of September, Devon County Council – following advice from their Highways Management department – wrote to Aggregate Industries saying:
The application needs to include the proposed agricultural access (TA 5.5.10) to the west of the existing farm access and directly opposite the existing field gate, to improve upon the current diagonal crossing point. That would enable a shorter traverse of the highway by livestock, effectively reducing crossing times. The Highway Authority also considers that these proposals should include holding pens on both sides of the road to assist in the efficient movement of the livestock. It appears that this would be a betterment of the existing situation and is related to the proposed mineral working based upon the worst case scenario of the available cattle movements, as put forward (TA 3.2.3) in the email from the Tenant Farmer [sic] to the Mineral Planning Authority dated 26 February 2018. The inclusion of the above is, we believe, outside of the application site and therefore it would possibly require a resubmission of the application to include it. However we do not believe that it is sufficient for the applicant to merely offer this to the Tenant Farmer and the Highway Authority without any means of the MPA being able to condition it.
Of course, Aggregate Industries does not control any land to the south of the B3174 that could be used for "holding pens" and be part of its planning application. What’s known as a Grampian condition would be needed: "a planning condition attached to a decision notice that prevents the start of a development until off-site works have been completed on land not controlled by the applicant." Devon County Council’s solicitor advised the Council’s head of planning by email that "the conditionality of the Grampian must be within the applicant’s gift to deal with, and there must be a reasonable prospect of so doing." So, that’s another complication.

And that’s where – more than two years on – we stood at the end of September, the date of our FOI, regarding just one of the issues raised by this contentious application.

Clearly – and for such a busy and fast road – this is something that needs to be carefully assessed before determination, otherwise we could end up with situations similar to this: