Consultants misled EA in key report to back Straitgate’s inclusion in Minerals Plan

In 2013, Aggregate Industries’ consultants provided a hydrogeological report to support Straitgate Farm's inclusion in the new Devon Minerals Plan in answer to the Environment Agency’s concerns:

The number of private water supplies suggests to me that this would be a difficult site to take forward. Similarly, if this area is shown to be a significant part of the catchment for the water features near Cadhay, its deliverability as a viable site would seem unlikely.

We posted about the report at the time. The report relied heavily on an earlier report: "S J Parkhouse (1990) Report on the Reserves of Pebble Beds at Straitgate Farm, near Rockbeare, Ref No: GR10/90":

A comprehensive review of the geology across the site was undertaken in 1990. This included the installation of 24 boreholes on an approximate 200m grid across the site, to depths of between 5m and 27m below ground level (bgl), to confirm the local geological characteristics and groundwater levels. 2.2

Back in 2013, AI was claiming it had 3.1 million tonnes of saleable material at Straitgate. Now it’s clear there’s less than 1 million tonnes available, and – according to Professor Brassington – even that can't be quarried without disrupting water supplies for more than 100 people:

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

In his report, Prof Brassington referred to data from the 1990 report, specifically the groundwater level in one of the boreholes. Groundwater levels are important because AI has proposed to quarry down to the 'maximum winter water table'; readings from this borehole puts groundwater 2.8m above the base of any quarry – in the middle of summer.

The EA has proposed to review the modelled MWWT before any quarrying starts – to take into account recorded groundwater levels that have recently exceeded it – but has already chosen to ignore data from 1990, much to Prof Brassington’s concern. In response to his report, the EA said:

We note the groundwater level reading from 1990. However, because this is just one spot reading it is difficult to judge its significance.

In other words, as we’ve already posted, the EA has chosen to ignore data directly from the site, in favour of an assortment of other boreholes miles away from the site.

It was, however, not one spot reading in isolation in 1990, it was part of "a comprehensive review of the geology across the site… to confirm the local geological characteristics and groundwater levels", as described above. The survey was undertaken by an experienced geologist – who had sufficient confidence to record the groundwater level in this location to the nearest cm. The data was relied upon by AI’s consultants SLR in 2013 to sell – to both DCC and the EA – Straitgate Farm’s inclusion in the new Devon Minerals Plan:

The assessment confirms that the site is hydrologically sensitive... [but] has shown that the site can be worked. 3.4

However, the EA was misled. The report by AI’s consultants said:

Previous groundwater monitoring data (undertaken in 1990) indicated that groundwater flows in an easterly direction from 149mAOD in the west to c.136mAOD in the east to the west of the fault. 2.2.1

What that statement forgot to mention – for reasons best known to AI or consultants SLR – was that one of the boreholes in 1990, SG1990/021, "in the east to the west of the fault", did not record water at "c.136m" but at 138.81 mAOD – 2.81m higher than the above statement suggests, and just 1.26m below the ground surface.

Take a look too at the cross sections in that report, particularly Section A-A' with various markers showing "RECORDED GROUNDWATER LEVEL (JUNE 1990)." This section runs from west to east across the site, but conveniently avoids borehole SG1990/021. In fact, notice that next to the fault, the 1990 groundwater level has been replaced with the level recorded from another borehole drilled south of SG1990/021 in 2012. Plainly the 1990 figure – and the extrapolated "APPROXIMATE GROUNDWATER LEVELS (JUNE 1990)" from it, indicated by the blue dashed lines – was far too inconvenient for AI’s consultants to include.

Would the EA have formed a different view on the merits of including Straitgate in the Minerals Plan, if it had been pointed out that groundwater in some locations was just a few feet below the ground surface? We shall never know. It wasn’t the first time that AI’s consultants had been economical with the truth, and it won’t be the last.

More worrying is why the EA – the guardian of our precious groundwater resources – chooses to ignore that data now, without contrary evidence. As Prof Brassington says:

If this [1990] value is to be ignored, then, by the same reasoning, all the groundwater data in the table can be regarded as "spot readings" and dismissed in the same way. If this is the way that the data are to be used to review the MWWT, then there can be no confidence in the results and no confidence in the EA either.

