‘HGVs make up approximately 5% of traffic flow and yet contribute more than 38% of the total NO2 emissions’

That’s what one survey found in Exeter. It’s something to remember when Aggregate Industries tells us that its HGVs would only make up a small proportion of traffic on the B3180 over the next 5 years.

Air pollution is in the news at the moment. The Supreme Court has ordered the UK government to take immediate action to cut NO2 air pollution - "the Government must prepare and consult on new air quality plans for submission to the European Commission... no later than December 31 2015". Air pollution is responsible for some 600,000 premature deaths in Europe each year; "29,000 early deaths a year in the UK - more than obesity and alcohol combined".

But air pollution does not just affect our biggest cities. Exeter City Council says that air pollution "may contribute to the deaths of 42 people in the city this year alone":

Exeter is one of the greenest and most beautiful places to live in the country. But no matter how good the air quality may appear, air pollution is an invisible potential health threat to everyone that lives and works here. Particularly vulnerable groups are children, pregnant women, the elderly and patients with pre-existing respiratory diseases.

DCC may not care about the adverse health impacts of air pollution on people living along the B3180, when it assesses AI’s application to haul as-dug sand and gravel from Straitgate Farm to Woodbury Common, 8 miles away for processing; DCC may not care about the impact of all the other associated heavy traffic a processing plant brings; however, what DCC will be required to assess is AI's air pollution impact on a site of European importance to nature. Planning guidance on air quality says:

When deciding whether air quality is relevant to a planning application, considerations could include whether the development would: Affect biodiversity. In particular, is it likely to result in deposition or concentration of pollutants that significantly affect a European-designated wildlife site, and is not directly connected with or necessary to the management of the site, or does it otherwise affect biodiversity, particularly designated wildlife sites. [5]

Natural England has already said that NOX pollution is impacting the East Devon Heaths. AI’s polluting million-mile haulage scheme, and the related HGV onward distribution traffic, would only cause more problems - for people and for nature.

Air pollution impacting integrity of East Devon Pebblebed Heaths

Natural England has identified that air pollution is adversely impacting the integrity of the East Devon Pebblebed Heaths. Pollution from extensive HGV traffic to, from and within Aggregate Industries' processing plant at Blackhill will be exacerbating this problem.

The Heaths are an internationally important site, and NE has produced a Site Improvement Plan:

Air Pollution: impact of atmospheric nitrogen deposition - Nitrogen deposition exceeds site relevant critical loads. Exceedance of threshold levels may affect heathland features by the transition of heather to grass dominance and the southern damselfly through changes to the vegetation mosaics. Action - Control, reduce and ameliorate atmospheric nitrogen impacts. Timescale 2014-20.

The Heaths are also protected under the Conservation of Habitats and Species Regulations 2010:

The Regulations require competent authorities to consider or review planning permission, applied for or granted, affecting a European site, and, subject to certain exceptions, restrict or revoke permission where the integrity of the site would be adversely affected.

In which case, how can a competent authority seriously entertain a million-mile HGV planning proposal for such an area - with the 5 years of significant nitrogen dioxide pollution it would bring?

NPPF: ‘The planning system should play an active role in guiding development to sustainable solutions’

Next week we will apparently find out exactly what Aggregate Industries' 'sustainable solution' is for East Devon - the one that involves hauling sand and gravel one million miles, through an area of European importance to nature conservation.

In the meantime, the issues page has been updated with relevant details, regulations and NPPF policies.

DCC has recently issued Devon Minerals Update No.10 - embedded here for convenience.

AI’s still not ready

People may remember how confident SLR’s Project Director for Straitgate was at the recent public exhibitions, saying that Aggregate Industries' planning application would be submitted by the end March - 'the first few days of April at the very latest'.

SLR has now advised DCC that the likely date for submission of AI's planning applications to quarry Straitgate Farm and to process the spoils on Woodbury Common will be 5 May. The formal consultation will begin shortly afterwards.

AI wants Straitgate - but not because of a lack of gravel at Uffculme

Apparently, there is still some confusion about the amount of gravel at AI's Uffculme sites.

Whilst it's true that Houndaller, which already has permission (to the west of Hillhead), is sandier - sand incidentally that AI is currently short of, Penslade (N6/N8) has a similar gravel component to Straitgate; at least it did in 2011, when AI’s Estates Manager confirmed to us that there was a "similar quality at Straitgate as at Uffculme".

As far as ownership, DCC has confirmed that "Aggregate Industries UK Ltd have mineral ownership rights over N6 and N8. They also have surface ownership of the majority of the sites". As far as quantities, DCC has said "Aggregate Industries have advised that the potential resource within that part of the Penslade site shown as a preferred site in our consultation document (i.e. most of N6 and N8) is 8.1 million tonnes".

