Tuesday 31 January 2017

Quarrying and processing restarts at Hillhead


Further to AI's had second thoughts about processing Hillhead material at Blackhill, mobile plant has now been installed in Hillhead Quarry, and is processing material from next door Houndaller. Aggregate Industries has 4.23 million tonnes of sand and gravel available at Houndaller - with planning permission - enough to last the company 12 years or more.


Hillhead Quarry is where AI wants to process any material it wins from Straitgate Farm. It's 23 miles from Straitgate, and currently without the sort of fixed, capital-intensive plant used at Blackhill that AI had previously said would be required for Straitgate material:
The substitution of the Blackhill plant with a mobile processing plant would severely restrict the output and product range to serve market demand. 8.30
For those unfamiliar with Hillhead, here's where AI's mobile plant is sited in relation to Houndaller.


And here's what's left to quarry, shown on one of the plans from AI's recent Hillhead ROMP application.



Meanwhile, huge stockpiles remain at Blackhill Quarry on Woodbury Common, but processing has now ceased. The processing plant and sales operations will be removed from the site within 12 months, in accordance with the Blackhill Restoration and Aftercare Scheme Revision F 2013:
4.14 Area 12
4.14.1 Restoration will commence in accordance with the requirements of planning permission ref: 10/0473/CM at the end of 2016 and be completed by the end of 2017...
4.14.3 The existing quarry processing plant, associated infrastructure, weighbridge, weighbridge office will be removed from the site.

Monday 30 January 2017

Rail movement of aggregates on the increase

Aggregate Industries is planning 2.5 million HGV miles on Devon roads with the Straitgate Farm planning application, but elsewhere more aggregate is being moved by rail:


Because rail produces 90% less particulates and 15 times less NOx than trucks, which are key contributors to air pollution.
Rail freight additionally produces 76% less CO2 emissions than the equivalent HGV journey.
And rail freight is safer; HGVs have been six times more likely than cars to be involved in fatal collisions on urban roads over the past three years (based on the percentage of miles they represent).

Thursday 26 January 2017

Straitgate groundwater levels at their lowest... in the middle of winter

January is typically a month when groundwater levels are around their highest. There was therefore surprise when readings taken from piezometers around the site today were at their lowest since monitoring started in 2013.

One piezometer was some 2.8m lower than the average of the previous three winter measurements, and 50cm lower than any reading previously recorded, summer or winter.

These readings will not have informed Aggregate Industries’ latest planning application - which is still awaiting validation by DCC.

All 4 Better Development

Campaign groups across the country have joined All 4 Better Development, a national alliance against rural over-development. Sign the petition calling for changes to planning legislation:
This petition calls for a parliamentary debate on government Housing and Planning policy over building on greenfield land and seeks community right of appeal on planning decisions and the removal of the presumption in favour of sustainable development.

Sunday 22 January 2017

Refusal recommended for Tewkesbury quarry application on noise and dust grounds

Planning officers at Gloucestershire County Council have recommended refusal for a sand and gravel quarry in Church End, near Twyning. The applicant proposed to:
extract 98,000 tonnes of sand and gravel from 3.04 hectares and restore site to agriculture, amenity and nature conservation uses with imported fill over a period of 2.5 years
The "minimum extraction stand-off margins would be 60m from the nearest residential property" - not unlike the wholly inadequate stand-offs proposed at Straitgate, an operation that would last 10-12 years.

Despite the modest scale of the Church End scheme, Gloucestershire planning officers concluded:
8.1 It is recommended that planning permission be REFUSED for the following reasons: 
1. The proposal fails to demonstrate that the noise from mineral extraction operations can be mitigated to an acceptable level so as not to interfere with local residents’ use and enjoyment of their property contrary to Minerals Local Plan policies DC1 and E14, the Tewkesbury Borough Local Plan policy EVT3 and Paragraph 144 of the NPPF. 
2. The proposal would have an unacceptable, adverse impact on the environment arising from the impact of dust for those living, visiting and working in the vicinity of the site contrary to Minerals Local Plan Policy DC1 and Paragraph 144 of the NPPF... 

