All change again at the top of Aggregate Industries

No one can accuse Aggregate Industries of letting the grass grow under its executives’ feet. 

This week, the company appointed a new boss, Lee Sleight – previously Managing Director of the Aggregates division, and, coincidentally, first mentioned here only a few days ago. 

Mr Sleight is clearly happy to be the next in line to be called upon: 

It is a very proud moment for me to be chosen to lead this fantastic business.

Mr Sleight will be Aggregate Industries’ sixth CEO during the time in which the company has been trying to get its hands on the sand and gravel at Straitgate. 

Whether that says more about the turnover of bosses in this fantastic business, or just how many years the company has spent messing about trying to secure the relatively small amount of mineral on offer at Straitgate, readers can decide. 

Kaziwe Kaulule will replace Mr Sleight as MD of the Aggregates division.

‘Time to get Britain building responsibly’, says Aggregate Industries

A change of government has prompted all manner of press releases from the building industry this week. 

Both the Mineral Products Association, the trade body representing Aggregate Industries et al., and Aggregate Industries itself have responded to plans set out by the new Chancellor, Rachel Reeves, to overhaul the planning system and boost housebuilding. 

MPA Director of Public Affairs, Robert McIlveen, said: 

The Chancellor has wasted no time to get going, and we warmly welcome her decisions on housing and onshore wind, as well as hiring more planners. We look forward to such decisive action in other areas… 

We will be writing to key ministers in the coming days, stressing that planning reform for housing is just the first step, and that a similar approach of unblocking the planning system needs to be taken for mineral extraction, processing and freight. This is fundamental to growth, given the sector represents the largest material flow in the UK economy – over 1 million tonnes of raw materials and products every day. Mineral products make up a major part of the supply chain for housing and infrastructure, but our members face prohibitive constraints in the current planning and permitting system.

Lee Sleight, who this year became Aggregate Industries' latest Managing Director of Aggregate, said: 

As a leading sustainable building materials supplier within the UK, we are fully on board with this initiative and ready to support key areas such as house building, infrastructure and onshore wind. 

So far in 2024, the UK market has seen a concerning slowdown in both infrastructure projects and house building, with 24% less construction starts in the first quarter of 2024 compared with the previous year, and construction output in the housing sector 19% below 2019 levels in February this year. 

etc etc 

Without a doubt, the urgent steps which the Chancellor has laid out to kick-start economic growth are necessary and achievable, and we are poised ready for the challenge. However, taking house building as an example, the 1.5 million homes projected over the next five years will require vast amounts of materials.

A conservative estimate of just the concrete required for these homes could be 37.5 million cubic metres. For perspective, this equates to more than nine times the capacity of Wembley Stadium and underscores the importance of recycled materials. 

This is why it’s crucial we create a new blueprint for the Great British built environment. Aggregate Industries have ambitious plans to help achieve net zero and are adopting a circular economy approach across everything they do. 

The construction industry must responsibly embrace the Chancellor’s national mission for growth but can only achieve this by building in a circular and wholly sustainable way. This goes far beyond just minimizing waste. Effectively, we need to build new cities from the ‘urban quarry’ of our old stock, thereby conserving the precious resources of our island nation.

And, of course, no one would disagree with Mr Sleight’s apparent passion for the use of recycled materials and conserving the precious resources of our island nation – but this is the MD of the division of Aggregate Industries that has been fighting tooth and nail over the last 15 years to dig the life out of a relatively insignificant greenfield site in East Devon for precious unsustainable primary un-recycled materials, and to process them 23 miles away – a wholly unsustainable way. 

Aggregate Industries: Say one thing and do another.

Quarry companies – if at first they don’t succeed

For the second time, Brett Aggregates has appealed the decision by Hertfordshire County Council to refuse plans for an eight million tonne sand and gravel quarry on the site of the former Hatfield Aerodrome. A planning inquiry is due to start on 19 November and is scheduled to last for 10 days. 

The Planning Inspectorate refused the company’s previous application to quarry the site in 2022 – following a nine-day public inquiry – citing harm to the Green Belt, character, appearance and amenity of the area, as we have previously posted. 

Herts County Council has described the latest application as being "substantially similar" to the first.

What is it about the answer NO that quarry companies don't understand?

Quarry plan subject to second inquiry https://t.co/c48pHsvm5F

— BBC Beds, Herts & Bucks (@BBC3CR) July 11, 2024

Cumbria coal mine unlawfully approved, government says

The Government has admitted that a proposed coal mine in Cumbria – subject of these posts – was approved unlawfully, as the carbon emissions of coal from the mine should have been taken into account in the planning decision, the Guardian reported this week.

Sense at long last. How was it ever possible not to take account of the emissions from burning the coal ?!? It took a conspiracy of warped and disingenuous arguments to keep this crazy mine plan going for so long. Thank SLACC and FOE for fighting it. https://t.co/UTLbu9cPli

— Mike Berners-Lee (@MikeBernersLee) July 11, 2024

Anger as Aggregate Industries cuts hauliers’ rates

According to Motor Transport magazine, Aggregate Industries has blamed "extremely challenging" trading conditions for its decision to cut rates for hauliers: 

Hauliers working for Aggregate Industries (AI) have reacted with fury at a move by the company to chop its rates by 1.77% after blaming “extremely challenging” trading conditions. 

In a letter to its franchised hauliers, AI said they needed to accept “the reality of a weakening construction market” and so it was taking the difficult decision to cut its rates. 

It said fuel prices had decreased and therefore tipper haulage rates on standard work would be reduced by 0.52%. 

But AI also said it was cutting the rate by an additional 1.25% to reflect the current trading environment. 

