Devon sand & gravel sales in 2023: lowest on record – down 29% on previous year

Oh dear. Pity poor Holcim UK (formerly Aggregate Industries). 

In the very same year the company finally won permission to quarry Straitgate Farm after a near decade-long struggle, the bottom fell out of Devon’s aggregates market, and sales of sand and gravel slumped by an eye-watering 29% – down from 521,000 tonnes to just 370,000 tonnes. 

What terrible timing. 

The recently published South West Aggregates Working Party Annual Report 2023 says: 

Devon’s sales of sand and gravel have remained fairly consistently around the half million tonne mark since 2011. Prior to 2023, 2020 had seen the lowest figure of the decade with sales of 0.437mt (possibly attributable to the effects of the Covid pandemic) whilst 2021 saw a rise back up to 2018 levels, with a sales figure of 0.54mt. 2022 sales remained on a similar level with a sales figure of 0.52mt but 2023 witnessed a fairly dramatic drop down to 0.37mt taking over from 2020 as the lowest figure of the decade by a reasonable margin. 

However, the trend has been clear for a long time.

 

No wonder the company said it would need to mothball Straitgate Farm immediately following implementation of the planning permission. 

Why such a dramatic fall in the county’s sand and gravel sales? The same report says: 

2.23 Devon has suggested that the decrease in sales this year is a result of the economic uncertainty brought about by market volatility, worldwide events and the pandemic, which the UK economy is still recovering from. 

But that hardly explains a 29% slump, when sales of recycled aggregates, crushed rock, and secondary aggregates in the county fell by a far more modest 9%, 5%, and 2% respectively in the same period. 

The 29% fall is noticeably more than in the South West as a whole, where sales fell by 18%:

In 2023, aggregate sales of land won sand and gravel in the region totalled 2.26mt, a decrease from 2022’s sales figure of 2.75mt

The contrast is even starker nationally. The MPA’s 11th Annual Mineral Planning Survey Report says that in 2023 across the country, “land-won primary aggregate sales decreased by 5.3%”, with sand and gravel down 7.1%. 

So why 29%? As the largest producer of sand and gravel in the county, was part of the decline self-inflicted? Did Holcim UK drop the ball? Could its prices for instance be too high? 

And what prospect now for expensive HVO-fuelled 2.5-million-mile haulage schemes? How will the market ever tolerate that? 

Things have not improved across the country since 2023. In February this year, the MPA reported: 

...ready-mixed concrete, ubiquitous to all types of construction projects, faced a 10.8% annual decline in 2024, reaching its lowest level in over 60 years. Primary aggregates sales declined by 2.6%, with sand and gravel particularly impacted due to weak demand from the struggling ready-mixed concrete market, where it is mostly used. 

The heady days of the 80s and 90s, when sales of unsustainable primary virgin land-won sand and gravel exceeded a million tonnes a year, are fortunately long gone. Now the more sustainable alternatives of secondary and recycled aggregates are taking over. Just in the last 10 years, the trend has been only one way, as the graph below shows. In Devon, land-won sand and gravel is now out-sold by both secondary and recycled aggregates, having gone from being 39% of the mix to just 26% – a trend we previously pointed to here and here.

‘We don’t just talk the talk’ – Really?

In promoting the rebrand from Aggregate Industries, Holcim UK – with seemingly little left in the marketing pot – is proud to tell you about its sustainable billboard:

 

View this post on Instagram

A post shared by Holcim UK (@holcim_uk)

But, let’s not be too harsh – the rebrand to Holcim UK is apparently "a really clear signal of intent of our commitment to a sustainable future."

Why the name Holcim should signal such intent is anybody’s guess; Holcim – the world’s largest cement company – is one of the biggest greenhouse gas emitters on the planet. 

However, the rebrand goes further, allegedly offering a chance for the company to revitalise its Place for Nature campaign – in part "to create a space for our colleagues to sit and enjoy and be part of nature whilst at work". Yes, seriously. 

Isn’t that comforting to know – as company bulldozer drivers up and down the country rip up existing wildlife habitat, like the ancient hedgerows due to be grubbed up at Straitgate? The company says: 

A strategy must be for the employees as much as the employer, and it’s vital they feel part of the overall sustainability journey. For us, that meant providing individual areas of ownership, a key element of which is creating ‘a place for nature’ across all our 200 sites nationwide.

How’s the plan going? The company’s latest sustainability report tells us: 

We developed 29 places for nature in 2023 which fell short of our target.

How hard can it be to put up a bird box or insect hotel?

Straitgate’s ‘revolutionary’ working scheme not being deployed at Penslade

Holcim UK (formerly Aggregate Industries) doesn’t intend to deploy Straitgate’s "revolutionary" working scheme at Penslade. 

For a scheme that allows more material to be recovered, isn’t that funny? How many aggregate companies would forgo another metre's depth of material given half a chance? 

For the company’s new application for Penslade – where there are few people nearby wholly reliant on private water supplies: 

4.1.3 The base of mineral extraction has been set at 1m above maximum recorded groundwater levels. 

One metre. It’s as clear and simple as that, and the Environment Agency has already said it has no objection to the application. 

Oh, what a different story it has been for Straitgate Farm, where for 12 months back in 2015 the company wouldn’t even come clean that the base of mineral extraction has been set at 0m above maximum recorded groundwater levels – or at least an imprecise model of them – and that a "revolutionary" seasonal working scheme is to be deployed: As we posted at the time: 

AI's seasonal working scheme has now been described as "revolutionary"; not by us, but by someone on the other side closely connected to all this. 

