Friday, 28 June 2019

EA’s model of Otter Valley groundwater levels “as much as 15m adrift”

The Environment Agency plainly thinks that Aggregate Industries’ consultants can accurately predict the maximum winter water table and base of any quarry at Straitgate Farm to cm precision – across some 55 sloping and geologically faulted acres – with just six data points.

It is of course nonsense. Professor Brassington is clear:
...the MWWT is not a representation of the maximum water table readings for the proposed quarry site 4.16
Dr Rutter was also concerned about AI’s groundwater predictions at Straitgate:
This surface is only a model of reality, and may not represent actual groundwater levels across the site…
There are many private water supplies reliant on the aquifer underlying Straitgate Farm. The EA has a statutory duty to protect and improve the water environment through effective management of water resources and by reductions in pollution. The EA obviously has a short memory about the difficulties of modelling groundwater levels in the Otter Valley:
The Permian and Triassic sandstone aquifer in the Otter Valley is one of Devon's largest groundwater sources, supplying drinking water to 200,000 people.




The National Rivers Authority, the EA’s predecessor, produced a four volume Environmental Study of the River Otter in 1994, based on their network of observation boreholes.

Volume 4 of the report accepts that:
The Otter Valley Triassic aquifer is complex. As a result there is considerable spatial variation in groundwater level response to natural recharge.
Water level responses are influenced by many factors. Those of greatest significance include: * proximity to areas of groundwater discharge; * proximity to the river, where changes in stage are reflected as groundwater level fluctuations; * proximity to the coast, where tidal responses are similarly reflected; * proximity to abstraction points; * thickness of the unsaturated zone, and the presence of low permeability material in the sequence...
But the bombshell is in Volume 2:
A substantial amount of work in this area has already been done by MRM Consultants (1989), who developed a ground water model of the sherwood sandstone aquifer in the Otter Valley. The model was used to assess the likely impact of certain abstraction policies on ground water levels in the aquifer, and resultant changes in the flow regime of the Otter between Fenny Bridges and Dotton. Calibration of the model was difficult to achieve, and modelled ground water levels were sometimes as much as 15m adrift from estimated ground water level after calibration. These discrepancies probably arise from the adopted assumption that the aquifer permeability is constant across the whole catchment (ie that the aquifer is homogeneous and isotropic). In practice, permeability can be highly variable, substantially affecting local transmissivities and rates of water table recession and drawdown. 3.1.6
So, the best that these consultants could produce for the EA – using records collected over almost two decades – was a model of groundwater levels "as much as 15m adrift."

It’s perhaps not surprising. After all, as this EA technical report makes clear:
A model is a tool, not a substitute for reality.
So, why then has the EA so much faith in AI’s model of maximum groundwater levels at Straitgate Farm – given that it was produced by consultants Amec Foster Wheeler (now Wood Group) who were looking to accommodate their client’s desire to maximise the recoverable resource, given that it was produced from groundwater levels recorded from just six boreholes only 12 months after they were drilled?

Why too – in an effort to support AI’s assertions that those groundwater levels at Straitgate can be relied on to be the highest ever – does the EA rely on groundwater levels from an assortment of boreholes on Woodbury Common and elsewhere, an assortment of boreholes up to 93m deep (at Straitgate they're 6-12m deep), including ones in different geology, and one going no further back than 2008? Why does the EA choose to ignore actual evidence from the site? Why does the EA choose to ignore higher baseflows in previous years from one of the streams emanating from Straitgate? Why does the EA choose to ignore groundwater levels from June 1990 in one borehole that shows water levels almost 3m higher than AI’s best guess close to where 'Drillers were surprised they struck water so quickly' in June 2017?

It’s a mystery – particularly as AFW has been so evasive over telling us, DCC and the EA the accuracy of the MWWT. No model can be 100% accurate. This paper says:
…it is vital that the uncertainties of the modelled GWLs are quantified so that land managers and scientists interpreting predictions can determine which features reflect statistically significant variation in groundwater processes rather than model errors.
It was back in January 2016 that we first 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?
AFW were asked again in 2017, but still refused to answer – even to the EA.

In February 2018, the EA asked again:
We recommend that a description of tolerance levels is therefore requested again from the applicant to support the planning application and to provide clarity in advance of the Planning Committee.
If any answer has subsequently been provided that adequately deals with tolerance levels, none has yet been made public. Why have AI’s consultants been so reluctant to provide an answer? Is it the risk that their groundwater predictions would look no more reliable than a chocolate teapot?