Last week Extinction Rebellion, this week shareholders urge cement co.s to cut CO2

Funds managing $2 trillion urge cement makers to act on climate impact https://t.co/ebLSbrLmjX pic.twitter.com/6clnCXOtQC

— Reuters Commodities (@ReutersCommods) July 22, 2019

As the FT reports:

Oil and gas companies have been the front line for investors concerned about the potential impact of global warming on returns. Now shareholders have a new sector in sight: cement makers.

LafargeHolcim – parent company of Aggregate Industries – is the world’s largest cement maker. Last week, Extinction Rebellion climate protesters targeted London Concrete – part of Aggregate Industries. The company trotted out the statement:

We are cognisant of the carbon footprint of cement and concrete and we are at the forefront of efforts to mitigate climate change.

As we wrote, being at the forefront of those efforts has resulted in:

AI emitting nearly 1.3 million tonnes of CO2 each year, more than 5x the amount in 1999.

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.

This week, shareholders overseeing $2 trillion in assets have urged cement makers – including LafargeHolcim – to cut emissions. Vincent Kaufmann, chief executive of the Ethos Foundation, a group of Swiss pension funds, said:

Construction materials companies may ultimately risk divestment and lack of access to capital as an increasing number of investors seek to exclude highly carbon-intensive sectors from their portfolios.

Stephanie Pfeifer, chief executive of the Institutional Investors Group on Climate Change said:

The cement sector needs to dramatically reduce the contribution it makes to climate change. Delaying or avoiding this challenge is not an option. This is ultimately a business-critical issue.

Business critical? Bloomberg reports: Cement companies are starting to get a $33 trillion headache:

Cement companies are also exposed to prices in the European carbon market, which have quadrupled in value since the start of last year. Besides facing higher costs if they don’t cut emissions quickly enough, the firms can also lose potential revenue from the sale of excess allowances as regulators tighten allocation of allowances in the program, said Stephanie Pfeifer, CEO at IIGCC and a member of the Climate Action 100+ steering committee.



Deutsche Bank, as cited by IIGCC, estimated that cement prices will need to rise by as much as 5% in 2020 to compensate for the gain in carbon costs. The surge will have a negative impact of between 1.3% and 5.1% by 2020 on earnings before interest, tax, depreciation and amortization by 2020 for European cement producers, according to the bank.

CNN reports: The cement industry produces more CO2 emissions than most countries. It may not survive. LafargeHolcim’s response to all this? It issued a statement, the same one trotted out last week:

We are cognisant of the carbon footprint of cement and concrete and we are at the forefront of mitigating climate change.

Whilst for LafargeHolcim it may be business as usual, some companies are stepping up their efforts – just yesterday, 20 global companies with a combined market value of $1.2 trillion have pledged to set more ambitious climate targets:

"Climate leadership has never been more important than it is right now, and it is inspiring to see so many diverse companies and brands boldly raising their ambitions," said Lise Kingo, chief executive and executive director of the UN Global Compact

And she's right. Climate leadership has never been more important. Even the UK construction press see the risks. As this article, Extinction Rebellion targets concrete works, says:

Not since the days of Swampy and his friends held up construction of the M3 through Twyford Down has direct action presented such a risk to construction companies.

As one campaigner, a structural engineer by profession and member of Extinction Rebellion, puts it:

I’m taking part in this action to disrupt concrete production because we have to pause and recognise the harm it is causing both locally and globally; locally with the dust in the air our children breathe and globally with the inextricable CO2 emissions involved which are destroying the world.

Obviously, the boss of the Mineral Products Association has a different spin:

The UK cement and concrete industry takes its environmental obligations extremely seriously and is committed to contributing to a net zero carbon society. Whilst global cement production is responsible for 7% of global CO2 emissions, UK cement emissions are amongst the lowest in the world at less than 1.5% of UK emissions.

Which may, of course, have something to do with the fact that the UK is a net importer of cement. In fact, a couple of years ago, AI was "one of the largest importers of cement in the UK."