How exciting! Local people will be thrilled. Thrilled at the prospect of being part of an experiment, where their drinking water supplies are reliant on the success of this "revolutionary" scheme; a scheme that relies on groundwater levels falling over the summer months to allow AI to quarry down to the maximum water table level, rather than leaving the 1m unquarried buffer above the maximum water table typically employed to safeguard surrounding water supplies.

So, a 1m buffer is to be retained at Penslade to protect the water environment, whilst a 0m buffer is to be retained at Straitgate – where there are more than 100 people reliant on private water supplies, as well as farms and businesses. 

No, it doesn’t make any sense to us either. 

It’s a story we won’t dredge up again, although it has been covered in these posts from 2015 to 2018 for anybody at all interested: 

Clarification from the EA 

How many AI suits does it take to have a meeting with the EA? 

Finally, in writing, how AI thinks it can wrestle 1.2 million tonnes from Straitgate 

AI was asked a very simple question

No wonder AI wants to keep Straitgate’s groundwater data secret

 

Aggregate Industries rebrands as Holcim UK

Today, Companies House filings confirm that Aggregate Industries UK Limited has changed its name to Holcim UK Limited – aligning with its Swiss-based parent, which acquired the company in 2005.

EDIT 17.3.25 Holcim UK claims it is set on a "new strategic direction" which will see the business "align more closely with its Swiss-based parent company":

Holcim UK’s strategy will see the organisation target significant growth in sales and sustainability – with particular focus on decarbonisation, circularity and nature... etc etc

No doubt, we'll all be watching to see whether the walk matches the talk.

Let's at least hope there's a focus too on maintaining proper warning signs for cyclists – given there clearly wasn’t on the truck used for the publicity shots.

 

In a line reminiscent of the film Love Actually, Lee Sleight, CEO of Holcim UK, said:

Our evolution from Aggregate Industries to Holcim UK is much more than a rebrand.

Brazil mining dam disaster: Trial concludes in UK’s largest class-action lawsuit

The trial over damages from the 2015 Mariana mining dam disaster in Brazil has concluded. The dam was owned by Samarco, a joint venture between Brazilian mining firm Vale, and Anglo-Australian BHP. Previous posts on tailings dam collapses in Brazil can be found here. 

More than 600,000 Brazilians, 46 local governments and about 2,000 businesses are suing BHP over the disaster in a lawsuit worth up to £36bn. 

The lawsuit, one of the largest in English legal history, began in October and ended on Thursday with closing submissions. 

“I will produce a judgment as soon as I can,” the judge, Finola O’Farrell, said as she announced the end of the trial.

A trial to decide Australian mining giant BHP's liability for one of Brazil's worst environmental disasters concluded in London on Thursday, with hundreds of thousands of victims demanding billions in compensation @CorpusculO https://t.co/VCfbzYgNw7

— AFP News Agency (@AFP) March 13, 2025

London trial concludes in largest ever UK group action — more than 600,000 Brazilians, 46 local governments and 2,000 businesses are suing BHP over Brazil dam disaster in lawsuit worth up to £36bn. https://t.co/IM92NOh7qZ

— Glaspell — Class Actions (@Glaspell) March 14, 2025

Aggregate Industries’ Straitgate update for February – still awaited

With just 10 months to go before Aggregate Industries’ permission to quarry Straitgate Farm expires, and with monthly monitoring of Private Water Supplies currently ceased in breach of its Unilateral Undertaking legal agreement, and with no sign of the revised site entrance plans called for last July, or even the exploratory investigations required beforehand, and with infiltration tests to verify the surface water management plan still waiting to be done, and the four boreholes planned for last summer still to be drilled, and a multitude of schemes to meet pre-commencement conditions still to be agreed with Devon County Council, and with an application to quarry 3.9 million tonnes of sand and gravel at Penslade next to Hillhead now validated by Devon County Council, has the company lost interest in Straitgate? 

It is certainly staying very quiet. 

Aggregate Industries had agreed to provide monthly updates of its progress, in relation to implementing its permission to quarry the site. 

Last month, the company anticipated being in a position to provide an update at the end of February, having reported nothing new since the beginning of last September. 

No update has been forthcoming – despite a reminder sent to Aggregate Industries a week ago. 

Devon County Council has also been kept in the dark. 

Any update provided by the company will be posted here, as and when received.

Glendinning wash plant ‘reduces reliance on imported sands’

In 2021, a planning application by Glendinning to extend Linhay Hill Quarry, a limestone quarry near Ashburton adjacent to the A38 in the Dartmoor National Park in Devon, was approved by the Dartmoor National Park Authority – as we posted about here. 

Last week, it was reported that the site’s main wash plant has been upgraded: 

Creating various limestone aggregates from 6mm to 20mm, the site also produces 0-4mm washed, crushed aggregate fines (black concrete sand). This black sand is mixed with traditional china clay sand, before being used in ready-mixed concrete at the firm’s plants within the quarry and in nearby Plymouth and in Exeter. 

By being able to use a larger percentage of the black sand within the ready-mixed concrete plant, Glendinning have been able to reduce their reliance on imported sands, lowering their carbon footprint and reducing truck transport on local roads.