In any case, AFW’s model of groundwater levels factors nothing in for climate change. BGS – in "Groundwater and climate change" – forecasts that during this century:
annual rainfall will remain about the same but winter rainfall will increase by 10 to 30% over most of the country
Producing:
increases in average winter [groundwater] levels, by the 2050s under a high greenhouse gas emissions scenario...
Perhaps it's for these reasons that Prof Brassington wrote:
If Devon County Council are minded to grant permission for these proposals, despite the evidence given in this report, they are asked to ensure that an unquarried buffer of at least 3 m is left above the maximum water table to minimise the negative impacts. It has already been demonstrated that the MWWT surface cannot be modelled accurately, neither can the MWWT be reliably adhered to during the operational phase. 6.14
It's important to get this right, particularly for those relying on the site for their drinking water.

It's important for AI too. They wouldn't want to be looking at scenes like this in the future:

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FM Conway ‘pushes boundaries of asphalt materials recycling in highways industry’

Whilst LafargeHolcim, the parent company of Aggregate Industries, bemoans the lack of demand for greener products – see post below – other companies in the construction industry are challenging working methods and using increasing amounts of recycled material.

For example, FM Conway working with Westminster City Council has recently laid a road surface containing 80% recycled materials:
Traditionally, this has been limited to 50% for the lower layers of roads and just 10% for the surface courses of motorways and ‘A’ roads.
Operations director at FM Conway, said:
With the UK’s materials reserves under pressure, we need to continue to challenge convention and invest in the re-use of highway arisings.
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‘Cement Produces More Pollution Than All the Trucks in the World’

... warns an article in Bloomberg. It's a mind-blowing statistic.

There are greener alternatives to cement, but the Head of Sustainability at LafargeHolcim – parent company of Aggregate Industries and the world's biggest cement producer – claims:
There is so far too little demand for sustainable materials. I would love to see more demand from customers for it. There is limited sensitivity for carbon emissions in the construction of a building.
Which sounds like business as usual then, and little sign that LafargeHolcim is fazed by our climate crisis.

Shirley Rodrigues, Deputy Mayor for London, says:
It’s very difficult. What we can do is to start to send a signal. We’ve got a new requirement for developers that they must develop a circular economy statement to show how they will reduce, reuse and recycle materials.
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French court of appeal to rule on LafargeHolcim terrorism charges

Executives from the parent company of Aggregate Industries have been accused of financing terrorism in Syria. We have posted on the subject before.

Global Cement now reports:
The Court of Appeal in Paris will decide on 24 October 2019 whether charges of financing terrorism and crimes against humanity will be upheld.
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Thursday, 20 June 2019

LafargeHolcim: Acting in a way that would ‘wipe out most life on the planet’

Aggregate Industries is a subsidiary of LafargeHolcim – the world’s largest cement producer.

You only have to look at AI’s record on CO2 emissions – or for that matter its proposal for Straitgate Farm to haul material 23 miles for processing, a total of 2.5 million miles in all – to tell that neither of these companies is taking our climate emergency seriously.

And that’s also the conclusion from a new study.

Financial Times analysis of Carbon Delta data shows "only 15 per cent [of the top 500 companies] are in line with the goals of the Paris climate accord, which seeks to limit global warming to well below 2C."
This analysis maps out each company’s current behaviour, and correlates it with the level of global warming it would imply by the end of the century if every company in the world made similar choices.
And LafargeHolcim is the worst of the bunch.

In fact, if other companies acted like LafargeHolcim, we would find ourselves not "well below 2C" but in a +6°C warmer world by the end of the century – within the lifetime of children being born today.



Contrast this finding, with the greenwash pumped out by LafargeHolcim:


Despite the direction of the graph, despite the ambition, despite the greenwash, in reality – as we posted in LafargeHolcim has a way with numbers – CO2 emission numbers – LafargeHolcim’s net CO2 emissions increased in 2018 to 121,000,000 tonnes*, up from 118,000,000 tonnes in 2017, up from 115,000,000 tonnes in 2016:
To put that 121 million tonnes of CO2 into context, it is equivalent to the emissions from 31 coal-fired power stations. To sequester this amount of CO2 would require 142 million acres of forest – an area more than twice the size of the UK.
Welcome to the world of LafargeHolcim – one of the biggest corporate polluters on the planet, increasing its CO2 output each year, acting in a way that would wipe out life on earth.


But what about those working for LafargeHolcim and other such polluting companies? The BBC points to a coal mine reopening in Cumbria, and asks:
The mine will create at least 500 well-paid jobs, but there is a large environmental impact. Would you take a job at the mine?
As one interviewee puts it:
As a human civilisation, we all have to help each other. And we all have to work together. And it’s not just about me getting a good salary, it’s about ensuring that the world stays alive.