* Net CEM CO2 emissions. Total gross direct CO2 emissions 135Mt. Total indirect CO2 emissions 30Mt. Source: LafargeHolcim Sustainability Report 2018

BGS updates Mineral Planning Factsheet – and highlights impact of transport costs

British Geological Survey has published a revised factsheet for construction aggregates.

The latest update of the ‘Construction aggregates’ factsheet has just been published by the BGS to reflect the many recent changes in the structure of the industry, the latest amendments in a wide range of aggregates-related planning issues, plus updated statistics on all aspects of aggregates supply.

A couple of interesting snippets:

Sales of primary aggregates in Great Britain peaked at 300million tonnes in 1989 but have since declined considerably. In 2017 primary aggregates sales for Great Britain were 176.3million tonnes, comprising 114.5 million tonnes of crushed rock and 61.8 million tonnes of sand and gravel, including marine dredged…

Sales of primary aggregates in the UK were some 190 million tonnes in 2017 with an estimated value of £2258 million based on ex-quarry values.

That's around £12 per tonne after processing – before onward delivery. On transport costs:

Aggregates are low value high weight/volume products... Transport is a key element of the supply process. There are two main issues associated with the transport of aggregates. First are the environmental impacts of the supply of aggregates in the immediate vicinity of the quarry (the environmental impacts of more distant transport movements are generally dissipated within the whole transport system). Second, since aggregates are probably the lowest value materials that are transported by road, rail and sea, the cost of transport is an important element of the final delivered cost of the aggregates.

In 2017, the Freight Transport Association put the costs of running a 44-tonne HGV at £140,000 pa. Based on working 250 days a year, that's £560 per day, before any allowance for profit.

For Straitgate, Aggregate Industries has proposed:

... material would be extracted at a rate between 120,000 tonnes and 180,000 tonnes per annum on a campaign basis which means that extraction would be limited typically to 2 or 3 times per year with each campaign lasting between five and seven weeks at a time.

All this material would need to be transported to Hillhead for processing, a 46-mile round trip for each 29-tonne load of as-dug material – which includes 20% waste. The scheme totals some 2.5 million miles.

If we assume, say, 150,000 tonnes per year, extracted over 16 weeks, costs would be in the region of (11 trucks x 5 days per week × 16 weeks) £500k per year – just to haul material to the processing plant – again before allowance for the haulier's profit. All back-of-the-envelope stuff, but a significant cost. In fact, over 10 years, it would cost AI £1m just to transport the waste.

It doesn't look like economics is Aggregate Industries' strongest suit. The haulage scheme is plainly bonkers. Plainly unsustainable. And plainly not, as we keep being told, "at the forefront of efforts to mitigate climate change."

Aggregate Industries targeted by climate emergency protesters

London Concrete – part of Aggregate Industries, and already in the news this month for a fatal incident – has now been targeted by climate protesters.

Extinction Rebellion activists blocked the entrances of its premises in East London:

The disruption is planned to halt the expansion of the site, which is intended to support the construction of the Silvertown Tunnel.

The Silvertown tunnel is a £1bn toll road proposed to run under the Thames.

The project – backed by the London mayor, Sadiq Khan – has drawn widespread criticism from environmentalists, local politicians and others concerned about deadly air pollution in the capital.

Construction "could begin in late 2019 or 2020, with the new tunnel expected to open from 2025." The proposal is opposed by the 'No to the Silvertown Tunnel' campaign. An Extinction Rebellion spokeswoman said:

Concrete has a huge environmental impact and building another tunnel will only make air pollution across East London worse.

The air pollution is already at dangerous levels and is affecting the health of children and adults in the area. With the siting of this industry right next to two schools, these children face lifelong negative impact on their health.

A spokeswoman for London Concrete is reported as saying:

We confirm there are currently peaceful protests taking place outside of our London Concrete premises in Bow, East London and we are cooperating with authorities on this matter.

We are cognisant of the carbon footprint of cement and concrete and we are at the forefront of efforts to mitigate climate change.