Articles from the February 2025 issue Quarry Management are now available to view on Agg-Net - https://t.co/9ZnL5Bz2TC - Site report on new PowerX Equipment wash plant at Glendinning’s Linhay Hill Quarry; Screens & Grizzlies; Institute of Quarrying; Special reports pic.twitter.com/0G4DNhg7PX

— Agg-Net (@aggnetweb) March 6, 2025

Aggregate Industries submits planning application to extend Hillhead Quarry

Aggregate Industries has submitted a new planning application to quarry sand and gravel in Devon – despite not yet implementing its permitted plans to quarry Straitgate Farm, and despite complaining that current economic conditions mean its plans for Straitgate may need to be mothballed. 

Today, Devon County Council validated the company’s application to quarry land south west of Penslade Cross, DCC/4424/2025, an extension to its quarry at Hillhead near Uffculme, that is expected to yield 3.9 million tonnes of saleable sand and gravel over a 13-year period: 

Proposed extension of Hillhead quarry for the winning and working of sand and gravel with restoration using imported inert fill, inclusive of a new internal haul road and the retention of the existing mineral processing facilities

The land is owned by Aggregate Industries, and has the same type of material that underlies Straitgate. In total, there are thought to be some 23 million tonnes at Penslade, 8 million tonnes of which are allocated in the Devon Minerals Plan. The site sits a short distance from the company's processing plant. 

Aggregate Industries’ planning application for Penslade has been expected for some time. In 2021, the company was granted permission to drill boreholes around Penslade to monitor the watertable. At the Straitgate appeal, it became clear that the company had told Devon County Council that an application would be submitted in 2023. However, only in September 2024 did the company issue a newsletter inviting locals to a drop-in event the following month to publicise its plans.

 

In this newsletter, the company reminded us – despite having won permission to quarry Straitgate – that: 

Hillhead Quarry is the main source of sand and gravel in Devon and is Aggregate Industries’ only sand and gravel quarry in the south west.

The proposed Hillhead extension is identified as a minerals allocation in the Devon Minerals Plan as the replacement resource for the existing Hillhead sand and gravel quarry, which on current production rates has permitted reserves until c. 2028/9. We are starting the planning process for our Hillhead extension now in order to allow sufficient time to enable an orderly and planned transition of mineral working to the new extension area to take place in c.2028/9. 

Clearly any material won from Straitgate in the intervening period – which is only permitted to be processed at Hillhead – does not figure in those timescales. Earlier this year, the company won permission for another 460,000 tonnes of sand and gravel at Hillhead, which will see it through until this new application is decided. 

Ever since Aggregate Industries moved its sand and gravel processing operation to Hillhead back in 2018 – after it was forced to move its operations away from Blackhill on Woodbury Common, part of the East Devon Pebblebed Heaths in the East Devon AONB – it has made economic and environmental sense to source raw material closer to the processing plant. It made no sense to source material from Straitgate, 23 miles away. Given we have a new application for Penslade, alongside the as yet unimplemented permission for Straitgate, perhaps the penny has finally dropped. 

At the Public Inquiry deciding the fate of Straitgate – with its barely 1 million tonnes – the Planning Inspectors chose to ignore the 23 million tonnes of sand and gravel sitting at Penslade, arguing there was "a shortage of sand and gravel in Devon", and writing: 

82. Although development of the allocated site west of Penslade Cross would contribute significantly to supply, there is no immediate prospect of this coming forward, and our decision must be based on the current situation with respect to sand and gravel supply.  

137. We have already noted that there is little prospect of the allocated site at west of Penslade Cross coming forward in the near future. Therefore, any advantage that that site would have over the appeal site in terms of its proximity to Hillhead Quarry is not material to our decision.

Even Aggregate Industries chose to forget there was any gravel in the fields around Hillhead, when it was trying to win permission for Straitgate. At the time, we posted AI’s greenwash document assumes no gravel at Hillhead, not 25%, not 5%, not any!

And yet, just two years on, a planning application for Penslade has indeed come forward – as we all knew it would – which is expected to provide enough material for years to come. 

So, clearly, there is no shortage of sand and gravel in Devon, and – as we have argued for the last two decades – zero need for mineral from Straitgate Farm.

UK construction activity falls at fastest pace since 2020

UK construction PMI falls to lowest since 2020 as house-building plummets https://t.co/4oSowP6mrv pic.twitter.com/C54ZcnOAXy

— Reuters (@Reuters) March 6, 2025

MPA: ‘Road ahead remains uncertain and peppered with potholes’

The Mineral Products Association – the trade body representing Aggregate Industries et al. – has recorded an uptick in sales of construction materials in the final months of 2024, but notes: 

Despite these encouraging signals, the MPA data also underscores the severity of the construction slowdown over the past two years and the major challenges facing the £22 billion mineral products industry. For example, annual mortar sales fell by 15% in 2024, dropping below 2 million tonnes - some 28% lower than their 2022 peak of 2.7 million tonnes. 

Similarly, ready-mixed concrete, ubiquitous to all types of construction projects, faced a 10.8% annual decline in 2024, reaching its lowest level in over 60 years. Primary aggregates sales declined by 2.6%, with sand and gravel particularly impacted due to weak demand from the struggling ready-mixed concrete market, where it is mostly used. 