* Net CEM CO2 emissions. Total gross direct CO2 emissions 135Mt. Total indirect CO2 emissions 30Mt. Source: LafargeHolcim Sustainability Report 2018
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Why is a stream’s baseflow important?

Groundwater sustains the flow of streams and rivers when it's not raining. The groundwater component of a stream's flow is referred to as the baseflow or low flow.

Baseflow is important "for sustaining human centres of population and ecosystems."

It's important at Straitgate too. In one of the streams emanating from Straitgate, such flows sustain Cadhay’s mediaeval fish ponds and stop them from turning into a quagmire. In another stream, such flows sustain wetland habitats in ancient woodland:



The amount of baseflow is determined by groundwater levels. Professor Brassington's report pointed to the baseflows (in 1976/77 and 2000/01) from yet another of Straitgate’s streams – as a reason why Aggregate Industries’ model of the maximum water table at Straitgate Farm (based on the winters of 2013 and 2014) cannot be trusted.


Groundwater is important in sustaining streams and water sources during dry periods. Look at these recent tweets from the UK Groundwater Forum and the Environment Agency's Groundwater & Contaminated Land Team:



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AI’s HGVs in the real world

Aggregate Industries has previously pointed to dangerous lorry driving and how safety must come first:
Throughout the duration of 2017 there has been an influx of headlines around poor lorry driving which has led to structural damage of property and infrastructure, accidents and, most tragically of all, fatalities.
As part of an ongoing crackdown on bad driving etiquette by Highways England, last month (November 2017) saw one UK County conduct secret filming which worryingly captured a number of HGV drivers using their mobile phones, watching YouTube videos and even reading books behind the wheel
In 2019, this sort of thing is still going on – including by AI's own drivers.



Since then twitter has been busy exposing further examples of AI's HGVs in the real world:












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Wednesday, 19 June 2019

Straitgate determination date extended for 8th time


Last month, we asked Is there any life left in AI’s application to quarry Straitgate, or is it just "resting"? Now, whether there's any life or not, Devon County Council and Aggregate Industries have agreed yet another extension for determining the planning application to quarry Straitgate Farm, this time "from 28th June 2019 to 31st December 2019".

For those who have lost count, it’s the 8th such extension – if we ignore the company's first application for Straitgate back in 2015, that had to be withdrawn in 2016 after AI forgot to ask permission from a landowner whose field was to be used for site access.

Of course, as with the other extensions, there’s been no visible progress from AI since the last extension.

So, what on earth can AI be finding so difficult – that requires so much time, and so many extensions??

Is it the hydrogeology, and the impact AI’s plans would have on private water supplies and Grade I Cadhay? Is it Professor Brassington’s recent report concluding that 'ANY quarrying at Straitgate would cause problems', a report which has prompted new objections, including this one?



Is it proposing what must be the UK’s most ridiculous and unsustainable quarry scheme – to haul as-dug material 23 miles away for processing – at a time of increasing concern and awareness about our climate emergency?

Is it – with a newly rebuilt plant at Hillhead together with 4 million tonnes of permitted sand and gravel reserves next door – the slow realisation that AI doesn’t really need the ever-shrinking resource at Straitgate after all?

Is it that LafargeHolcim bean-counters have finally cottoned on, that – with a working scheme that (according to Prof Brassington) "will not work in practice", with associated infrastructure, extensive archaeological investigations, restoration, legal agreements, and multi-million-mile haulage costs – Straitgate Farm is never going to be worth it?

Or is the company just sitting on its hands, twiddling its thumbs, stringing DCC along, waiting for the Brexit mayhem and associated economic uncertainty to pass? As if that's going to happen anytime soon.

It’s now over 4 years since AI’s application for Straitgate went live, and almost 2 years since any substantive information was supplied by the company.

In 2015, AI was in a rush to quarry Straitgate. In 2017, AI was in a rush to quarry Straitgate. Now, in 2019, having kicked the can down the road for another 6 months, AI is plainly coping quite well without Straitgate's relatively small amount of sand and gravel after all.
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Wednesday, 12 June 2019

CEMEX quarry plan in Suffolk – underlines AI’s reckless stance to water at Straitgate


Concerned residents in Suffolk have directed us towards a planning application submitted last month by CEMEX to quarry Lime Kiln Farm, an extension of Wangford Quarry. The site has been proposed by Suffolk County Council as a Preferred Area for gravel extraction in its draft Minerals Local Plan, despite being in the Suffolk Coast and Heaths AONB – where "planning permission should be refused for major development other than in exceptional circumstances" NPPF 172.