“We will aggressively target utilisation improvements to help reduce the impact of the rate changes,” the letter said. 

“When the market dynamic shifts towards a more positive outlook, we will actively review this specific change.” 

However, hauliers have told Motor Transport that AI is doing the opposite of other companies in the sector: “I think they’re just greedy,” said one, who asked to remain anonymous. 

“Work has got quieter, but it only seems to be for them. Breedon have put their rates up by 3.91%. 

“People can’t run trucks with what they are asking us to do; like the spec on all our wagons. 

“You need one truck and two drivers and you need to work them day and night and that’s it, or it will never pay.” 

Another haulier, Roger Foster, said he’d pulled his trucks off AI work in the west of England when he received the letter: “I think it stinks,” he said. “There is work! I’ve heard they’ve got lorries coming from Manchester covering the work because we are not doing it. 

“No-one else is cutting the rate. I think there’s plenty of work out there.” 

An AI spokesman said: “We recently communicated to our franchised hauliers who serve our aggregates and asphalt business in respect of our standard rates. 

“We regularly review these rates against fluctuating fuel costs and adjust them accordingly. 

“As average fuel prices have dropped this quarter we will be adjusting all standard tipper haulage rates for all vehicle types on all standard work by -0.52% from 1 July 2024.” 

The spokesman added: “There are also very challenging market conditions across the industry currently and, as a business, we must constantly look at how we can remain competitive and drive efficiencies. 

“As part of this drive we have made the difficult decision to reduce standard rates by a further 1.25%.” 

Of course, a reduction in rates won’t help Aggregate Industries find an operator prepared to haul any Straitgate winnings to Hillhead for processing – a 46-mile round trip for every as-dug load that must only be fuelled with the more expensive HVO. However, the company has already admitted that economic conditions are not currently conducive to the viability of mineral working at Straitgate, and that once the permission is implemented the site could be mothballed.

Aggregate Industries’ Straitgate update for June

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

No change this month as no new schemes have been submitted.

AI’s ponding problem at Hillhead – enough water to fill 15 Olympic pools!

Any quarry Aggregate Industries ends up digging at Straitgate Farm must not introduce water bodies, because of aircraft safeguarding considerations at Exeter Airport: 

25. No water body shall be created within the site other than the approved weigh bridge lagoon.    

But Aggregate industries is not very good at controlling surface water. 

If it were, it would not be suffering a "surface water ponding issue" at its Hillhead Quarry near Uffculme. We’ve already posted about this – here, here, here and here. 

Aggregate Industries has recently lodged a planning application with Devon County Council 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.

The Planning Statement for the application reads:  

3.4.1 Houndaller Extension Area is currently facing surface water ponding issues in Phase 6 which is preventing completion of restoration of this section of the quarry. It is considered that a similar situation will occur once extraction operations cease in Phase 7. During 2023 and to date in 2024, in excess of 1m dept [sic] of water has collected over much of the Phase 6 area. The consented final restoration landform does not allow for effective drainage. Therefore, Aggregate Industries are proposing a long-term solution for surface water ponding issues on site.  

Just how wrong has Aggregate industries got things at Hillhead? 

There may be in excess of 1m depth of water, but how far does that water extend? Fortunately, Google Earth has recently provided new imagery for the area – and the answer is 9.27 acres or 3.75 ha, giving a volume of water in excess of 37,500 cubic metres, or enough to fill 15 Olympic-sized swimming pools. 

Where is all this water to go, now and in the future? According to the Hydrological & Hydrogeological Impact Assessment for the above application: 

5.8.8.1 ... ingress waters (rainfall runoff and groundwater seepage) will be captured by the perimeter drainage ditch and directed into Houndaller Plantation Pond, which will recharge the groundwater system in the BSP Aquifer. 

5.8.8.2 An infiltration rate of 50 m/d has been used in the calculations, which is the worst-case value for hydraulic conductivity derived from falling head tests (as used for calculating the worst-case ingress rates in the extraction area). 

5.8.8.3 The design storm would raise the water level (injection head) in the pond by 0.5 m.

5.8.8.4 The mean surface area (through which the outflow occurs in the recharge / soakaway feature) is taken to be the sides of the pond when accommodating 0.5 m change in water level. 

5.8.8.5 The unlined flanks of the pond have a total length of 400 m and have an effective depth of 0.5 m; therefore, the total surface area for infiltration would be 200 m2. 

5.8.8.6 Based on Darcy’s Law, applying an injection head of 0.5 m and an infiltration rate of 50 m/d, and with the mean surface area for infiltration set at 200 m2, the soakaway rate (recharging the BSP Aquifer) equates to 5,000 m3/d. 

5.8.8.7 This is equivalent to circa 150% of the storm ingress ASV indicated at section 5.8.7.14. Therefore, it is concluded that Houndaller Plantation Pond has sufficient soakaway capacity for the design storm. 

However, this calculation doesn’t look right: a soakaway rate of 5000 cubic metres of water per day through an infiltration area of just 200 square metres seems impossibly large.

What do we find? Firstly, the author of the report has not assumed "the worst-case value for hydraulic conductivity" they have in fact assumed the best: 

3.5.9.1 The hydraulic conductivity of the BSP has been determined from falling head tests undertaken in the area; and typically varies between 5.8x10-4 and 7.3x10-6 m/s, equivalent to 0.6-50 m/d. 

Secondly, the author has omitted the length of the flow path (l) from their calculations. Darcy’s Law relates the flow of groundwater through the saturated aquifer (Q) to the cross section of the aquifer (A) and the hydraulic gradient (h/l) and is written as Q = -kAh/l, where k is the hydraulic conductivity. 