Of course, if AI has been at the forefront of any efforts to mitigate climate change, we all know by now how very unsuccessful those efforts have been. As we've posted in the past: If AI’s record is an example of corporate action on climate change, we’re all screwed; and parent LafargeHolcim: Acting in a way that would “wipe out most life on the planet”. We've posted how:

AI's emitting nearly 1.3 million tonnes of CO2 each year, more than 5x the amount in 1999.

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.

BREAKING: Members of Extinction Rebellion East London groups peacefully block the entrance to London Concrete in Bow. This action is part of the #SummerUprising - a week of disruption to urge local councils, industry and government to #ActNow on the climate/ecological emergency. pic.twitter.com/zjnfEEUdIt

— Extinction Rebellion 🌻 (@ExtinctionR) July 16, 2019

Both entrances to London Concrete in Bow currently blocked by peaceful rebels! #SummerUprising #ActNow pic.twitter.com/B6Kh6CwiSq

— Extinction Rebellion 🌻 (@ExtinctionR) July 16, 2019

BBC London lunchtime news report on @LdnRebellion @ExtinctionR @TowerXR @XR_Newham action against London Cement and the Silvertown Tunnel. @Heidi_LDN @sabrodrigues61 @nickbowes1975 @Len_Duvall @MuradQureshiLDN @FloEshalomi @VictoriaRance @CarolineRussell @sianberry @nuttyxander pic.twitter.com/bdkRAWRwLn

— StopSilvertownTnL (@SilvertownTn) July 16, 2019

"Concrete has a huge environmental impact and building another tunnel will only make air pollution across East London worse." - @ExtinctionR https://t.co/ech3BnaJWC

— DW News (@dwnews) July 16, 2019

According to @ChathamHouse cement = 8% of global CO2 emissions. That's why @ExtinctionR / @TowerXR are blockading London Concrete in Bow today #ClimateEmergency #ClimateAction

— DoctorsForXR (@DoctorsXr) July 16, 2019

Tributes to cyclist killed by cement lorry in south west London #scourgeoftheroads #drivers https://t.co/Y04ojfEJUD

— coshgirl (@coshgirl) July 8, 2019

* Net CEM CO2 emissions. Total gross direct CO2 emissions 135Mt. Total indirect CO2 emissions 30Mt. Source: LafargeHolcim Sustainability Report 2018

Professor rebuts EA’s response to his report. Has the EA got it all wrong?

In May, a Professor of Hydrogeology produced a damning report concluding that 'ANY quarrying at Straitgate would cause problems'.

The Environment Agency, through the Area Director of Devon, Cornwall and Isles of Scilly, has now responded to Professor Brassington’s report – essentially dismissing large chunks of it, essentially saying that the person at the EA responding to Aggregate Industries' planning application to quarry Straitgate Farm knows better than a Professor of Hydrogeology who has authored textbooks on the subject, essentially saying the EA found more comfort in the story being spun by an aggregates giant desperate to eke out the maximum amount of material, who, for a long time, couldn’t even come clean on how deep it intended to dig.

The EA – which has a statutory duty to protect the water environment – does however concede:

We agree that it would be challenging for machine operators to excavate precisely down to the planned quarry base (MWWT in summer and MWWT plus 1m in winter). We will therefore recommend to Devon County Council that they obtain a detailed method statement from Aggregate Industries (AI), describing how they plan to achieve this.

The EA has conceded another point too.

Cadhay Spring derives its water from Straitgate, and supplies Grade I listed Cadhay House, surrounding properties and a busy tea room; 60 people are reliant on this source, 2000 people visit the tea room each year. It's an important source. The EA has designated a SPZ across Straitgate in an effort to protect it.

Previously, however, Cadhay was not to be included in any Section 106 covering the provision of alternative drinking water supplies should private springs or wells surrounding Straitgate become diminished or polluted due to quarry operations. We posted about this as far back as 2015 in For those worried about losing their water supply... Now the EA says:

Although we have concluded that it is unlikely that quarrying at Straitgate Farm will affect Cadhay House’s private water supply, we will recommend to Devon County Council that Cadhay House should be included in the Section 106 Agreement. The Agreement includes a groundwater contamination provision. We will recommend to Devon County Council that this is updated to explicitly include pH.