Readers will remember Aggregate Industries’ attempts not so long ago to win consent in the East Devon AONB – to process material from Straitgate at their existing plant adjacent to the East Devon Pebblebed Heaths. Approval would have meant a continued blight on Woodbury Common, and would have introduced nitrate-rich agricultural soils into an area sensitive to any nutrient change. After concern from Natural England, AI withdrew its application and has now relocated the plant.

But we’ve digressed. The reason for this post was to contrast the difference between CEMEX and AI in relation to protecting nearby groundwater supplies.

CEMEX has submitted a range of documents in support of its application to extend Wangford Quarry and to quarry up to 1 million tonnes of gravel over some 11 years. The small number of documents submitted by CEMEX contrasts with the huge jumble of fragmented reports AI has been forced to submit in its multi-year quest to win consent to quarry Straitgate Farm – a clear indication of the number of constraints the company faces here in East Devon.

One of the CEMEX documents is a Hydrogeological Assessment – again, a brief affair compared with the tomes supplied by AI’s consultants Amec Foster Wheeler for Straitgate. Interestingly, CEMEX’s consultants rely on "(Brassington, 2007)" – a reference to academic literature by Professor Brassington, a leading authority on groundwater, who recently wrote a damning report concluding that 'ANY quarrying at Straitgate would cause problems'. For the Wangford extension, the salient features are a public water supply 280m away, no private water supplies located within 2km, and a proportion of the site within an Environment Agency Source Protection Zone 2. Groundwater levels have been monitored close to the proposed site since 2002 and show a typical range of 0.6 to 1.4mAOD. In contrast, at Straitgate, which also has a SPZ2 designated across part of the site, groundwater levels have been monitored since 2013 and fluctuate in some areas by no more than 24cm and other areas by as much as 6m.

CEMEX’s report is in stark contrast to the risks AI is prepared to take with the "fragile groundwater system" at Straitgate. The conclusions from CEMEX's consultants, JBA Consulting:
Quarrying involves activities that have the potential to affect the hydrogeological environment of the area. These activities have been identified and an assessment of their potential effects made.
The operational phase potentially poses the greatest risk to the groundwater regime because it will involve constant earthworks and frequent vehicle movements. There will also be minimal vegetation and no soil within the excavation area.
The main potential impacts to the hydrogeological environment are: alteration of recharge pattern, reduction in groundwater quality and increased groundwater vulnerability.
Proposed mitigation measures include the use of a Pollution Prevention Plan and the limitation of all workings to at least 1m above the highest water table.
Yes, that’s right. For this very level Suffolk site, where the maximum groundwater level is relatively easy to model, CEMEX still proposes that working will be limited to "at least 1m above the highest water table". CEMEX's Non-Technical Summary reiterates:
Historically quarrying has always left 1 metre of undisturbed sand and gravel between the bottom of the quarry and the surface of the groundwater. It is proposed to continue to do this when quarrying Lime Kiln Farm. This will, however, reduce the depth of dry, or unsaturated, sand and gravel that lies above the groundwater. In turn, this means that it is easier for potentially polluting liquids, such as fuels and lubricants, to reach and pollute the groundwater if they are spilt. 2.7.4
In contrast, at Straitgate, AI is proposing to leave a 0m unquarried buffer above the maximum water table; a maximum water table the exact position of which is still unknown, and where – as AFW admitted before whitewashing its reports – "there is the possibility for steps in the water table related to faulting" and "there is also likely to be other unmapped local faulting".

The aquifer underlying Straitgate supplies water to more than 100 people, to livestock farms, wetland habitats in ancient woodland, mediaeval fishponds, and a Grade I manor house. Dr Rutter is "concerned that there is a very steep hydraulic gradient across the site... Variations in the shape of the water table cannot be contoured based on the number of piezometers used". Prof Brassington says "an unquarried buffer of at least 3 m [should be] left above the maximum water table to minimise the negative impacts".

If AI doesn't propose to leave an unquarried buffer above the maximum water table to safeguard water supplies – a buffer typically employed by CEMEX, Hanson and others, as we posted in Quarry companies struggle to dig in the right direction, let alone to the nearest cm – what does it propose? AI's cunning plan is to rely on groundwater levels falling by at least 1m over the summer months – and clearly in some areas they don’t – before digging down to the maximum water table, and backfilling with overburden before groundwater levels rebound in the winter. Prof Brassington says it’s "untried anywhere else in the country" and "too difficult for typical machine operators". We’ve posted on the scheme before in No wonder AI wants to keep Straitgate’s groundwater data secret, Seasonal working scheme for Straitgate can't work as AI describes and AI was asked a very simple question.