Scottish aggregate shipped to Devon

The Devon Minerals Plan (Proposed Adoption Version) tells us that:
5.4.6 Small quantities of marine-dredged sand and gravel are landed at Appledore and Yelland to serve local markets in northern Devon that are remote from the land-won sources in the east of the County.

Is the North Devon Marketing Bureau trying to draw tourists from East & Mid Devon?

Or is Evans Transport - one of the South West's largest privately owned transport companies and owner of the lorry branded to encourage people to visit North Devon - sizing up the Straitgate haulage job?

Friday 20 January 2017

Wednesday 18 January 2017

Planning application for Straitgate inextricably linked to Hillhead



The first application is for a new sand and gravel quarry at Straitgate Farm located 3km west of Ottery St Mary. The second application is to allow for the importation of as-dug sand and gravel from Straitgate Farm into Hillhead Quarry for processing.
It was the same with the last application for Straitgate; that was inextricably linked to the application for processing at Blackhill - they shared an Environmental Statement.

If the new applications for Straitgate and Hillhead are inextricably linked, then surely the Hillhead ROMP application must also be linked? We've mentioned some of the problems with this application already: More groundwater problems for AI, Hillhead truck numbers ‘don’t stack up’, Another objection to AI's Hillhead ROMP application.

DCC has now issued a Regulation 22 request for the ROMP application outlining even more problems, including the fact that no noise, dust or cumulative impact assessments have been performed.

It should be remembered that DCC first gave notice to AI in 2013 that a review of operating conditions at Hillhead Quarry was due. AI submitted a ROMP application in March 2014 and DCC issued a Scoping Opinion in January 2015. It is therefore difficult to understand why, at the start of 2017, AI has still to supply such fundamental information.

Many will also wonder how a new application for Straitgate, an application that is inextricably linked to Hillhead, can proceed when there are still so many outstanding issues relating to this ROMP application.

Saturday 14 January 2017

AI's planning application set in motion - again

Aggregate Industries has given formal notice to affected tenants that a revised planning application to quarry Straitgate Farm was submitted to DCC on 12 January. The application will be open for comments once it has been validated by DCC. We will post further information when we have it.


The Devon Minerals Local Plan will provide the planning policy framework for assessing AI’s applications for quarrying at Straitgate and off-site processing at Uffculme, 23 miles away - a haulage scheme totalling some 2.5 million miles. The new Plan has yet to be formally adopted, but says this on transportation:


Here are a few more relevant policies:



The mysterious and unpredictable world of planning

Aggregate Industries will be looking to put anything up to 200 HGV movements per day onto Birdcage Lane, as part of its crazy haulage scheme to and from Uffculme 23 miles away.

Birdcage Lane is a quiet country lane. It sees one or two trucks a week for rubbish and recycling collections. It’s used for walking, running, cycling and horse-riding.

Now look at a planning application that came before DCC last year, DCC/3863/2016, an application - involving a similarly narrow country lane - that proposed an increase in the number of HGVs bringing waste to an industrial site near Cheriton Bishop, an increase from one to three movements per day.

Not HGV movements of the 44-tonne AI kind, more like the "10 tonne tractor/trailer combo" farming kind.