Aggregate Industries’ Straitgate update for January

Aggregate Industries has today provided the following update in relation to implementing its permission to quarry Straitgate Farm: 

I don't have anything to report at this time, but anticipate that I will be in a position to provide you with an update at the end of this month.

Previous monthly updates from the company can be found here.

AI’s Planning Manager overseeing Straitgate leaves the company

A new year – yet another in this long-running saga – and another person responsible for Aggregate Industries’ attempts to quarry Straitgate Farm has moved on to pastures new. 

Chris Herbert, Planning Manager South, has, we have been informed, left the company to pursue new opportunities. 

Over the last five years, Chris has been tasked with overseeing the company’s efforts to firstly win planning permission from Devon County Council, and then, when that failed, to appeal the refusal, and then, when permission was finally – and, to some, surprisingly – granted by the Planning Inspectorate, to implement the heavily-conditioned permission. 

It was Chris who provided us with monthly updates on the company’s progress in relation to implementing the permission. Today, Aggregate Industries said "we have no further update at this time."  

The company has until 5 January 2026 to implement its planning permission for Straitgate. 

Many personnel at Aggregate Industries have come and gone over the many years that we have been striving to save Straitgate. For instance, the company fielded three representatives at the Development Management Committee meeting in December 2021, when permission was originally refused. For whatever reasons, all three – the other two here and here – have now left the company. 

Could the last Aggregate Industries' person leaving the Straitgate project kindly turn out the lights?

Merry Christmas

Another year has passed, and even though Aggregate Industries won planning permission to quarry Straitgate Farm almost two years ago – after a decade-long effort – the company has still not recovered a single bucket-load of that oh-so-precious sand and gravel from the site.

Having achieved little over the last 2 years, the company has left itself much to do in the next 12 months if it is to implement the permission before it expires on 5 January 2026. 

For instance, it must: 

• have a raft of schemes to satisfy pre-commencement planning conditions approved by Devon County Council;
• evict the dairy farm tenants – whose family has farmed at Straitgate for nearly 100 years – to overcome the expired cattle crossing permission and to achieve the enhanced biodiversity net gain figures required; 
• design a workable site access scheme to fit in the narrow space between the two TPO’d oak trees and the third party hedgebank; 
• design a surface water management plan – based on a series of yet-to-be-performed and results-far-from-certain infiltrometer drainage tests – that will not risk creating any prohibited-by-planning-conditions bodies of water, noting how problematical surface water management is currently proving for the company at Hillhead; 
• drill 4 new boreholes, install piezometers, and complete 12 months of baseline monitoring from them; 
• correct some of its water monitoring programme, and complete 12 months of accurate baseline monitoring; 
• and more... 

And yet – as the company made clear earlier in the year – Aggregate Industries currently has no appetite to work the site, given the economic outlook and the costly HVO-fuelled multi-million-mile haulage plan. 

During the year, however, Aggregate Industries did find the motivation to apply to quarry another 460,000 tonnes of sand and gravel – the same sort of sand and gravel that underlies Straitgate – at its Houndaller site next to its processing plant at Hillhead Quarry near Uffculme, that, according to the company, will see it through to the end of 2029: 

The current estimate completion date for extraction [at Houndaller] is end of 2029 with completion of restoration and landscaping by 2031, this is based on an average production rate of 350,000 tonnes per annum.

Although, judging by the figures, Aggregate Industries has in fact been producing sand and gravel at Hillhead over the last few years at the reduced rate of just 250,000 tonnes per annum. At that rate, Houndaller’s reserves would last another 8 years or so. 

So, no wonder Aggregate Industries doesn’t really seem that bothered with Straitgate.   

But such mineral talk is very un-Christmassy, so, to finish off the year on a lighter note, here’s a popular Christmas carol – with a Straitgate twist and themed scene to match – courtesy of the other sort of AI: 

– Verse 1 –


Dashing through the woods,


Where the oak trees proudly stand,


Dormice make their homes,


In this precious, thriving land.


But here comes a plan,


To tear it all away,


We’ll raise our voices loud and clear,


To keep destruction at bay! 

– Chorus –


Stop the quarry, save the trees,


Let the dormice play,


Drinking water’s under threat,


Don’t wash it all away! 


Stop the quarry, save our springs,


Nature’s worth the fight,


Protect this land for future dreams,


And keep our future bright! 

– Verse 2 –


The oak trees stand so tall,


With roots both deep and true,


They’ve weathered years of storms,


Don’t let them fall for you.


The dormice need their space,


The water must stay clean,


No digging here, no dusty trucks,


Let Devon stay serene! 

– Chorus –


Stop the quarry, save the trees,


Let the dormice play,


Drinking water’s under threat,


Don’t wash it all away!


Stop the quarry, save our springs,


Nature’s worth the fight,


Protect this land for future dreams,


And keep our future bright! 

– Verse 3 –

Devon’s land is rare,


A treasure we must guard,


With ancient oaks and wildlife here,


Destruction hits so hard.


The drinking water’s pure,


A gift we must defend,


No quarrying should take its toll,


This harm must have an end! 

– Chorus –


Stop the quarry, save the trees,


Let the dormice play,


Drinking water’s under threat,


Don’t wash it all away!


Stop the quarry, save our springs,


Nature’s worth the fight,


Protect our home for all to share,


And keep our future bright! 

We wish all readers a Merry Christmas and a Happy New Year.