If that doesn’t ring warning bells, consider that the authors of this "revolutionary" scheme – at AI and consultants AFW – are both no longer with their respective companies.

What if this experiment screws up drinking water supplies and mediaeval fishponds? Who would sort out the mess, given AI’s legal assurances for alternative water supplies are “unfit for purpose”? Let’s hope the EA and DCC have some good answers. They could never say they weren’t warned.
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An indication of things to come

In a post earlier in the year, Construction, demolition & excavation waste – largest waste stream in UK economy, we pointed to figures from the Minerals Products Association – the trade body representing Aggregate Industries and others, who claims "the need for resources and waste materials to be used more efficiently and effectively has never been so strong" – telling us that 120 million tonnes of construction, demolition and excavation waste is created each year – the largest waste stream in the UK economy – of which 26 million tonnes continues to be dumped in landfills.

The UK Green Building Council says "construction is still getting the circular economy wrong":
In the UK, construction, demolition and excavation account for 60% of both material use and waste generation. Humanity is on course to triple material extraction in the next 30 years and triple waste production by 2100.
Clearly the construction industry can't keep on like this. Fortunately there are signs – in these three recent stories – that some things are slowly moving in the right direction:

CDE recycling is set to receive a boost in the South West. A new £4m recycling plant has been set up on the outskirts of Bristol in response to demand. The materials recovery facility is set to be the most efficient and effective plant in the South West, processing construction and commercial waste, producing 'zero waste to landfill'.
The contractors that choose us are the ones that have environmental management systems at the forefront of their procurement so their sites have to be as close to ‘zero waste to landfill’ as possible. This new plant is the only one in the south-west that can process construction and demolition waste to that degree.


Meanwhile, Tarmac has become the first company in the UK to develop a new rubberised asphalt using recycled waste tyres. Some 40 million waste tyres are produced every year in the UK. The new material has been trialled in Coventry. Coventry City Council's senior highways engineer said:
We are delighted with the rubberised asphalt trial; we hope we can use more of the product across the city in the future to help divert waste tyres from landfill and incineration to reduce the carbon footprint for road construction projects in Coventry.
The Tyre Recovery Association, added:
While there has been significant progress in reusing and recycling waste tyres in the UK, there is still an over-reliance on the export of used tyres to countries such as China, India and Pakistan, who are importing fewer tyres as they become self-sufficient.
The UK needs a second disposal route for used tyres. Tarmac’s commitment to developing rubberised asphalt provides an excellent opportunity to achieve this and deliver environmental savings for this under-used waste stream.


Finally, in an indication of the recycling rates in construction waste that can be achieved – Station demolition achieves 95% recycling rate:
100% of the brick, timber and concrete removed from the site during the demolition work has been recycled for reuse elsewhere in the construction industry.

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UK commits to ‘net zero’ emissions by 2050; Ottery declares climate emergency

The UK is set to become the first G7 country to legislate for net zero emissions. One architect of the Paris climate agreement said:
Theresa May, desperate to leave a positive legacy, said:
Now is the time to go further and faster to safeguard the environment for our children. This country led the world in innovation during the Industrial Revolution [through the use of fossil fuels], and now we must lead the world to a cleaner, greener form of growth.
Environmental groups welcomed the news, but were concerned that it wasn’t far or fast enough, and that the UK would retain the ability to use international carbon credits. The acting energy minister, said the government did not "intend" to use such credits but had kept it "as an option". The Committee on Climate Change had warned "it is essential that the commitment [to net-zero] is achieved without use of international credits". The chief scientist for Greenpeace UK said:
As the birthplace of the Industrial Revolution, it is right that the UK is the world’s first major economy to commit to completely end its contribution to climate change, but trying to shift the burden to developing nations through international carbon credits undermines that commitment. This type of offsetting has a history of failure and is not, according to the government’s climate advisers, cost-efficient.






As part of the declaration, Ottery Town Council will set up a working group consisting of "councillors, residents, experts, scientists, businesses and young citizens" to recommend actions, policies and changes "to make Ottery St Mary a carbon-zero town by 2030".
Anyone interested in joining the group or has interest or knowledge of environmental issues, the science behind climate change and the local geography and economy should email the assistant town clerk.
Ottery St Mary’s new Mayor said:
Ottery St Mary has been at the forefront of environmental actions for a very long time. We have enjoyed the benefit of several excellent green groups: Recycling in Ottery almost 25 years ago, followed by Otter Rotters and most recently the Plastic Free Ottery group.
It is, therefore, entirely appropriate Ottery will become one of the first towns to comprehensively address this crucially important issue.
I look forward to Ottery St Mary Town Council engaging with local people - especially with younger people - to fully play our part in tackling the great threat of climate change.
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Friday, 7 June 2019

Bussels No 7A and its link – or not – to the MWWT at Straitgate

So, there are now two independent hydrogeology experts who have serious problems with Aggregate Industries’ scheme to quarry Straitgate Farm; two independent hydrogeology experts who have discredited AI’s hydrogeology reports and found fault with their conclusions. How many more experts will be needed before the Environment Agency sits up and takes note?