Letters of objection were lodged, but Mid Devon District Council had no objection, nether did the Environment Agency nor the Highways Authority. Planning officers recommended approval "in accordance with the policies of the Waste Local Plan"

However, the DMC committee went against that advice, and considered that three movements a day "would have an adverse impact on the peaceful enjoyment of the countryside and of the individual residences". In fact, the full refusal considered that the proposal was not in accordance with the Waste Local Plan:
It is considered that the increase in traffic as a result of the proposal would have an unacceptable impact on the amenity of residential properties close to the roads leading to the application site and upon the peaceful enjoyment of the countryside, in terms of traffic noise and vibration, contrary to policy W18 of the adopted Devon Waste Local Plan.
Policy W18: Quality of Life:
Peoples’ quality of life and amenity will be protected from the adverse effects of waste management development and transportation…
That might have been the end of it, had the applicant not appealed. DCC then argued that:
The DMC were mindful of the representations as reported in the committee report which included 19 letters of objection from local residents and an objection from the Local Member (Devon County), as well as representations made at the DMC by [a local resident], who spoke on behalf of a number of members of the local community.
15. ... the private residential gardens of the properties extend up to the road and occupiers’ ability to enjoy their outdoor space is an important component of their quality of life.
17. The frequency of noise and vibration events would increase significantly as a result of the proposal...
22. I have found above that the proposal would result in a significant increase in HGV movements along the haul route to the site. I consider that the greater frequency of noise and vibration events related to HGV movements would erode the tranquil character of the surrounding rural area. I also consider that this increase would adversely affect the ability of local people to peacefully enjoy the lanes and surrounding area through activities such as walking, running, cycling and horse-riding.
All things to bear in mind when AI launch their planning application for a quarry just a stone's throw from nearby homes with 100,000 HGV movements thrown in for good measure. How much will the living conditions of nearby residents and the peaceful enjoyment of the countryside come into it then??

How much confidence does Amec have in those contours?

Aggregate Industries' last planning application was all about separating fact from fiction. The new application will no doubt be much the same. Perhaps that’s not surprising, in this new "post-truth" age in which we find ourselves.

AI will wheel out its expert reports again, but read I'm a Scientist, and I Don't Believe in Fact from Julia Shaw, author of "The Memory Illusion: Remembering, Forgetting, and the Science of False Memory". She reminds us that "scientists don’t prove anything". In fact:
... please stop saying "because, science" to justify your argument, and using “FACT” as a preface to your statements. These are just the grown-up versions of "because I said so." We need to remind each other to stay on our toes and to actually backup our claims.
And this applies to AI’s water consultants, Amec Foster Wheeler, too.

There is uncertainty with any data, and any prediction derived from that data. No model can make predictions with 100% certainty. Scientists start their academic life having that drummed into them, and know to give an indication of confidence in any results they produce.

Amec used just 6 numbers (from PZ01 to PZ06) to map maximum groundwater contours across more than 60 acres at Straitgate Farm; contours that "represent just two of the many possible interpretations of the data which themselves are based on an incomplete parameterization of the detailed groundwater dynamics of the site".

Does it sound like Amec is 100% confident in those contours to you? It is these contours that AI wants to quarry down to, without leaving 1m above the maximum water table to protect drinking water supplies.

If Amec is not 100% confident in those contours - and how can it be - then how confident is it? How does that translate to a +/- figure? If it's no more precise than +/- 1m, say, how can AI justify not leaving the 1m? If it's more precise, then Amec needs to actually back up its claims.

Last year, we asked DCC:
Since AI now intends to dig right down to the maximum water table, perhaps you could ask Amec to confirm the specific level of accuracy (in +/- m) to which their maximum groundwater contours are mapped?
DCC asked AI and Amec for an answer. To date, none has been forthcoming.

Reducing freight CO2 emissions

Aggregate Industries' plans for Straitgate would involve over 100,000 truck movements and some 2.5 million miles. The Campaign for Better Transport warns us that:
Given that HGVs produce 22 per cent of transport’s CO2 land transport emissions while only accounting for 5 per cent of vehicles it is crucial that more freight be transferred to rail and that HGVs become more efficient. While road haulage has long been competitive, load efficiency has not improved significantly nor has empty running which remains at around 28 per cent of HGVs.


For those used to old money, 35 litres/100km is about 8 miles per gallon.