Unfortunately, the EA’s concession does not include the listed mediaeval fishponds – the reason why the Devon Gardens Trust objects. Unfortunately, as a leading planning solicitor has already pointed out, AI’s legal assurances for alternative water supplies are “unfit for purpose”. However, this obviously increases the potential financial exposure for AI. The cost of restoring water supplies to Cadhay would not be insignificant, the reason no doubt why AI had previously argued against the need for Cadhay to be part of any Section 106.

On the subject of the 'Maximum Winter Water Table' – the base of any quarry – not accurately reflecting maximum groundwater levels, the EA continues to rely on a disparate assortment of boreholes to corroborate AI’s estimate of the MWWT, a modelled surface based on the argument that groundwater levels in winter 2013/14 were the highest on record. The EA is choosing to ignore historical evidence from the site – as posted here and here – in particular, the base flow in one of the streams emanating from the site, and groundwater levels from a borehole drilled on the site, both of which contradict that assumption.

The EA’s response can be found here. Whilst disappointing, the EA's letter did leave the door open, saying: "We would be very interested to see any comments from Professor Brassington on the points in this letter." Prof Brassington has now responded to the EA – disputing many of the Agency's conclusions.

Prof Brassington clearly thinks the EA has got it all wrong, in particular the accuracy of the maximum water table and the impact of removing the unsaturated zone.

With respect to the former, he dismisses the comparison with EA observation boreholes:

...the records of observation boreholes across a wide area (Woodbury ED is more than 10 km away) are affected by many factors: different rainfall amounts, geology, depths, neighbouring abstractions, dipping frequency (in the past, most were only dipped monthly), so a competition between observation boreholes has little meaning.

He again points to the Salston stream base flows:

The only conclusion that can be drawn from this hydrograph is that the groundwater levels on the Straitgate Farm site would have been at a higher elevation than those in 2013/14 during the winters of 1976/77 and 2000/01.

He rebukes the EA for ignoring 1990 water levels:

If this value is to be ignored, then, by the same reasoning, all the groundwater data in the table can be regarded as “spot readings” and dismissed in the same way. If this is the way that the data are to be used to review the MWWT, then there can be no confidence in the results and no confidence in the EA either.

With respect to the effect of removing the unsaturated zone, the EA has previously said:

Our main concern previously was the loss of unsaturated zone storage and the potential effect of this on stream flow and private water supplies. The information provided [by Aggregate Industries] gives us sufficient confidence that the rapidity of groundwater flow through the unsaturated zone is such that a reduction in thickness will not result in significant adverse impacts.

Prof Brassington's view, on the other hand, is that such confidence is utterly misplaced:

I do not accept the proposition by Aggregate Industries that the water percolates quickly, so the difference caused by removing almost all the unsaturated zone will make no difference. It will make a great deal of difference.

Again, Prof Brassington's stresses that:

...if quarrying were to be permitted, I maintain that a 3 m unquarried buffer should be left above the maximum water table to minimize the negative impacts

However, he is even stronger in his condemnation of the whole sorry proposal:

I would point out that I remain totally opposed to the idea of this quarrying being allowed to go ahead... In my opinion the proposal that removes most of the unsaturated zone in an aquifer that is fragile is too risky and presents too much of a hazard to the water supplies of a large number of people in addition to those supplies for Cadhay House and its mediaeval fishponds and ancient woodlands.

A copy of Prof Brassington’s letter has now been sent to the EA and DCC.

AI’s latest plans for Marshbroadmoor & Rockbeare in trouble already

Oh dear. Aggregate Industries’ plans to import some 200,000 tonnes of materials that "will consist mainly of subsoils and clays" – as part of its proposal to restore Marshbroadmoor to "areas of mixed woodland" – have come unstuck already. Only last week, we posted about the company’s plans for the sites in AI launches another retrospective planning application.

You would have thought – given that the company has already had airport safeguarding issues with its planning application to quarry nearby Straitgate Farm – that AI would have learnt by now not to propose tree planting on a hill top location directly below the landing path to an international airport.