Aggregate Industries’ Straitgate update for November

Shortly after Aggregate Industries received planning permission to quarry Straitgate Farm, the company agreed to provide monthly progress updates. 

It has not been an onerous task – as previous updates demonstrate. 

A gentle reminder was sent to Aggregate Industries earlier this month. The response? 

Any update provided by the company will be posted here, as and when received.

EDIT 17.12.24

There are no updates this month.

AI’s Hillhead surface water management plan – more dodgy assumptions?

Flooding can have a devastating impact on communities. Not only can it cause damage to property and possessions, it can cause injury and death. The Met Office says we should expect an increasing frequency of extreme rain: 

…research, published in Nature Communications, found that under a high emissions scenario (RCP 8.5) rainfall events in the UK exceeding 20mm/hr could be four times as frequent by 2080 compared to the 1980s.

Managing flood risk is therefore an important business. Council’s trust consultants to get the figures right. 

Last month, Aggregate Industries submitted further information to Devon County Council in relation to its planning application DCC/4399/2024 for Hillhead Quarry near Uffculme, which is in part to deal with the quarry’s ponding problems.

 

In its revised surface water management plan for the site – where "all surface water will be managed in the former extraction area, with Houndaller Pond only acting as an exceedance route" – Aggregate Industries’ water consultants BCL Hydro – the same crew working on Straitgate – made a big assumption: 

The fact that [Houndaller Plantation] pond can sustain long-term and regular abstraction… means that it would be similarly effective as a soakaway.

We questioned this claim in the post AI sense-checks AI... and its soakaway assumptions at Hillhead, and wrote to Devon County Council saying: 

There remains, therefore, no cogent evidence – measurements or otherwise – of the soakaway capacity at Houndaller Plantation Pond. It is wrong to assume that Houndaller Pond would be “similarly effective as a soakaway”, and therefore it does not necessarily ‘follow’ that Houndaller Pond could cope with exceedance flows from a storm event.

But there appeared to be other wild assumptions put forward by Aggregate Industries’ water consultants too. As we set out to Devon County Council:

... it appears that the applicant’s revised plans have not allowed sufficient storage space within the extraction area for the design storm event: 

The applicant claims “the ASV [Attenuation Storage Volume] requirement equates to 3,350 m3 during the design event (1 in 100-yr + 45% allowance for storm intensity due to climate change)” and that “the revised surface water management plan for Houndaller (by incorporating 3,416.60 m3 within the former extraction area) will provide sufficient storage space for the design event.” 

The applicant claims runoff rates and attenuation requirements were computed using “the assumption that 12.75 hectares [127,500m2] of the catchment area would possess runoff characteristics analogous to that of an impermeable paved surface.” The applicant has not provided any output from those computations to substantiate the conclusions. 

An ASV of 3,350m3 divided by the impermeable catchment area of 127,500m2, implies the applicant has modelled for a rainfall event of 0.0263m or 26.3mm. 

This would seem to be an inadequate figure, given the historic records for nearby areas: 

“June 1946 In Cullompton, 2.35 in [60 mm] of rain fell in 45 minutes and ... in the lower part of the town flooding was 3 ft deep in houses.”

“22 October 1960 Flooding occurred in Crediton, following a total of 64 mm of rain on 20 and 21 October (recorded in Exeter)” 

“21 November 2012 Between 20mm to 39mm (0.8in to 1.5in) fell in 12 hours overnight on already saturated ground.” 

https://www.middevon.gov.uk/media/345917/appendix-j-historic-records-of-flooding.pdf 

The University of Exeter Weather Observation Records has the Highest Daily Rainfall at 47.20 mm on 4 September 2024.

https://empslocal.ex.ac.uk/uoeweather/records/ 

The UK’s wettest day, in records back to 1891, was 3 October 2020. The average rainfall across the entire UK was calculated at 31.7mm. The Met Office says record-breaking rainfall like that seen on 3 October 2020 could be 10 times more likely by 2100.

https://www.metoffice.gov.uk/about-us/news-and-media/media-centre/weather-and-climate-news/2021/record- breaking-rainfall-more-likely-due-to-climate-change 

Using the FEH22 rainfall depth-duration-frequency model for that area, 26.3mm is less than a 1-hour, 30-year event; by contrast, a 12-hour, 100-year event would exceed 90mm.

https://www.ceh.ac.uk/sites/default/files/2023-05/FEH22_rainfall_depth-duration_frequency_%28DDF%29_model.pdf 

A 90mm rainfall event, with the same impermeable catchment area of 127,500m2, would require a much larger storage capacity of 11,475m3...

When it came to Straitgate Farm, consultants Amec Foster Wheeler, writing Aggregate Industries’ Flood Risk Assessment, modelled for a lesser 1 in 100-yr storm event + 10% climate change, and reckoned that across the 25.61ha (256,100m2) site, a total volume of 19,054m3 was required to attenuate runoff. Dividing the latter by the former implies a 74.4mm rain event was modelled for, or 67.6mm excluding the 10% climate change uplift. Assuming Hillhead, 23 miles away, is prone to the same level of storms as Straitgate, then adding back a +45% climate change allowance, means that the surface water management plan for Hillhead needs to accommodate runoff from a 98mm storm event – or in old money, nearly 4 inches of rain. 

So why BCL Hydro has only modelled for a not-uncommon 1-inch rain event is anybody’s guess. 