Whilst, incredulously, the EA is prepared to accept AI's highly unorthodox working scheme – despite evidence that AI's model of the water table has already failed dramatically – both Dr Helen Rutter and Professor Rick Brassington point to the proposal's serious risk to drinking water supplies to over 100 people, 3 farms and a Grade I Manor House. Prof Brassington says:
any proposals to quarry at Straitgate Farm will impact on the fragile groundwater system and cause the flows of springs to decrease and the quality of the water also to deteriorate 5.7
With the Boeing 737 Max scandal, there has been much talk recently of "regulatory capture", or:
what happens when a government agency’s relationship with the industry it oversees becomes too close for comfort; instead of acting primarily in the interests of the public, it puts the needs of businesses first.
Let’s hope that’s not the case with the EA, who works closely with the aggregate conglomerates – here being just one example.

One section of Prof Brassington’s report was devoted to how – based on the the agency's own policies – the EA should be responding to this application:
it is strongly suggested here that the EA has not recognized that the hydrogeology and groundwater resources of this area are very sensitive and fragile. 5.5 It is expected that the EA should object strongly to this proposal. 5.6
A major bone of contention is the location of the maximum winter water table. AI proposes to quarry down to this level. It clearly doesn’t know exactly where it is.

AI and its consultants Amec Foster Wheeler (now Wood) quote the MWWT to cm precision, yet in places it is clearly out by almost 3m. The EA is of the view that the MWWT can be re-guesstimated using recent elevated levels "immediately before operation of the quarry begins" – despite infiltration plans being unable to work with groundwater so close to the surface – but it has at least pushed AI/AFW to provide tolerances, errors in +/- m, for this surface: numbers first asked for in 2016, which have still not been provided, at least publicly.

AFW say the winters of 2013 and 2014 – conveniently and coincidentally when AI first started monitoring the area – can be relied upon to derive, model, guess, the maximum water table:
Monitoring over the exceptionally wet winters of 2013 and 2014 allow this surface to be defined with confidence. 6.2.2
Both Dr Rutter and Prof Brassington disagree. Prof Brassington says:
...the MWWT is not a representation of the maximum water table readings for the proposed quarry site
Prof Brassington points to the records of Salston Stream – included in AFW’s hydrogeological assessment – which indicate that groundwater levels would have been higher across the site in both 1976/77 and 2000/01.

How then were AI/AFW so sure that 2013/14 could "allow this surface to be defined with confidence"? AFW pointed to other borehole records around the area, compared historic readings with those from 2013/2014, and then employed some smoke and mirrors:
Whilst it is recognised that 2013 and 2014 are considered to be extremely wet years in terms of rainfall, the observed groundwater level data themselves do not provide sufficient context to establish whether the observed groundwater levels might be considered to be close to the historical maximum. Therefore additional historic data for both rainfall and groundwater levels have therefore been obtained from the EA and reviewed to better understand the historical fluctuations in groundwater levels. 4.2
AFW looked at the records for the Salston Stream – one of the four watercourses emanating from Straitgate. It looked at the baseflows – the stream flow sustained between precipitation events:
Daily flow data for the period 1976 to September 2016 have been examined for the nearby weir at Salston, located 2.5 km downstream of the Straitgate site. It is clear that very high baseflow occurred in the winter months of 2012/13 and 2013/14, reflecting high BSPB spring flows (and therefore high groundwater levels). The only previous periods characterised by similarly high baseflow were the winter periods of 2000/01 and 1976/77. 4.2.8





Clearly, however, the baseflows recorded in 2000/01 and 1976/77 – as Prof Brassington points out: "1976/77 being over 11 Ml/d and 2000/01 some 7.5 Ml/d compared with 6.5 Ml/d for both 2012/13 and 2013/14" – were not convenient to AI/AFW’s argument. And here's the clever bit: In the next line – when AFW pointed to borehole Bussels No 7A, for which there are long term records – AI's consultants effectively dismissed both 2000/01 and 1976/77 at one stroke:
The nearest CEH groundwater index well with similar geology is located at Bussels No.7A, constructed in the Permo-Triassic sandstone in the Exe Valley. Groundwater levels in the winter of 2012/13 and 2013/14 rose c. 0.3 m above the previous long-term maximum level recorded in 2000/01. 4.2.8
No mention of 1976/77, but how very convenient for AI. Where actually is Bussels No 7A?