In 2014, we posted Presumptuous? after AI started planting trees at Straitgate. We said:

Aggregate Industries does not have permission to quarry Straitgate Farm; in fact, the farm is not even in Devon's Minerals Plan. This hasn't stopped AI from starting to mark out where it wants to quarry, with fencing and the planting of tree screens, according to its 'concept plans' - plans not agreed by anyone other than its consultants; not DCC, not the Environment Agency, not Natural England, not Exeter Airport…

And indeed it was presumptuous. Because in 2015, Exeter Airport said:

No trees or hedges must be planted to the west or south of the site. The land in this location already penetrates the OLS and any further penetrations would be unacceptable. Ideally any existing penetrating trees should be removed over time. Any tree and hedge planting should be restricted to the far eastern side of the site and below the 135mAOD contour ensuring trees are not allowed to grow to a height that will cause OLS penetration issues in future years.

Again in 2017 – plainly because AI still hadn’t got the message – Exeter Airport advised:

Tree management and planting should be carried out following the guidance in the attached EDAL tree planting plan to ensure no further penetrations of the Obstacle limitation surfaces.

And so, in 2018, the majority of trees AI had planted at Straitgate – in an effort to provide compensatory habitat for dormice, for all the ancient hedgerows it plans to grub up – were cut down. We posted AI cuts down ‘compensation’ planting; so where does that leave protected species? As we wrote:

It’s a shambles. If we can’t trust AI to do a simple job like managing tree planting in the right place, how can we trust it to dig in the right place, or more specifically for the protection of people’s water supplies, dig to the right depth?

Clearly AI didn’t learn. Its restoration plans for Marshbroadmoor proposes planting areas of woodland higher than 135mAOD, and again Exeter Airport has objected:

The landscaping proposals in this planning application are on ground that is directly below the take-off and climb and approach surfaces for Exeter airport. The land here already penetrates some of the airports safeguarded surfaces which are in place to protect the safe manoeuvring of aircraft in the area and ensure no adverse effects to instrument landing systems.

Any additional tree planting and landscaping works in this area have the potential to further increase the surface penetrations that Exeter Airport already suffers, over time these penetrations should be reduced, and also increase the risk of birdstrike to aircraft that are in a critical phase of flight as they pass over this location either on approach or departure…

A robust Wildlife Hazard Management Plan to include Landscape and Tree maintenance would need to be supplied and approved by Exeter Airport to ensure there is no increase in risk of birdstrike to aircraft and that there would be no further surface penetrations by trees either now or in perpetuity.

Accordingly, Exeter Airport object to the proposal on the grounds of aviation safety.

AI launches another retrospective planning application

Aggregate Industries has launched a planning application, DCC/4132/2019, "to continue importation of inert soils and subsoil to allow for revised restoration contours at Marshbroadmoor including a revised restoration scheme at Rockbeare Quarry."

Mineral extraction at Marshbroadmoor ceased in 2014. Importation of material has since continued despite "3.3 Condition B1 of Schedule B of planning permission Ref. 7/11/98/P0050 required the cessation of operations at Marshbroadmoor by 25th of April 2015."

Over the years we’ve posted about nearby Marshbroadmoor and Rockbeare – the latter being the area that had previously been earmarked, by both AI and DCC, for processing material from Straitgate Farm. We’ve posted things like: AI says it's done this sort of thing before - if so, it was breaching planning conditions, and how AI's asphalt plant at Rockbeare continues to operate without permission.

Incidentally, for anyone banking on Straitgate delivering the goods, Marshbroadmoor was one of the quarries mentioned in AI’s last two quarries in East Devon produced significantly less than expected - and there's every chance Straitgate would too:

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.

This new planning application "includes an overall restoration masterplan for both Marshbroadmoor and Rockbeare Quarry which will provide for a more comprehensive, coherent scheme." The volume of material required to complete restoration is "estimated to be approximately 118,000m3", which at 15 tonnes per load equates to another 30,000 truck movements "likely to average 40 (20 in, 20 out) per day."