Using the worst case of 0.6m/d for hydraulic conductivity (k), with 200m2 (A), 0.5m (h) and, for example, a 1000m flow path (l), the soakaway rate would fall from the incredible 5,000 m3/d to just 0.6 x 200 x 0.5/1000 = 0.06m3/day – almost 100,000 times less. 

Which means that it’s not at all clear that Houndaller Plantation Pond does have "sufficient soakaway capacity for the design storm." 

The Hydrological & Hydrogeological Impact Assessment for the above application was authored by the same team that will, either this month or next*, be trying to work out infiltration rates at Straitgate Farm. Hardly instills confidence does it?

EDIT 25.6.24 *Infiltration tests now postponed by Aggregate Industries until "end of July/early August". 

EDIT 12.7.24 Objection from Devon County Council Flood Risk Team

AI’s planning permission for the livestock crossing has expired – so what next?

Remember all the fuss about the cattle crossing – first raised here in 2017, and mentioned numerous times since?

 

The subject of the crossing was covered at the Public Inquiry, and the Planning Inspectors subsequently ruled that mineral extraction at Straitgate Farm is contingent upon the implementation of planning permission 20/2542/FUL, a permission secured by Aggregate Industries from East Devon District Council in 2021, for a "New access to the B3174 Exeter Road to provide a livestock crossing incorporating holding pens." 

Condition 19 of Aggregate Industries' permission to quarry Straitgate says: 

No soil stripping in Phase 1 of the development hereby approved shall be undertaken unless the cattle crossing permitted by East Devon District Council permission ref. 20/2542/FUL has been fully implemented and brought into operation in accordance with the conditions of that permission.

The Inspectors granting permission for the quarry spelt out the reason for this: 

109. Material to this appeal proposal is a planning permission granted by East Devon District Council (EDDC) for a new access to the B3174 Exeter Road to provide a livestock crossing incorporating holding pens. At the time of the Inquiry this permission had not been implemented. However, no cogent evidence was presented to suggest that it would not be implemented. From the details of this permission submitted to the Inquiry it is clear that this livestock crossing arrangement will enable a more direct, efficient and therefore safe movement of livestock when they need to cross the road which is of benefit to the livestock, farmer and other highway users. 

However, as we posted last year, Aggregate Industries mucked up. Permission 20/2542/FUL could not be implemented as it stood because some nitwit from the company had put the red-line planning boundary in the wrong location, as the District Council later confirmed: 

I have written to Aggregate Industries drawing their attention to this issue and recommending that they address this issue through a further application. 

Overlooking that inconvenient detail, the livestock crossing permission, granted on 21 June 2021, was itself subject to conditions, the first of which said : 

1. The development hereby permitted shall be begun before the expiration of three years from the date of this permission and shall be carried out as approved. (Reason - To comply with section 91 of the Town and Country Planning Act 1990 as amended by Section 51 of the Planning and Compulsory Purchase Act 2004). 

Today, three years have passed. 

A further application has not been made. The development has not been implemented. Parroting a famous sketch: The application is no more. It has ceased to be. It has expired and gone to meet its maker. It is an ex-application.

But that’s not the end of the story. In desperation, Aggregate Industries will now lower itself to more brutal tactics. To negate the need for the livestock crossing, and hopefully thereby to persuade Devon County Council to drop the Inspectors’ condition, the company’s ability to implement its permission to quarry Straitgate Farm will now be contingent upon foisting more pain and suffering on local people. The company will attempt to evict the tenant farmers and their children from their home – a home that has been in the same family more than 80 years – and to close down their successful dairy operation. 

The words heartless and bastards might spring to mind. 

But fortunately, and as the company itself acknowledged many years ago, the tenants have "the benefit of an Agricultural Holdings Act 1986 Tenancy Agreement." 

tenancies under the 1986 Act continue to exist because they are difficult to terminate, and because tenants have powerful rights of succession, allowing their close relatives to succeed them. 

What pain and suffering would befall this multinational cement bully should any eviction not be successful and implementation of the permission not be possible? Is there an urgent need for sand and gravel from Straitgate? Are the minerals in fact needed at all, given the millions of tonnes of similar material available to the company next to its processing plant at Hillhead also allocated in the Devon Minerals Plan? Answers: Insignificant, no and no. 

To prove the point, earlier this year, the company admitted that economic conditions are not currently conducive to the viability of mineral working at Straitgate, and that once the permission is implemented the site could be mothballed.

Tungsten West wins permit for Mineral Processing Facility, but loses CEO

Following on from a public consultation exercise, Tungsten West, the operator of the Hemerdon tin and tungsten mine near Plympton in Devon, has today announced it has been granted a permit to operate its Mineral Processing Facility – the source of complaints by local people last time the mine was operational – "within the limits previously agreed between the Company and the Environment Agency": 

This is the last of the key permits required to further progress the Project. 

However, earlier this month, it was also announced that the company’s CEO has resigned "with immediate effect". 

Tungsten West’s plans to increase sales and HGV movements of secondary aggregates were approved by Devon County Council earlier this year.

Tungsten West has received the final permit for the Mine Processing Facility. This momentous achievement is a key milestone for our company, completing the suite of permits needed to process tungsten, tin, and aggregates.
A huge thank you to all team members, past and present🙌

— Tungsten West Plc. (@TungstenWest) June 12, 2024

Aggregate Industries – planning application vs reality

Should a planning application from Aggregate Industries be read more like a sales pitch than a promise? More like a dream than reality?

Take Aggregate Industries' plans for restoring the orchard at Straitgate Farm back to "its former glory": 

3.8.14 Immediately to the south of Straitgate farmhouse is a dilapidated orchard. The orchard is shown on Ordnance Survey Maps dating back to the late 19th century and could be considered as an important part of the setting of the grade II listed farmhouse. 