Miles away. Is it representative of monitoring boreholes around Straitgate, which are 6-12m deep? No. Bussels No 7A is 91.44m deep. Dr Rutter says "I don’t consider it relevant":
this well is over 90m deep and unlikely to respond to recharge in the same way as the shallow groundwater.
At Bussels No 7A, "annual fluctuations are normally between 1 and 2 metres." Boreholes around Straitgate see annual fluctuations as much as 6 metres.

AFW also pointed to records from "four EA observation boreholes … within the Otter Valley" to substantiate its claims. However, as Dr Rutter says:
the report suggests that all of the EA monitoring wells show that 2013/14 represented the historical highest GWL. Longmead stopped recording in 2012, and West Hill Village Hall has a short record, therefore this conclusion cannot be drawn from either of these. Salston Cottages looks as if there were similar high levels around 2000/01, and other earlier years… Woodbury Common appears to be the only one that you can say definitely had higher levels in 2013/14. But again, without some comparison of groundwater level responses between this well and the site piezometers, it is not possible to say if this well is representative.
But based on Bussels No 7A, and the other dodgy assortment of borehole records, AFW then made the grand claim – a claim that dictates the total resource and total profit that can be recovered by AI from Straitgate, the raison d'être for the whole planning application – that:
These data provide supporting evidence for using the exceptionally high groundwater level conditions in the winter months of 2012/13 and 2013/14 as indicative of peak (winter) groundwater levels. 
4.2.9
Amazing.

Another case of outright deception from AI’s consultants, or just a simple lack of professional nous? Either way, it won’t bring any comfort to the many people who rely on the area for their drinking water, who will no doubt ask the question: Can any of the conclusions in AI's hydrogeological and flood risk assessments – for example, when the word "unlikely" is used – be trusted?
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When AI and its consultants say ‘unlikely’ what does that mean?

In Aggregate Industries' recent planning application for Westleigh Quarry near Burlescombe, to vary the approved working scheme to extract an additional 600,000 tonnes, one of the supporting documents told us what the word "unlikely" means "in reference to the degree of confidence in predicting an impact on ecological interests".

It’s something to bear in mind, when reading documents in support of AI’s application to quarry Straitgate Farm, when consultants say things like:
It is therefore considered that the proposal is unlikely to impact adversely on the quality of groundwater supplying nearby local private water supplies 5.3.44
Or: 

Birdcage Spring is unlikely to be affected by the excavation

Great Fir Spring… is unlikely to be adversely affected by the dry working proposals
Pitfield Spring… is unlikely to be adversely affected by the dry working proposals

In the Westleigh document, it tells us what unlikely means in an Environmental Statement context:
Unlikely: Probability estimated above 5% but less than 50% 2.9
So, let’s rephrase one of those above statements for Straitgate to reflect that:
It is therefore considered that there is up to 50% chance that the proposal will adversely impact the quality of groundwater supplying nearby local private water supplies
Perhaps that might focus minds at County Hall – more so since AI’s legal assurances for alternative water supplies are "unfit for purpose". Consider for example that Birdcage Spring – which has up to 50% chance of being affected by the excavation and supplies a livestock farm – is miles away from any alternative mains water supply.

We are of course assuming that the consultant’s assumptions – unlikely, highly unlikely or otherwise – have not been swayed by its paymasters. It’s something worth pointing out, because when AI’s consultants say "Cadhay Springs are highly unlikely to be affected by the excavation" – i.e. a "probability estimated at less than 5%" – Professor Brassington, an independent expert authority on groundwater, author of scientific papers and textbooks on the subject, paints an entirely different picture:
the reliance of the Cadhay House and associated businesses on the spring for a water supply means that the EA should object to this proposal 5.5 It is strongly suggested here that any proposals to quarry at Straitgate Farm will impact on the fragile groundwater system and cause the flows of springs to decrease and the quality of the water also to deteriorate. 5.7
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Quarry companies struggle to dig in the right direction, let alone to the nearest cm

At Straitgate Farm, Aggregate Industries proposes to quarry down to the maximum winter water table – wherever that might be.

I am concerned that there is a very steep hydraulic gradient across the site, from around 152m in the west to less than 135 m in the east, and the limited number of piezometers used to grid the water table surface. Variations in the shape of the water table cannot be contoured based on the number of piezometers used in the application.
... groundwater resources of this area are very sensitive and fragile [but] if Devon County Council are minded to grant permission for these proposals, despite the evidence given in this report, they are asked to ensure that an unquarried buffer of at least 3 m is left above the maximum water table to minimise the negative impacts.
It’s standard to leave an unquarried buffer or safety margin in a quarry where nearby groundwater supplies are at risk from pollution or degradation.