HGVs thundering to and from Straitgate would be less than half the problem

Obviously, the sand and gravel from Venn Ottery currently going in to Blackhill to be processed has to come out again. The trucks taking the processed material out are on average smaller, meaning more movements out than in, many travelling on the B3179 through the middle of Woodbury.

It’s not quite clear after Aggregate Industries' exhibitions how many HGV movements would be generated specifically by Straitgate, before onward distribution to the wider market. Some people were left with the impression of 85 a day, others were left thinking it would be closer to 200. Enquires to AI have gone unanswered. In the past we have gone by AI’s Haulage Statement for Venn Ottery, which claims 110 movements a day for a 5-day working week, or 138 movements a day for a 4-day working week, 50 weeks a year, 400,000 tonnes pa, using 6-axle HGVs carrying up to 29 tonnes.

Whatever the claims, on 14 April for 4.5 hours the actual vehicle movements recorded going in and out of Blackhill were as follows:

Over the space of half a day, 97 truck movements were recorded going to and from Venn Ottery (equivalent to 194 for the day), with 230 vehicle movements recorded in total. This equates to approximately 115,000 annually.

This is a truly staggering figure. All the more so because the isolated factory that is generating all these HGV movements on our B-roads is sitting in the middle of an AONB, SSSI, SAC and SPA. All the more so because as recently as 2010 this arrangement received the blessing of DCC.

And AI will shortly be asking DCC again to rubber stamp a continuation of this situation - not to bring in material from a site 5 miles away this time, but to bring in material from Straitgate 8 miles away over a period of 4-5 years. When there’s an industrial site 2 miles away from Straitgate that could do the job, continuing to use Woodbury Common like this shouldn’t even be a question, let alone an answer.

Is this any way to treat ‘one of the most important conservation sites in Europe’?

Designated a Site of Special Scientific Interest, a Special Area of Conservation and a Special Protection Area, this area represents one of the most important conservation sites in Europe.

And yet these photographs show just what's happening on the East Devon Pebblebed Heaths. You would never know that Aggregate Industries had already been paid millions of pounds of public money to stop quarrying on the Common. Operations like this - especially without any adjoining active quarry to justify a continued presence - have no place in such important areas for nature, locals and visitors alike.

Why did DCC ever think that repeatedly allowing AI to carry on operating here was a good idea?

And what of Thorn Tree Plantation?

In 1999, Aggregate Industries was served with modification orders to stop quarrying at Blackhill. AI was later paid millions in compensation. Despite this, in 2002 AI won permission to quarry Thorn Tree Plantation, an adjacent area at Blackhill. AI worked this site until 2009.

In 2000, in documents approved for court purposes, AI's Divisional Estates Manager (Southern) put the company's chances of securing permission at Thorn Tree at 50:50, and said "if planning permission was turned down on that area it was doubtful in view of the small size of the site that an appeal would be considered". But DCC granted AI permission anyway, as DCC invariably does, and AI is still there today - now looking to stay until 2021, and no doubt beyond.

More than 5 years after quarrying ceased, this is what the site looks like today. How well does it sit in this important landscape? How is restoration progressing? People can make up their own mind.

And while we’re on the subject of assurances made by AI

Apart from the impact of 44-tonne HGVs pounding up and down the B3180, one of the main issues of contention in Aggregate Industries' 2010 application to process Venn Ottery material at Blackhill Quarry was the height and extent of its stockpiles - the ones sitting in the middle of an AONB, SPA, SAC, SSSI.

We have already established that although DCC recognised that "mineral developments in AONBs must demonstrate that they are in the public interest, and that there is an overriding national need for the development which cannot be reasonably met in some other way”, it chose to ignore an undesignated industrial site two miles closer, for no reason other than the profits of a Swiss multinational.

But it was East Devon AONB that raised the issue of Blackhill's stockpiles, and DCC admitted:

The major impact of the proposal is the visibility of the stockpile areas, particularly for viewpoints from the East Devon Way and other public rights of way. Currently Blackhill Quarry is required to be restored by March 2012, and this proposal would effectively delay the restoration of this part of the site by up to 6 years. 6.13

AI assured the Council that it had a plan:

In terms of the visual impact, the Applicant has agreed to produce an annual stocking plan for Blackhill, with an aim to reducing the stocking areas and hence the visual impacts. In the event that planning permission is granted this could be secured by planning condition. 6.19

A planning condition was indeed added and formed part of the proposal that councillors voted upon:

9. Prior to the commencement of the development the operator shall submit a detailed stocking plan that shall include measures to reduce the quantities of stock held on the site and provide a height limit to the stockpiles. The stocking plan shall be reviewed annually and the development should be carried out in strict accordance with the agreed details, or such alternative details that may and subsequently be agreed in writing by the Mineral Planning Authority. REASON: In the interests of the visual amenity of the area.