Wednesday 11 January 2017

‘Groundwater - Our hidden asset’

For anyone interested in finding out more about groundwater, UK Groundwater Forum has produced an e-book "Groundwater - our hidden asset" which is free to download:
The book is aimed at everyone, both within the UK and beyond, who needs to know about groundwater and who wishes to obtain a concise overview of this important natural resource.

The book reminds us that:
The importance of groundwater is easily overlooked. It is a hidden asset, out-of-sight and out-of-mind...
Many farms, households and communities in rural areas still obtain their water supply from shallow wells or small-diameter boreholes. In these situations groundwater is the only practical means of supply. Because such sources are relatively shallow and often near habitation, they are vulnerable to contamination.
Once an aquifer is polluted, remedial treatment is expensive and may not even be feasible.
The book may be of particular interest to all those dependent on groundwater around Straitgate:

Guess who's already profiting from fracking?

We should be weaning ourselves off fossil fuels, not developing new sources. Only last month, Nick Hurd MP, Minister of State for Climate Change and Industry, confirmed:
Known fossil fuels - not new ones.

Fracking is deeply unpopular. It has no social licence. Clearly that hasn’t stopped Aggregate Industries, however, from being one of the first to profit:



Monday 9 January 2017

LafargeHolcim reminds us that... the green construction revolution continues

Green building, which is designing and constructing buildings using eco-friendly materials and techniques, will continue to influence the global construction industry in 2017.
If LafargeHolcim's staggeringly unsustainable plan for Devon is an example of leadership on sustainability then, as the world's largest CO2 belching cement giant, we're all in trouble.

What's more, and no doubt for extra greenwash effect, the company has included the stock photo of a green roof and solar panels; they are not LafargeHolcim's line of business, but hey, cement's not green.

In fact, as anyone who has visited the Warsaw University Library will know, this building exemplifies the use of copper and glass - which is not LafargeHolcim's line of business either.

So what part will Aggregate Industries' parent company play in the green construction revolution?

Devon Minerals Plan challenged

A complaint and request for a holding direction has been sent to the Secretary of State for Communities and Local Government in relation to the Devon Minerals Plan. A copy was sent to MP Sir Hugo Swire. Further details will be posted when any response is known.

Saturday 7 January 2017

Climate change allowance for flood risk assessments

DCC's objection to Aggregate Industries' Hillhead ROMP application says:
Following the publication of the Flood Risk Assessments: Climate Change Allowances document (dated 19th February 2016) by central government, the applicant will be required to use a climate change uplift value of 40% when sizing the proposed surface water drainage management system for this development.
The same authority raised issues over the proposals for Straitgate back in 2015; proposals that were looking to permanently change the landscape and surface water runoff above a town with a long history of flooding. In response to that application, DCC said:
The surface water management is inextricably connected to Flood Risk Management/ Airport safeguarding and the need to maintain and recharge watercourses. This issue is so important in terms of the likely significant impacts of the proposal the MPA would wish to ensure that a SWM scheme can be designed to meet all of the requirements identified in advance of the determination of this application.
Based on the Environment Agency's advice at that time, this was the allowance that Amec made for climate change in that application:


The Environment Agency has since issued new advice on flood risk assessments and climate change:


To see why a 10% allowance was grossly inadequate, here's just one graph from the UKCP09 climate projections, for the change in winter precipitation in the South West for a high emissions scenario:

Another objection to AI's Hillhead ROMP application

There’s yet more trouble for Aggregate Industries' Hillhead ROMP application. Following the objection from the Environment Agency, and the truck numbers not stacking up, DCC, in its role as Lead Local Flood Authority, has also objected:
At this stage, we object to this planning application because we do not believe that it satisfactorily conforms to Policy MP47 (Flood Risk and Floodplains) of Devon County Council's Minerals Plan (2004-2011) which states that proposals for mineral development which increase the risk of flooding will not be permitted unless the risks or impacts can be mitigated by appropriate measures.
...it is not clear how surface water is managed during the restoration.
Following the publication of the Flood Risk Assessments: Climate Change Allowances document (dated 19th February 2016) by central government, the applicant will be required to use a climate change uplift value of 40% when sizing the proposed surface water drainage management system for this development.