Quarries on sites less sloping, or where’s there’s less at stake, might leave less than 3m. Some leave 2m or more. At Town Farm Quarry – a quarry that has the same geology that underlies Straitgate, but where only two properties were reliant on private water – Hanson left 1m. Hanson recognised:
The unsaturated zone above the water table affords protection of the aquifer from surface pollution, allowing adsorption, attenuation and degradation of contaminants prior to reaching the water table. Removal of lower permeability clay layers from within the Pebble Beds could also remove some protection from the groundwater. During the operation of the site pollution may arise from the extraction and restoration activities. The pollution may be in the form of fuel, lubricants and other fluids associated with the operator’s machinery. C3.1
Once upon a time, AI also said it was going to leave 1m unquarried above the MWWT. AI confirmed this to the EA and DCC. The EA said:
Aggregate Industries have proposed to stop quarrying a metre above the water-table. We expect DCC to make this a condition of any permission that is granted.
It was a lie. Resource figures put forward by the company showed that AI intended to leave 0m. It took months before the company came clean on the matter.

But it’s not just that. AI claims it knows where the MWWT is to cm accuracy, and furthermore that it could dig to this. That’s also a lie, not least because water levels have already exceeded AI’s guesstimate by almost 3m in places.

But the truth is, quarry companies find it difficult digging in the right direction, let alone to the nearest cm.

Recent site inspections have highlighted that parts of the site are not being worked in accordance with those approved plans in terms of the directionality of the working.
restoration was not in accordance with the approved plans and failed to achieve a natural slope, leading to some areas becoming waterlogged while the ponds had reduced water levels
Unfortunately, AI is no better. At Houndaller in Devon – the site with 4 million tonnes of permitted sand and gravel reserves that the company is currently working – DCC’s monitoring report of 2016 reported:
The site is in contravention with the requirements of Condition B2 and Condition B6. The requirements of these conditions relate to the order of development in defined phases. The working of phase 4 should not have commenced until the "majority of the restoration, seeding and planting of the following Phases has been completed". 4.3
To "regularise the situation", agricultural land was lost – as DCC's monitoring report 2017 made clear:
To regularise the situation on site the operator submitted an interim restoration plan and a biodiversity statement. The statement provided evidence that the area which had previously been left to naturally regenerate had now developed valuable areas for ecological habitats. It was concluded that it would not be appropriate to regrade this area and return to the approved restoration of agricultural land given that this would then harm established habitats of value. 4.9
The point is, once quarry companies are left to their own devices, anything can happen. We posted examples in What’s the chance that AI would stop digging when it gets to the water table? of how much notice the industry takes of planning conditions and water tables, saying:
To be fair, it’s not just Aggregate Industries that breaches planning conditions – the whole industry is at it.
But what of AI's unorthodox scheme? According to Prof Brassington such a scheme is "untried anywhere else in the country", and:
It is suggested that this operational procedure is too difficult for typical machine operators and so the application should be refused unless there is a much thicker layer of unquarried rock left in place stipulated in the application. 4.20
Clearly, if quarry companies find it difficult to work in the right direction, or in the right phase order, or to the right depth, Prof Brassington has a very valid point.
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EA flood defence scheme ‘will be like building a new quarry next to our homes’

The Environment Agency – in partnership with Blackwater Aggregates, a joint venture involving CEMEX UK – has proposed a 20-year quarrying operation as part of a £9m flood defence scheme for a trio of villages in Essex. Villagers are up in arms. One local councillor likened it to "using a sledgehammer to crack a peanut."

The EA says "quarrying operations... will ultimately support in the delivery of a flood alleviation scheme that would otherwise mean the public purse would need to contribute in excess of a further £25 million."

Councillors are not happy, and say that the EA’s proposals to create "1 in 100 year flood storage" would cause "irreparable damage" to the Blackwater Valley and "are out of proportion with what is needed":
It is not clear that the cause of the 2001 flooding was from the River Blackwater near Coggeshall - the flooding was not simply the result of heavy rain.
We are concerned about the proportionality of the plans and that the Environment Agency has seemingly already made its mind up.
The EA says there is "no viable alternative":
We have forged a valuable partnership with Blackwater Aggregates to develop a scheme fit for the communities - a scheme that not only provides flood protection but will take opportunities to enhance the rich flora and fauna and biodiversity features forming the River Blackwater valley and develop new habitats.
Locals say it will leave them with "20 years of noise, dust and pollution."

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