Which all sounds well and good. But no "detailed stocking plan" was ever submitted by AI, or asked for by DCC. The development was not carried out "in strict accordance" with any agreed stocking details. The "visual amenity" of the AONB continued to be impacted.

DCC forgot to put Condition 9 on the formal notice. And AI conveniently 'forgot' all about it too.

Something to bear in mind when AI tells people "...we’ve been operating quarries in East Devon for over half a century and working in partnership with the surrounding communities every step of the way." Something to bear in mind when AI says it has a plan. Something to bear in mind when AI asks people later this year to trust it again, with 5 more years of delayed restoration for Woodbury Common.

AI made assurances about ‘dry working’ at Venn Ottery too

To get some idea of what quarrying 100 acres of "best and most versatile agricultural land" at Straitgate Farm would look like on Ottery St Mary's doorstep - if Aggregate Industries were to get its way - here's a photograph of the company’s operation at Venn Ottery.

For Straitgate, AI has made assurances that "extraction would be restricted to a dry working option" - at least for Phase 1 - but for those 100 people reliant on the wells surrounding the farm for their drinking water, for those concerned about streams flowing to wetland habitats in ancient woodland, and for those worried about birds and airport safeguarding issues, this photograph won’t bring any comfort. Because AI made similar assurances to the Environment Agency back in 1998*, saying that Venn Ottery "does not involve working below the water table" - and look at it now.

* [Development Control Committee 4.3.98, 97/P1588, ROMP Conditions 10/09/98]

Pilot's-eye view

Amazingly, Aggregate Industries hasn’t yet ruled out Phase 2 - “wet working” below the water table - at Straitgate. This would involve another 6 years beyond the 4-5 already indicated; risking drinking water supplies and, based on AI's track record, another 6 years of wanting to haul material along the B3180.

AI’s aerial photograph of Straitgate Farm is, ironically, exactly the view that pilots and passengers have as they fly into Exeter Airport from the east. It should therefore be immediately obvious to anyone why the issue of water, habitat changes and increased bird numbers are so important in any quarry application:

Wetland creation is one of the most problematic development types in terms of birdstrike prevention at aerodromes.

Because if a population of seagulls, like those at AI's Blackhill and Hillhead Quarries for example, were to subsequently become an aviation hazard directly under a flight path, it's not always a straightforward issue to fix; in Lancashire for example, a controversial cull of seagulls to lower the risk of bird strike to aircraft has been blocked by the Court of Appeal.

If AI was more committed to doing green rather than promoting green...

Aggregate Industries' million-mile haulage plan across Woodbury Common is as far from green and sustainable as a quarry operation can be, and yet in a new report backed by the company, it proclaims its support for green infrastructure, saying "involvement in the report from the UK-GBC was very important for our business as we continue to search for ways to promote the importance of green credentials across the construction industry…".

One of Aggregate Industries’ commitments towards sustainability includes listening and responding to local communities and other key stakeholders. The report from the UK-GBC explains how adopting a green approach helps prepare businesses for climate change adaptation, as well as promoting biodiversity, human health and wellbeing… Involvement in the UK-GBC report continues Aggregate Industries’ commitment to promote greener business, with the company currently working with the Wildlife Trust in London to create a tool to calculate the value of green space.

Local people won’t recognise it as the same company.

Of course, if AI was more committed to doing green rather than promoting green, it would never have arrived at this ridiculous, polluting and unsustainable haulage plan for East Devon in the first place.

Aggregates Levy exemptions for Devon & Cornwall china clay waste ruled lawful

One 'uncertainty' in planning Devon’s future provision of sand and gravel was removed last week, as the European Commission reaffirmed that the Aggregates Levy exemption for secondary aggregates derived from china and ball clay operations in Devon and Cornwall is lawful and can be reinstated.

DCC had said: "...the removal of the Aggregates Levy exemptions for secondary aggregates introduces significant uncertainty into the prediction of future requirements for land-won aggregates".

But whilst public services are hit by spending cuts, the Government has bowed to industry lobbying by freezing the Levy at £2/tonne for the sixth year running. This is despite soaring profits at Aggregate Industries et al. The Aggregates Levy, which raises c.£300m pa, was introduced in recognition of the environmental cost of quarrying, and to encourage the use of secondary and recycled materials. Calls have been made for the Levy to be significantly increased to promote the use of waste materials in place of newly quarried aggregate; to clear up existing scars on our landscape before creating new ones.