Given that there are now a series of questionable conclusions from BCL Hydro – here, here and here – local people would be forgiven for having little faith in whatever surface water management plan eventually emerges for Straitgate Farm.

EDIT 17.1.25 Devon County Council issues Planning Permission for DCC/4399/2024 with conditions

AI seeks to delay Chard Junction Quarry restoration in Dorset AONB – again

Aggregate Industries’ planning application to extend its Chard Junction Quarry – a development that would have caused considerable harm to the Dorset AONB for the sake of a relatively small amount of decorative stone – was refused in September 2021 by Dorset Council, and, after the company appealed the decision, again in October 2022 by the Planning Inspectorate. 

The extant permission WD/D/20/000313 was "limited to the period ending 31 March 2023":

Reason: To safeguard the natural environment and amenity of the local area and to ensure the timely restoration of the site in accordance with Policies SSI (Presumption in favour of sustainable development), RS1 (Restoration, Aftercare and Afteruse of Minerals Development) and DM4 (Protection and Enhancement of Landscape Character and the Countryside) of the Bournemouth, Dorset and Poole Minerals Strategy. 

But that wasn’t enough for Aggregate Industries. 

In February 2023, the company submitted a planning application P/VOC/2023/00946 "seeking a time extension until the 31 December 2024 in order to complete the restoration of Chard Junction Quarry", blaming in part its failure to stick to the existing planning condition on "adverse weather conditions". 

The Officer’s Report explained:  

5.4 … given that permission WD/D/20/000313 lapsed on 31 March 2023, and that application WD/D/19/000451 was refused, for the operator to fulfil its obligation in restoring these areas, they are now proposing to vary the requirements of condition 3 (Duration of the development permitted) of Planning Permission WD/D/20/000313, to extend the end date to 31 December 2024, in order to have further time in which to restore the site. 

The Dorset AONB Team commented: 

Whilst our clear preference would be for the timely completion of restoration in line with the planning consent, we do not feel it appropriate to object to the requested extension of time. We recommend that the Council carefully examine the reasons for a time extension and reach an opinion as to the reasonableness of this in relation to the circumstances. 

Dorset Council duly granted permission for the extension in May 2023. 

But we all know by now that Aggregate Industries rarely does what it says it will. 

Last month, the company submitted yet another planning application P/VOC/2024/06538, requesting yet another extension of time, this time blaming National Grid: 

We are therefore seeking to vary Condition 1 of the Permission to extend the end date for completing restoration of the site to the 31 December 2025. 

Please be assured that the company remain committed to the completion of the restoration of this site and the delay that has caused this application has been due to matters entirely outside of our control.

AI’s water monitoring at Straitgate being undertaken incorrectly at several properties

To win permission to quarry Straitgate Farm, Aggregate Industries entered into a legal agreement to monitor the private water supplies of surrounding properties for the lifetime of the development. 

Part of this agreement also stipulates that 12 months of chemical analysis of water supplies be performed before any quarrying starts, to produce a baseline so that any potential changes in groundwater quality from future mineral workings can be detected. 

Aggregate Industries’ water consultants BCL Hydro are now nine months into this monitoring period. 

In an email to us last month, the consultants confirmed that all the samples taken for analysis are "untreated groundwater". 

It stands to reason. Chemical analysis is meant to provide an accurate baseline of the natural quality of the groundwater, not a baseline that is masked or altered by treatment systems. 

It now transpires, however, that "untreated groundwater" is not what’s being sampled from at least three of the 19 or so properties being monitored. 

It looks like Aggregate Industries and its consultants have fallen at the first hurdle, before any quarrying has even started. 

The nine months of data collected from these properties is invalid. The owners do not have the protection afforded to them by an accurate 12-month baseline of untreated groundwater data, independent of their treatment process, to evidence any potential future claim for "derogation, contamination or interference" to their supply. 

Devon County Council has been informed.

Another quarry accused of disrupting water supplies

In 2016, we posted Look what happens when a quarry company is accused of polluting a couple's drinking water supply: 

...everything changed and it was clear the spring had been contaminated because the water was coming out brown and dirty...[which] coincided with the operators of the quarry near our home being served with statutory notices for quarrying outside their permitted area

Now, it looks as though it’s happened again elsewhere, allegedly caused this time by Dareduff Hill Quarry in East Ayrshire to a home in East Renfrewshire. 

According to GlasgowLive: 

Ali says part of the planning agreement carried conditions that her private water supply would be protected - but already, she says, it has been affected. 

She said: "It's basically an ancient spring out of the ground, where you won't get any planning that says where it comes from, because nobody knows - but it's been here for as long as this building has been up, for hundreds of years. 

"The water goes naturally into a tank that's in the ground. This farm used to be a dairy farm, so it supplied this whole place with water. And it's never been a drama. I only ran out of water once years ago when we had a big drought. It all works fine, it's dead old-fashioned but I've never wanted to or had to change it. 

"So while this proposal was going on, I had contacted MPs. I contacted Planning and everyone has ignored me, nobody's done anything. On the back of that, both East Renfrewshire Council and East Ayrshire Council are going to get 7p a ton from the aggregate that's taken out of this quarry, so there's money involved for the councils too." 

She added: "They've now started the digging. I wasn't informed about it at all. 

"Part of the concessions that were approved in the planning stage was that the water at this farm [West Carswell Farm] had to be sorted, and that West Carswell was either to be connected to the mains or some other solution. But nothing's happened."