3.8.15 The Applicant recognises the value of the orchard both to biodiversity and to the heritage asset and proposes to restore the orchard to its former glory by propagation from existing apple trees, growing them on and replanting in a grid pattern. Cuttings will ensure local providence and the restored orchard will provide an attractive feature.  

The orchard even featured in Aggregate Industries' error-laden Greenhouse Gas Assessment. As we previously posted, this greenwashing document told us that the "17,200m2 of restored orchard" would be planted "at a density of 2,250 trees/Ha" – a staggering 3,870 trees that would supposedly sequester an impossible "9.3 tCO2e" annually. Bonkers. 

Restoration of this orchard would, Aggregate Industries claimed in its application, involve the following:

2.6 A specialist local nursery will be engaged to graft new trees for the orchard. This involves taking cutting of scion wood from trees in the orchard and grafting them onto the stems of suitable rootstock grown at the nursery. This new grafted tree can be grown on in a pot for 2 – 3 years before being planted out in the orchard. This method guarantees the new tree will produce fruit of exactly the same variety as the tree from which it was pruned. Cuttings will be taken from 10 trees as agreed with the nursery. When grafted trees are ready, they will be planted in suitable gaps around the orchard and protected from stock grazing by individual timber post and rail with stock netting shelters, 1.8m high and 1m square. 

Cuttings will be taken from 10 trees, although but it’s not altogether clear how many would actually be planted. Surely a minimum of 10?

Aggregate Industries' marvellous before and after pictures imply a significant amount more:

The Planning Inspectors, approving the company’s plans to quarry the farm, wrote: 

85. The appellant also proposes restoration of the orchard at the front of Straitgate Farmhouse. Cuttings from the existing apple trees would be propagated and planted. We saw on our visit that tree cover within the orchard is sparse compared with what it would have been historically. Because the orchard is part of the historic layout of the grounds to the farmhouse, its restoration can be given some weight in favour. 

The restoration influenced the Inspectors’ planning balance. 

154. There are also significant material considerations which weigh in favour of the proposal. These include… restoration of the orchard at Straitgate Farm. 

Aggregate Industries has now submitted its Landscape and Ecological Management Plan to Devon County Council for approval in order to satisfy Condition 7 of the permission. How many trees are proposed to be planted? 3870? 100? 10? 

5.4.2 Five new trees from this grafted stock should be planted in the nursery when they are ready. Newly planted trees should be protected by a square, post and rail tree guard with stock netting to protect the tree from sheep grazing, such as the one in the photograph below. 

Five. Isn't Aggregate Industries embarrassed by this sort of thing?

Aggregate Industries’ Straitgate update for April & May

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

The May update would be that we have now submitted the first batch of schemes required by condition (of which you have copies) to Devon for formal approval.  During June I also hope to be in a position to submit our water monitoring scheme and the written scheme of [archeological] investigation.

For April, the company provided this update: 

Please find attached copies of the schemes that I have submitted to Devon [County Council] today. 

The schemes referred to by Aggregate Industries include: 

Condition 7 (Landscape and Ecological Management Plan) 

Condition 20 (Travel Plan) 

Condition 22 (HVO Use) 

Condition 26 (Airport Safeguarding) 

Condition 33 (Dust and Air Quality) 

Condition 42 (Hedgerow along A30)

Aggregate Industries had extra 460k tonnes of sand & gravel up its sleeve all along

At the Public Inquiry in October 2022, Aggregate Industries pointed to the less-than-7-year landbank for sand and gravel in Devon, and claimed there was therefore an "urgent" need for a quarry at Straitgate Farm. As a result, in weighing up the planning balance, the Planning Inspectors concluded there were: 

154. ... significant material considerations which weigh in favour of the proposal. These include its contribution to sand and gravel supply in Devon in circumstances where there is not currently a 7-year landbank as required by the Framework. 

Ten months before, in December 2021, at the time Aggregate Industries’ application to quarry the farm was refused by Devon County Council, the landbank was actually above 7 years, according to a subsequent revision by the Council. However, by the time of the Public Inquiry, the landbank had indeed dropped to 6.4 years, based on permitted reserves of sand and gravel in the County at the end of 2021 of 3.317 million tonnes, divided by the 10-year sales average of 0.514 million tonnes per annum. 

But, surprise, surprise. It now turns out that, at the time of the appeal, and unbeknown to the Planning Inspectors, Aggregate Industries had another 460,000 tonnes of sand and gravel up its sleeve, which, once permitted, would have pushed the landbank to over 7 years. 

Aggregate Industries has recently lodged a planning application with Devon County Council 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." 

This application is concerned with modifications to the Houndaller part of the site – a site with the same sort of material that underlies Straitgate Farm – that has suffered from ponding problems, as we have posted about here, here and here.

The Planning Statement for the application reads: 

3.4.1 Houndaller Extension Area is currently facing surface water ponding issues in Phase 6 which is preventing completion of restoration of this section of the quarry. It is considered that a similar situation will occur once extraction operations cease in Phase 7. During 2023 and to date in 2024, in excess of 1m dept [sic] of water has collected over much of the Phase 6 area. The consented final restoration landform does not allow for effective drainage. Therefore, Aggregate Industries are proposing a long-term solution for surface water ponding issues on site. 

Clearly, the concern must be that if the company hasn’t been able to adequately manage surface water at Houndaller, it doesn’t stand much chance of complying with the no water bodies condition at Straitgate: 

25. No water body shall be created within the site other than the approved weigh bridge lagoon.   

However, the company’s application for Houndaller is not just concerned with surface water management. The application’s Non-Technical Summary says: 

1.1.6 The proposed modifications to mineral operations at Houndaller include removal of two unsafe historic faces which will provide an estimated 460,000 tonnes of permitted reserves to Devon’s sand and gravel landbank. 