HSE consults on strategy for quarrying industry


Article from AggNet:
As part of Helping Great Britain Work Well, the Health and Safety Executive is seeking consultation from the wider quarrying industry on its draft strategy for the sector.
The HSE’s top three priorities for the quarrying industry are: reducing cases of occupational lung disease by better control of exposure to respirable crystalline silica...

Tuesday 3 January 2017

Aerodrome Safeguarding

Exeter Airport has revised its website. It says "The purpose of Aerodrome Safeguarding is to":
- take the measures necessary to ensure the safety of aircraft, - and thereby the passengers and crews aboard them, - while taking-off or landing, - or while flying in the vicinity of an aerodrome - by controlling potentially hazardous development and activity around it.
There are three main types of aerodrome safeguarding;

1. physical safeguarding which protects a set of flight safety surfaces up to a 30km radius around the airfield, 2. technical safeguarding which protects aircraft navigational equipment from any interference or disruption, and 3. wildlife management which prevents any development areas from creating an environment attractive to birds.
Aircraft are vulnerable to bird strikes. 80% of bird strikes occur on or close to aerodromes, therefore highlighting the necessity for wildlife management on and within the proximity of an airfield. Exeter Airport is responsible for monitoring bird activity within a 13km radius of the aerodrome. This is to mitigate the bird strike risk to aircraft and be aware of what species we have in the local area. The objective of the safeguarding process is to prevent any increase in, and where possible reduce the bird strike risk at the aerodrome.
According to Aggregate Industries' consultants, this is where Straitgate Farm sits in relation to planes landing at Exeter Airport, 6 km away:


So let's hope that Straitgate doesn't turn out like AI's nearby Venn Ottery Quarry then:


These photos of so-called "seasonal waterbodies" are from DCC's Venn Ottery Quarry Monitoring Report; the date of the officer's visit was 19 August 2016. The officer reports a "Significant amount of run off was present in the waterbodies at the time of the visit", which is surprising given that last summer's rainfall in this area was well below average - according to the Met Office.

Here's the newly revised Safeguarding Advice Note 3.



And here's who would be in charge of controlling the birdstrike risk caused by any development at Straitgate; the same person who was responsible for nearby Blackhill Quarry - photo below - where one of the water bodies has been named Seagull Pond.

If you're at all worried about AI's plans, why not email safeguarding@exeter-airport.co.uk.



AI’s last two quarries in East Devon produced significantly less than expected - and there's every chance Straitgate would too

We all know that forecasting what a quarry might yield is an inexact business, even if the mineral companies would have us believe otherwise. Perhaps the quote from economist JK Galbraith best describes it:
There are two kinds of forecasters: those who don’t know, and those who don’t know they don’t know.
But how inexact is inexact?

Take Straitgate. Once upon a time, it was thought that the site could yield some 20 million tonnes. In 2012, DCC went out to public consultation telling people that there were 3.6 million tonnes. In 2017, Aggregate Industries will struggle to make the case for 1.2 million tonnes.

When AI eventually came clean on exactly how it hoped to win those 1.2 million tonnes - without retaining a 1 metre unquarried buffer to protect water supplies - the company reminded us that "Calculations have been undertaken by Chartered Geologists".

So let’s look at AI’s other two quarries in the area to see how well its chartered geologists did there.

In 2011, AI reassessed its sand and gravel reserves in Devon and found that it had lost 2 million tonnes; equivalent to a couple of Straitgates.

If anybody can remember as far back as the public meeting in West Hill in the same year, AI explained that 1.2 of those 2 million tonnes had been lost at Venn Ottery (that's what recent application "DCC/3861/2016 Variation to conditions 3 and 19..." was all about), but, to much merriment, the representative couldn’t (or wouldn’t) say where it had lost the other 0.8 million tonnes.