Ali said plumbing experts believe disturbance to the ground from the launch of the quarry works may have put “muck” in the water with the silt clogging old pipes. She added: "There's water in the tank... but there's no water getting to my property."

As we said back in 2016: 

At Straitgate, water supplies for 100 people, 3 farms and Grade I Cadhay would be in the hands of one digger driver. What could possibly go wrong? And - with an extensive catalogue of ignored warnings from local residents going back years - how many nationals would cover the story if it did?

 

Renfrewshire woman devastated as quarry works begin near dream countryside home.https://t.co/zWOHLHnXz1

— Glasgow Live (@Glasgow_Live) December 3, 2024

AI joint venture blames economic slowdown for quarry restoration delay

Wight Building Materials is a joint venture between Eurovia and Aggregate Industries. 

Last week, onthewight reported: 

Restoration work at an Isle of Wight quarry with tens of thousands of tonnes of fill material will continue for two more years following a council decision. 

In justifying its decision for Wight Building Materials’ Hale Manor Quarry, an officer wrote: 

The submitted information states that the downturn in the economy caused by rising interest rates and the cost of living over 2022/23 has caused the slowing rate of restoration for the quarry. Therefore, the restoration scheme cannot be completed by the 2024 deadline. 

Of course, it wouldn’t be the first time that a deadline linked to Aggregate Industries has come and gone. 

In the past, the word deadline meant something: 

a line drawn within or around a prison that a prisoner passes at the risk of being shot 

a line that does not move 

To Aggregate Industries et al., a deadline seems to mean nothing more than a guideline. 

But we mustn’t be too harsh. Aggregate Industries and other mineral companies are clearly feeling the economic pain – as was made perfectly clear to us earlier in the year, when a representative from Aggregate Industries explained why the company intends to mothball Straitgate Farm immediately following implementation of the planning permission.

EA issues Closure Notice to Walleys Quarry Ltd

In 2023, we posted about Walleys Quarry Landfill site in Silverdale near Newcastle-under-Lyme in Staffordshire, and the long-running battle by local people to Stop the Stink. 

Yesterday, the Environment Agency finally showed its teeth:

    

The Environment Agency has today, 28 November 2024, issued a Closure Notice to Walleys Quarry Ltd (WQL).

For full details of what this means visit: https://t.co/zNrm5r8P0I

— Env Agency Midlands (@EnvAgencyMids) November 28, 2024

Walleys Quarry landfill that is ran by @RedIndustries2 have today been issued with a closure notice!!! It's done!!!Thank you to to @AJogee for you and all your teams hard work. We've spent years breathing this poison, it's time we got a breath of fresh air #StopTheStink pic.twitter.com/r62RSwbPuO

— Stop The Stink (@StinkStopthe) November 28, 2024

Today is a good day for the people of Newcastle-under-Lyme.

Finally - after everything - a closure notice has today been issued to Walleys Quarry Ltd. #LoveNuL 🇬🇧🌹 pic.twitter.com/StH1f71hT3

— Adam Jogee MP (@AJogee) November 28, 2024

Rick Brassington, Field Hydrogeology, 5th Edition

Rick Brassington – a recognised authority on hydrogeology, winner of the Whitaker Medal, and author of various textbooks on the subject – has been a long-term opponent of Aggregate Industries’ plans for Straitgate Farm, warning that any quarrying would permanently damage the many surrounding water supplies. 

His arguments were no doubt instrumental in persuading Devon County Councillors to turn down Aggregate Industries’ planning application for the site on 1 December 2021. 

However, at the Public Inquiry in October 2022, in relation to one of the main areas of contention – groundwater, and the mechanism for water movement through the unsaturated zone, put forward by Rick and supported by the Council’s expert hydrogeologist, Paul Thomson, as well as much scientific literature – the Planning Inspectors thought they knew best:  

23. ...we are not persuaded that piston flow is the dominant flow mechanism in the BSPB or at the site... 27. ...we prefer the appellant’s model of rapid infiltration...  

Rick Brassington has now produced the Fifth Edition of Field Hydrogeology – his successful "Pocket-sized field workbook for students studying hydrogeology at undergraduate and postgraduate levels", published by Wiley. 

The Fifth Edition addresses some new topics, including – and directly relevant to the arguments at Straitgate – "Complicated flow rates through the unsaturated zone". 

In the Preface to this Edition, Rick writes: 

There were a number of small changes [in this edition] but the biggest new addition covers flow through the vadose [unsaturated] zone. This came about when I failed to explain this to intelligent people who had no knowledge of geology who decided that they would rather accept a simple picture of rapid recharge flow with the unrealistically high value for the hydraulic conductivity in the vadose zone rather than the complex system that nature has provided for us. You will have to read it to see what I mean; it is now at the end of Chapter 3.

We recommend Rick’s book to any budding hydrogeologists, and Planning Inspectors wanting to find out about the real world.

AI sense-checks AI... and its soakaway assumptions at Hillhead

In August this year, the Ministry of Housing, Communities and Local Government posted a blog titled Exploring the use of artificial intelligence to streamline the planning process:

Planning documents often contain vast amounts of valuable information, but accessing and using this data can be challenging. Artificial intelligence (AI) offers a potentially promising solution by efficiently processing and interrogating large volumes of data to extract key information and insights.  