1.4.10 In addition, at present the approved plans under the extant consent contradict each other, with the approved restoration plan (ref. 2285/ROMP/4C) not showing the ridge along the northern boundary of phase 8, but it is in-situ on the working plans (ref. 2285/ROMP/3C & 2285/ROMP/73D) thereby creating an anomaly. Therefore, at present the approved restoration scheme cannot be delivered as currently consented. 

A spare 460k tonnes? Unsafe quarry faces? Approved plans that contradict each other? How has Aggregate Industries allowed all this to happen? 

But could it be that these perilous quarry faces were not known about at the time of the 2022 appeal? Not unless Aggregate Industries has been asleep for 20 years. The application’s Planning Statement points to The Quarries Regulations of 1999 and says: 

3.2.6 It is proposed to remove the ridge escarpment which lies adjacent to the eastern edge of Houndaller Plantation Pond which is in the northern part of Houndaller Extension Area and former Phase 1 area. 

3.2.7 The former Houndaller Phase 1 extraction area, north of the current Phase 8, had been worked pre-Quarry Regulations 1999 when long-term geotechnical stability of the final quarry faces when excavating sand and gravel material was not given the consideration which is now required for quarry legislative purposes. Whilst this area is now restored, the historical faces are currently up to 20m high and 65˚ to near-vertical therefore presenting both a stability, and health and safety issue. 

3.2.8 Hillhead Quarry is now subject to a Regulation 33 geotechnical assessment every two years. Within this assessment, there are various design criteria that the quarry must use to ensure geotechnical stability for both active and inactive faces. These design criteria’s are derived from the specific geotechnical properties of the geology onsite and from various stability analyses undertaken alongside the assessment. 

3.2.9 Based on the current design criteria for restoration slopes, the historic faces adjacent to the eastern edge of Houndaller Plantation Pond and along the northern boundary of the current approved Phase 8 extraction area have been assessed and are considered to be excessively steep and too high for long- term stability. They therefore currently present a significant geo-technical risk, and health and safety hazard. The current Regulation 33 Geotechnical Assessment for the site states that "Aggregate Industries must develop a plan to include remedial actions on these historic quarry faces". Further detail on the stability issues are presented within the Stability Assessment accompanying this planning application at Appendix 6.2.

The company would therefore have known for years that these hazardous quarry faces did not comply with the 1999 regulations, and that removing them would likely yield extra material. 

But perhaps it forgot all about them at the time of the Straitgate appeal in October 2022? This isn’t likely either. The Stability Assessment referenced in Appendix 6.2 says: 

1.3 ...It was identified in 2022 that the restoration plan needed to be updated to include improved drainage and to update the final profiles in relation to the materials available for backfilling the extraction area. At this point it was a natural way to deal with this legacy face to ensure the whole Houndaller excavation area is left in an adequate way that it supports long term stability and no hazards remain when Aggregate Industries complete this area.

So, how very clever of Aggregate Industries to keep all this material – about half the quantity available at Straitgate – up its sleeve. 

Prior to the determination of its Straitgate Farm application, Aggregate Industries had been in the habit of losing material – including at Houndaller – which had the inevitable effect of reducing the landbank and creating the impression of need for Straitgate. Miraculously, after Straitgate is determined, we now discover the company has found material again. How convenient. How cunning. 

What does this application for Hillhead mean for the County’s sand and gravel supplies: 

3.2.16 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. 

Assuming production for the years 2024,25,26,27,28,29 this implies that some 2.1 million tonnes remain, or 1.64 million tonnes excluding the newly found 460,000 tonnes. Aggregate Industries helpfully confirmed in 2019: 

The company's reserves schedule for Houndaller was subsequently revised to 2.9 million tonnes as at 1st January 2019.

Subtracting those two figures implies that over the 5 years 2019,20,21,22,23, some 1.26 million tonnes of sand and gravel has been produced, at a rate of 250,000 tonnes per annum. 

At this rate, Houndaller would in fact last another 8 years. 

Of course, this is why Aggregate Industries – knowing all along it had extra material at Hillhead – has been in no rush to advance its plans for Penslade, despite starting groundwater monitoring in 2021. 

Penslade is owned by Aggregate Industries, and again has the same type of material that underlies Straitgate. Whilst Aggregate Industries claims there is 1.06 million tonnes of saleable aggregate at Straitgate, Penslade is a 23 million tonne sand and gravel resource, 8 million of which is allocated in the Devon Minerals Plan. It sits next to the company's processing plant, not – like Straitgate – 23 miles away. At the appeal, the Council’s Mineral Planning Authority said: 

5.1.13 The Appellant has stated at meetings of the local liaison group for Hillhead Quarry that it is preparing a planning application for their West of Penslade Cross site (to the east of Hillhead Quarry), having undertaken investigative boreholes and intending to seek pre-application advice from the Council before the end of 2022, with a view to submission of an application in 2023. It is also understood that remaining reserves at Hillhead Quarry are sufficient to maintain supply until a new quarry at Penslade has been approved and is capable of being implemented. 

However, to date, no planning application for Penslade has arrived. All Aggregate Industries would say at the appeal was: 

8.4 Aside from the appeal site, the only other allocated site is West Penslade. West Penslade is also AI controlled which [sic] and would be an extension for the Hillhead quarry (planning permission ends in 2028). West Penslade will not come online until then. 

The bottom line is that Straitgate is not quite so urgent after all. 

Furthermore, as we posted last month, Aggregate Industries now says that if current market conditions persist then Straitgate will have to be "mothballed". Local people will wonder what strategic thinking goes on at Aggregate Industries, if any. 