Perhaps it had something to do with nearby Marshbroadmoor? The original planning application gave a figure of 1.1 million tonnes, but, due to geological faulting, nothing like that amount ever came out. After an 'incidental' amount was transported to Hillhead for processing, an application was made in 2010 for the bulk of the reserve, some 176,000 tonnes, to be processed at Blackhill.

Which just goes to show that it doesn't matter how many chartered geologists study the data, AI won't know how much material Straitgate would actually yield up until the excavators did their worst.

This wouldn’t matter to AI if Straitgate still had 20 million tonnes, or even 3.6 million tonnes. But given that it’s now down to 1.2 million tonnes - 900,000 tonnes if the 1 metre is left - the economic benefits of quarrying Straitgate would be marginal at best. AI would therefore be taking a gamble - particularly when its last two sites in the area, two sites with the same geology, have been so disappointing; particularly when Amec tells us that at Straitgate:


Does any of this matter to a planning application? It does when the size of the mineral benefit must be weighed against the destruction of an East Devon farm, the loss of thousands of metres of hedgerows, trees and dormice habitat, the risk to drinking water supplies to more than a hundred people, the risk of birdstrike by creating water bodies 195m directly beneath an international flight path, and the pollution and carbon emissions from a 2.5 million mile haulage plan.

Is AI desperate?

We all know that Aggregate Industries' proposal to haul as-dug sand and gravel 23 miles from Straitgate Farm to Uffculme to be processed makes no sense.

The funny thing is, AI has been saying the same thing for years.

We have accumulated a stack of notes from previous meetings and phone calls; here are a couple of things that AI representatives have told us in the past:

In 2012: 'AI don’t want to move to Uffculme because it’s too far away from the target market'

In 2013: 'AI won’t consider Uffculme for processing [Straitgate material]; it's too far and not economic'

In fact, in 2015, these views were even formalised in AI’s last planning application for Straitgate:




So what makes Uffculme an acceptable and sustainable place to process material from Straitgate now? Has AI's target market moved? Have the economics changed? Is the massively greater amount of CO2 now acceptable? No, of course not. Having run out of options, AI is now desperate.

AI's junction designs


Detail was conspicuously missing from the junction designs at Aggregate Industries' recent public exhibition; AI's traffic consultant couldn’t or wouldn't talk numbers.

The screenshot above is of the Birdcage Lane junction with the B3174 Exeter Road. The junction opens out to about 13m. Look at the set of designs below that AI put forward for its last application. The access road is 7.3m wide, making the junction around 35m at its widest point - almost 3x the width of the current Birdcage Lane junction.

AI claimed that its designs didn't need the removal of any additional trees or hedgerows. Quite how that's possible, given that the gateway next to the Public Footpath doesn't belong to AI, is anybody's guess.


Site monitoring

The County Council carry out monitoring visits for all mineral and landfill sites to ensure compliance with the terms of their planning permissions.
DCC's site monitoring reports can be found here.

Aggregate Industries' Blackhill, Venn Ottery and Hillhead quarries were all inspected by DCC in 2016. See which planning conditions AI has complied with, and which it hasn’t:

Blackhill Quarry monitoring report p.14-15



Venn Ottery Quarry monitoring report p.26



Hillhead Quarry monitoring report p.31


‘We can’t wait for technology to save us’

... concluded a piece in the FT last year: Relax about robots but worry over climate change.
...the big lesson, at policy level, is that we cannot sit and wait for innovation to save us from climate change.
Imagining new technologies — as Philip K Dick did in his 1968 novel, Do Androids Dream of Electric Sheep (filmed as Blade Runner) — is a part of inventing them. Pinning our hopes on a sudden leap in the technologies we know is more likely to deliver the post-apocalyptic world in which that story is set.