Draft minutes of the October 2024 meeting of the South West Aggregates Working Party – a group referred to in this post – also talked about the use of artificial intelligence in the planning process, particularly in the analysis of consultation responses: 

EIW, LM and TB had recently attended a POS [Planning Officers Society] meeting. Various matters had been discussed including safeguarding, the Finch case (and adopting a cautious approach) and the use of artificial intelligence (AI) in the planning process, particularly in the analysis of consultation responses.

But artificial intelligence can work both ways, not only saving planning officers time in the analysis of hundreds or thousands of consultation responses, but also allowing Joe Public to sense-check consultants’ reports. 

Aggregate Industries has this month submitted further information to Devon County Council in relation to its planning application for Hillhead Quarry near Uffculme – DCC/4399/2024:

Variation of conditions 2, 4, 6, 7, 12, 19, 22 and 25 of ROMP permission DCC/3655/2014... to vary the phasing; landform; drainage; and restoration of the site. 

We had posted about this application earlier this year – here and here – which in part is to deal with the ponding problem at the quarry, and in part to deal with unsafe quarry faces – which would, fortuitously for the company, yield a further 460,000 tonnes of sand and gravel in the process. 

In June, we wrote to Devon County Council saying: 

We are concerned that the ES Chapter 9 Hydrological & Hydrogeological Impact Assessment Version 2 May 2024 for the above application is incorrect, more specifically that the calculated soakaway rate at Houndaller Plantation Pond of 5,000 m3/d is impossibly large. 

The soakaway rate being pushed by Aggregate Industries and its consultants – five thousand cubic metres per day, equivalent to 1.8 million cubic metres per year – was used to conclude that: 

5.8.8.7 ...Houndaller Plantation Pond has sufficient soakaway capacity for the design storm.

We pointed to a flaw in the author’s calculations, suggesting that the above assumption was incorrect. Devon County Council’s Flood Risk team objected to the application, and also asked for "Calculations for the current outflows from Houndaller Pond (abstraction / groundwater) to be submitted." 

Aggregate Industries has now fundamentally redesigned its surface water management plans: 

Following discussions at the site meeting held on 4th July 2024, an updated surface water management scheme has been prepared where, following mineral extraction operations, all surface water will be managed in the former extraction area, with Houndaller Pond only acting as an exceedance route.

Consultants have also had a stab at "Calculations for the Current Outflows from Houndaller Pond": 

AIUK abstracts water from the groundwater-fed Houndaller Pond in accordance with Abstraction Licence No. SW/045/0002/055. 

The quarry operator has confirmed that they make full use of this licence. The rate of abstraction is set at 14 l/s, equating to 50 m3/hr. The annual rate of abstraction comes to 180,000 m3/year. 

This abstraction activity is a sustained process, occurring day after day, and the average groundwater level contours (Figure 5 in BCL’s report) are only c.1 m below the maximum levels (Figure 6), showing that abstraction (drawdown) impacts on water level in the pond are relatively limited. 

The fact that the pond can sustain long-term and regular abstraction at 14 l/s means that it would be similarly effective as a soakaway. It follows that occasional input to Houndaller Pond as a result of storm runoff would not be expected to raise the long-term water level in the pond.

So Aggregate Industries' consultants now appear to have moved from a soakaway rate of 1.8 million cubic metres per year to one approximating just 10% of that. However, even that is a leap. 

Look at this claim again: 

The fact that the pond can sustain long-term and regular abstraction… means that it would be similarly effective as a soakaway. 

Is it correct? similarly effective? 

We asked Google’s artificial intelligence chatbot Gemini to assess the above paragraph for accuracy. One of the Points Needing Clarification or Improvement was: 

* "Similarly Effective as a Soakaway": 

While the pond can sustain the current abstraction rate, it's not necessarily directly comparable to a soakaway. A soakaway is designed to absorb and disperse water into the surrounding soil, while a pond primarily stores water. 

Could Gemini be hallucinating? 

We asked OpenAI’s ChatGPT instead: If a groundwater-fed pond can sustain long-term and regular abstraction would it be similarly effective as a soakaway? 

If a groundwater-fed pond can sustain long-term, regular abstraction, it could theoretically serve some functions similar to a soakaway, but there are important differences in design, function, and environmental impact to consider. 

* Soakaway: A soakaway is designed specifically to manage surface runoff, allowing water to percolate directly into the ground and recharge the groundwater at a controlled rate. It's typically used in areas where rainwater needs to be quickly drained to avoid surface flooding. 

* Pond: A groundwater-fed pond typically has a different purpose, such as wildlife habitat, aesthetics, or water storage. While it may lose some water through infiltration, its primary function isn’t to allow for rapid or direct infiltration into the subsurface layers like a soakaway…. etc etc 

It all sounds like common sense, but just to be sure, we also asked a human hydrogeology expert whether the pond would be similarly effective as a soakaway. He said: 

Not true. No. No. No. 

He explained that it is normally many times harder to get water into the ground than it is to take it out. 

So what are Aggregate Industries’ hydrogeologists playing at? A simple error? A wild assumption? Or just trying to hoodwink the council? 

The hydrogeologists working on the ponding problems at Hillhead, are the same ones working to implement Aggregate Industries’ permission to quarry Straitgate Farm, who will calculate infiltration rates and produce a surface water management plan for the site, a site that sits above flood-prone Ottery St Mary. It’s important they know their stuff, and worrying if they don’t.