What else does DCC/4399/2024 tell us? In relation to groundwater and nearby water users: 

5.7.3 Throughout the lifetime of the development, some 2 m thickness of unsaturated material will be retained beneath the quarry floor at the western margin of the Houndaller Extension. 

Compare and contrast that with extraction all the way down to the maximum water table at Straitgate, a site with more than 10 times the number of nearby private water supplies at risk than at Houndaller. Even so, Aggregate Industries again recognises that private supplies will be put at risk:

5.7.14 In the unlikely event that a supply is shown to have been impacted by quarry-related drawdown, the following approach is proposed to provide mitigation… The fallback position would be the provision of mains water. AIUK would cover the costs for mains water connection and usage at any property where the water supply is affected by the quarry development. 

What ecological damage will be done in removing those treacherous quarry faces? 

3.5.3 As part of the remedial works for the two unstable ridges within the northern extent of Houndaller, approximately 28,863m2 of lowland mixed deciduous woodland is required to be removed.

 

Which rather undoes this PR piece pushed out by Aggregate Industries last year, congratulating itself for planting saplings at Hillhead. 

Devon County Council is accepting comments on DCC/4399/2024 until 29/06/2024.

Aggregate Industries’ pushback on planning conditions has already started

Aggregate Industries claims: 

In all areas of our business, including internal and external interactions, we always act with integrity. 

Why is integrity important? Aggregate Industries tells us: 

High performance with high integrity is key to sustainable success. 

It may only be corporate BS, but doesn’t it sound good? Well done to the company’s PR gurus. 

If, however, Aggregate Industries does act with integrity, if Aggregate Industries does have strong moral and ethical principles, if Aggregate Industries is virtuous, honourable, trustworthy, it would of course want to abide by planning conditions. It would not want to find weasel words to get around them. It would recognise that planning conditions are there for a reason. They are not there to be interpreted in a way that is favourable to the bottom line of a multinational cement conglomerate. They are there to protect people and the surrounding environment. They are there to "enable development to proceed where it would otherwise have been necessary to refuse planning permission."

But, surprise, surprise, what do we find? Aggregate Industries is already pushing back on the conditions imposed for its permission to quarry Straitgate Farm, pushing back on environmental protection. 

Take the two majestic oak trees, trees F and G, which sit either side of the approved site entrance, but outside of any mineral working area. In its planning application, Aggregate Industries admitted: 

the works will potentially interfere with the root protection areas of Trees F, G... and it is likely they will be damaged by the development and need to be felled. 4.1

One of the reasons Devon County Council had refused Aggregate Industries' application to quarry Straitgate Farm was because: 

6. The proposed development would result in an unacceptable loss of mature trees and hedgerows leading to the fragmentation of habitat corridors, contrary to Policies M16 and M17 of the Devon Minerals Plan, Policy D3 of the East Devon Local Plan and Policies NP1, NP2 and NP8 of the Ottery St Mary and West Hill Neighbourhood Plan. 

The Council defended this reason for refusal at the Public Inquiry when the company appealed. 

However, by that time, Aggregate Industries had changed its story about trees F and G. Representatives for the company assured Government Planning Inspectors that the site entrance could be created without harming these trees or their roots. 

In their subsequent report, the Inspectors recognised that these 200-year old oaks "are worthy of protection and should be retained". This was secured by Condition 41, which states, unequivocally:

Outside the designated mineral working areas, trees shall not be felled, lopped or topped or have their roots damaged and hedgerows shall not be removed, thinned or cut back without the prior written consent of the Mineral Planning Authority.

What could be clearer than that? 

East Devon District Council also recognised that the trees were worthy of protection and last year put a Tree Preservation Order on both. 

The trees contribute to the amenity and character of the area and they are considered under threat from development and the impact of heavy machinery and vehicles.

The Council was of the view that:  

The detailed plans submitted by Aggregate Industries show both trees being retained but then states that tree F (named as T3 in TPO) and tree G (named as T2 in TPO) ‘will be monitored and only removed if necessary’. This is somewhat ambiguous and raises concern that the trees may not be given the full protection during construction if it’s considered that the trees can be removed ‘if considered necessary’.  

It is noted as stated by the Objection [from Aggregate Industries], that the trees are protected by Condition 6 of The Appeal as they are shown as being retained on the plans (albeit with the caveat of ‘will be monitored and only removed if necessary’). However, with the conditions being only short-term and the rather ambiguous wording, it is considered that TPO will therefore help ensure long-term protection and that they are appropriately managed by current and future owners.

It is a criminal offence to wilfully damage or destroy a protected tree without consent from the local authority. TPOs allow the potential for "unlimited fines" in the case of damage:  

in determining the amount of fine, the court shall take into account any financial benefit which has resulted, or is likely to result, from the offence.

You would think that that would be the end of the matter. But no. At a meeting last month, Aggregate Industries said it would try not to damage oak trees F and G. 

Try. And in writing this month, Aggregate Industries confirmed: 

Our tree and highway consultants are looking at this issue and I will be able to update you in due course. I would refer you to approved plan reference R22/L/3-3-005 which clearly labels Trees F and G as "condition of tree to be monitored and only removed if necessary". 

Removed if necessary. It’s a surprising position to take, not only because of the clarity of Condition 41, and the TPO, but also because – as East Devon District Council recognised – the approved plans (listed below) all show the oak trees retained:

0308.101 rev F Junction improvement scheme layout 

0308.104 Junction improvement long section 

SF/RS/XX Road Section AB 

SF/RS/XX Road Section CD 

Clearly, Aggregate Industries thinks it’s above planning conditions and TPOs. Integrity?

Ignominious twist: Straitgate may have to be mothballed until better times – says AI

At the Public Inquiry in October 2022, Aggregate Industries assured Government Planning Inspectors that the need for minerals from Straitgate Farm was "urgent": 

8.3 The landbank for Devon is below the required 7 year supply and as such the need can be considered as urgent. Combined with the lack of supply in the wider region which is detailed in the follow paragraphs, the need for the development is indeed considered urgent. 

Aggregate Industries’ Mr Kimblin KC concluded in his closing statement: 

170. The essential planning circumstances in this case are so very simple. The appeal site is one of two allocations in the DMP and the site is needed in order to maintain a steady and adequate supply of minerals, which the MPA is presently failing to provide. 

Needed. Urgent. So very simple. 

And yet, after struggling over many, many years to win planning permission to quarry Straitgate Farm – after fighting tooth and nail to make sure the site was in the Minerals Plan, after extensive site investigations, after two failed planning applications and a successful, but time-consuming and expensive appeal, after putting local people through decades of blight and aggravation – Aggregate Industries is now talking about mothballing the site.

How has it come to this? 

Around the same time Aggregate Industries’ representatives made those claims to Planning Inspectors, another aggregates company in Devon was having altogether different concerns. It was not thinking needed and urgent. Precisely the reverse. 

Aggregate Industries is not the only company in Devon with reserves of sand and gravel from the Budleigh Salterton Pebble Beds, the material that underlies Straitgate Farm. 

Heidelberg Materials – or Hanson under a previous guise – owns Town Farm Quarry near Burlescombe in Mid Devon, close to the Devon/Somerset border. As-dug mineral from this quarry has previously been processed at Whiteball Quarry, 2 miles away in Somerset, which is itself only 4 miles away from Aggregate Industries’ Hillhead Quarry, where Straitgate material would be processed. 

Heidelberg’s permission for Town Farm – extended in 2023 – does not have the same long list of restrictive constraints that faces Aggregate Industries at Straitgate Farm. Town Farm material does not need to be transported 23 miles between quarry face and processing plant, neither does it need to be worked and hauled using equipment and HGVs fuelled with expensive HVO. 

And yet, even without these cost constraints, Heidelberg is not currently able to make the numbers work at the Town Farm and Whiteball sites, both of which were mothballed in 2023. Last year, a Devon County Council Monitoring Report stated: 

As of 1st February 2023 it was confirmed that it has been necessary for Hanson to undertake a review of its Whiteball and Town Farm operations due to current economic conditions, in order to cut production capacity and reduce overheads and the decision has been made to temporarily mothball the Town Farm site until market conditions improve. 

This year's Monitoring Report tells the same story. Heidelberg says the operation is still closed. 

A number of issues will have conspired against Heidelberg: energy costs, red diesel rebate loss, interest rates, house-building slump, Liz Truss etc. The situation is unlikely to change anytime soon. Last week, the Mineral Products Association reported that "weakness persists for heavyside building materials": 

....ready-mixed concrete sales have plummeted to historically low levels, hit by the contraction in housebuilding, which compounded longer-term weaknesses in demand from new commercial offices and retail projects which have been subdued since 2017. 

...demand for primary aggregates has been supported by the requirement for bulk fill materials on major infrastructure projects, particularly from HS2, but the lack of significant new infrastructure projects outside of the country’s only major rail scheme remains a concern.

The Construction Products Association says the sector is heading for a worse recession this year than previously expected.

Aggregate Industries will have been cock-a-hoop last year to have finally won the keys to plunder the green fields of Straitgate Farm, but, at a meeting last month, the company admitted that economic conditions are not currently conducive to the viability of Straitgate, and that once the permission is implemented the site could be mothballed.

Questioned more on the subject, the company would not be drawn further:

... we have 10 years from the date of commencement to extract the mineral and that remains our intention.

However, even with a fair wind, it’s hard to see Aggregate Industries ever making the figures work for the site – given the gargantuan haulage distances involved and the HVO fuel premium.

But hey. If the company has backed itself into an uneconomic corner, it has no-one but itself to blame; no-one forced the company to process the Straitgate material 23 miles away – a 46-mile round trip for every load of as-dug material, material that includes a 20% waste factor – or to work the site and haul material using expensive HVO fuel. It came up with those ideas all by itself. 

As far as we’re concerned, however, the writing has been on the wall for some time. We’ve been questioning the viability of the site since long before this early post in 2012 – pointing to the fact that the company has access to little more than 5% of the material first thought possible, and asking What is AI’s bottom line, because it surely can’t be profit?

In fact, so concerned were we for Aggregate Industries' financial wellbeing – haha – we even created a viability label. Given the amount the company will have spent on winning those green-field keys – after a decade of fees to consultants and lawyers – the company should have perhaps heeded our advice.

But when did Aggregate Industries ever listen to Joe Public?

Denmark passes new law to recycle more building materials

Denmark aims to increase the recycling of construction materials: https://t.co/N1mgcHtlAn #sandcrisis

— Vince Beiser (@VinceBeiser) April 30, 2024

The Danish government has approved new legislation mandating recycling plans for buildings exceeding 250m2 scheduled for demolition. The Danish Minister for the Environment warns: 

We can’t keep extracting sand and gravel.

Holcim’s climate legacy laid bare in Carbon Majors database

Climate scientists are alarmed, reported the Guardian earlier this month:

This is the 10th consecutive monthly record in a warming phase that has shattered all previous records. Over the past 12 months, average global temperatures have been 1.58C above pre-industrial levels. 

For those looking to apportion blame, the Carbon Majors database was helpfully relaunched a few days before: 

The Carbon Majors database traces 1,421 GtCO2e of cumulative historical emissions from 1854 through 2022 to 122 industrial producers, the CO2 portion of which is equivalent to 72% of global fossil fuel and cement CO2 emissions since 1751. Over 70% of these global CO2 emissions historically can be attributed to just 78 corporate and state producing entities. 

Cement producer Holcim – parent company of Aggregate Industries – is one of them, 63rd on the list:

What might the legal consequences of this be? 

The Carbon Majors dataset has played a pivotal role in holding fossil fuel producers to account for their climate-related impacts in academic, regulatory, and legal contexts. Examples include quantifying the contribution these entities have made to global surface temperature, sea level, and atmospheric CO2 rise; and establishing corporate accountability for climate-related human rights violations.

Indeed, Holcim has already found itself at the sharp end of climate litigation, as previously posted.

Carbon Majors is a historic production database used to quantify emissions from 122 of the biggest fossil fuel and cement producers. The dataset contains emissions data from 1854 through 2022. pic.twitter.com/aMv3aTf0et

— InfluenceMap (@InfluenceMap) April 4, 2024

Fascinating case for legal responsibility by @ECCHRBerlin: cement industry is responsible for ≈8% global annual CO2 emissions, almost 3x aviation industry; Holcim is a Carbon Major whose contribution has been quantified (https://t.co/gO1YYHf69U) Details: https://t.co/QuASMeHiJ0 https://t.co/bcHztqWypk

— Lucy Maxwell (@lucysmaxwell) July 13, 2022

‘Circular solutions vital to curb environmental harm from cement and concrete’

Excellent article in @MongabayOrg @Sean_Mow on how essential it is to reduce the impacts & consumption of concrete, feat @aurora_torresm talking about the biodv impacts & me about the need to eventually transition to a post-growth infrastructure stock https://t.co/PcCA609aC8

— Sophus zu Ermgassen (@sophusticated) April 19, 2024

* Cement and concrete production is responsible for significant pollution, human health impacts and vast amounts of climate-fueling emissions. 

* Manufacturing cement is particularly problematic as the chemical process used to make it produces nearly 8% of global carbon emissions. Experts also underline that demand for the mined and quarried aggregate materials used to make concrete, such as sand, is responsible for biodiversity and ecosystem harm. 

It’s estimated that around 30 billion tons of concrete now gets used each year, already posing huge extraction, pollution and greenhouse gas emission risks, even as production surges in the Global South as the construction industry ramps up. “That starts looking like quite an enormous pressure on our planetary boundaries,” says Sophus zu Ermgassen, a postdoctoral researcher at the University of Oxford. 

Circular solutions are urgently needed to address environmental threats at multiple points along the cement and concrete supply chain, say experts such as Jonathan Duwyn, a buildings and construction specialist with the UN Environment Programme’s Climate Change Division. Research indicates that quarrying for construction minerals — including sand, stone and gravel — poses a threat to at least 1,000 species planetwide, according to Aurora Torres, an ecology and sustainability researcher at the University of Alicante. 

It’s estimated that around 50 billion tons of sand is used annually for construction, generating an array of environmental problems and social challenges. Research indicates these activities take a toll at the ecosystem level, and with human health by degrading air and water quality, and even influencing infectious disease spread in sand mining areas.

Two months on – PZ2017/03 is STILL underwater

On 12 February this year, we posted Water level at borehole PZ2017/03 rises to GROUND LEVEL.

By 18 February, the situation was even worse:

Last week – more than two months on, and now with monitoring equipment finally installed – the top of the piezometer was still underwater:

The sand and gravel that Aggregate Industries wants at Straitgate Farm starts on average 2.3m below ground level. The company’s permission only allows quarrying above the maximum water table.

Clearly this is one area where extraction should not be taking place.

So, how close to this area could extraction be permitted? Aggregate Industries is in no position to say. As we previously posted: 

Piezometer PZ2017/03, at the NE corner of Phase 1 and SE corner of Phase 2, is obviously unable to provide any meaningful information on how far to the west of this point the maximum groundwater levels would allow sufficient depth for mineral extraction, given water levels here have reached ground level. 

Clearly, therefore, there need to be further boreholes drilled at the redrawn eastern boundary of the extraction area – to fulfil Condition 30, ie. so that there are piezometers at "each corner of each working sub-phase".

How do companies make themselves look green?

The is how Aggregate Industries does it – as any visitor to aggregate.com/sustainability will see:

 

Of course, many companies face the same problem – what photo to put on your sustainability page, to make yourself look green? 

But what if your business is concrete – the most destructive material on earth? What to choose then? 

Aggregate Industries has chosen a photo of a green living wall. 

If only all buildings were made like this, you might think. Green walls: 

Remove air pollutants 

Reduce urban temperatures 

Reduce energy consumption 

Improve biodiversity 

Attenuate rain water 

Reduce noise 

etc, etc

What a wonderful company Aggregate Industries must be, you might think, to produce such a product. 

You might think that, because next to the photo the company writes "Our Sustainable products". 

Yet Aggregate Industries does not design, make or sell green walls. 

The photograph is greenwash. 

Aggregate Industries does not even operate in the same country as the photographed building.

The magical #livngwall of the Musee du quai Branly #Paris is a 200m long by 12m tall carpet of exotic #biodiversity which echoes the diversity of the artists who exhibit at the museum. #sustainability #architecture #sustainablearchitecture#greenwall  #greenroofs #verticalgarden pic.twitter.com/xEF6vTeCle

— SUSTAINABILITYBAE (@sustbae) October 7, 2021

Aggregate Industries' parent company – which also has form in this area – does however operate in Paris. It is not known for its green walls either – but is known for polluting the Seine.