One aim of the restoration will be to "to ensure the stability of RB2":

3.19 The large waterbody known as RB2 is a former silt pond. It was originally intended to infill the pond under the previously approved restoration scheme. The pond is currently (and will continue to be) used to accept surface water drainage that is pumped from a sump near the Waycon Precast Concrete site. Given the need to retain the pond and potential ecological value, it is no longer intended to infill completely.

3.20 The restoration of RB2 will be reliant on the stability of the surrounding slopes and silt content. A survey of the slopes is required and the applicant is willing to accept a condition requiring one to be undertaken within a specified timeframe alongside a restoration scheme solely for RB2…

3.22 The reduction in the size of RB2 and the proposed planting will make the waterbody less attractive to birds which may present a bird strike risk given the site’s proximity to Exeter Airport.

Three other water bodies, that were originally proposed to be infilled will now also be retained – directly below the landing path to Exeter Airport – apparently in agreement with DCC.

Mineral extraction at Rockbeare dates from 1947 and at Marshbroadmoor from 1997. The retrospective application seeks to amend the restoration scheme such that the "final restoration of Marshbroadmoor will be completed by April 2022" and "the timeframe for restoration of Rockbeare… remains up to 21st of February 2042."

AI’s consultants say – without any trace of irony – that over that 95-year interval:

5.1 The effects associated with the operational development will generally be considered to be temporary in nature, mineral development and restoration representing a temporary use of the land. Long term effects arising from the finalisation of the operations and final restoration will generally be considered permanent and beneficial in nature.

On the latter issue – how restoration will benefit nature – here’s the document spelling out how AI will deal with the removal of habitat at Marshbroadmoor for nesting sand martins.

It is not considered safe or feasible to maintain or create a face suitable for nesting Sand Martins as part of the final restoration scheme.

Is this another example of Aggregate Industries making space for nature?

Consultation for the above application remains open to the public until 1/8/2019.

Photo: Sand martins at Tarmac’s Arcow Quarry, in North Yorkshire, by Michael Cardus

Quarry firms criticise council for allowing “unregulated mineral extraction”

What hope is there of Devon County Council and the Environment Agency being able to police Aggregate Industries’ complicated working scheme at Straitgate Farm – "untried anywhere else in the country"? What hope of stopping water supplies from being harmed when excavators are let loose? What hope of knowing what goes on, or what depths would be reached, behind closed bunding.

What hope? None at all.

In Yorkshire this month, Quarry firms criticise council for allowing "unregulated mineral extraction":

Two of the country’s leading building materials firms have accused local authority planners of allowing a large mineral extraction operation to continue unregulated.

It's not surprising. Planning conditions are broken all the time.

Recently, we have posted Even aggregate companies are pointing fingers at each other over planning failures, Quarry companies struggle to dig in the right direction, let alone to the nearest cm and What’s the chance that AI would stop digging when it gets to the water table?

Planning conditions are broken in Devon too, often by Aggregate Industries. We have posted Another AI quarry in Devon non-compliant with planning conditions, Would the S106 water monitoring plan for Straitgate be as successful as Blackhill’s?, and Fancy that: AI’s missing S106 water monitoring reports turn up days after last post. We have written:

If AI can't be bothered to fulfil its Blackhill obligations, what hope is there for Straitgate? What hope for people who lose their drinking water supplies? What hope for people whose supplies become contaminated? What hope for timely action, when the last three hydrological monitoring reports for Blackhill have either been submitted late or not at all, when surface flows haven't been measured since 2011?

Cyclist in her twenties crushed by Aggregate Industries cement lorry in Battersea

Today's @EveningStandard splash: https://t.co/0jL6ViLWGS

— Ross Lydall (@RossLydall) July 5, 2019

London Concrete – part of Aggregate Industries – was quoted in the Evening Standard as saying:

It is with deep regret that we can confirm a vehicle owned and driven by a self-employed franchise haulier was involved in a fatal collision with a cyclist. Our sincerest sympathies go out to the family of the deceased. London Concrete are currently working closely with the authorities to fully investigate the incident.

Thats exactly what they're doing, absolving responsibility, despite a LondonConcrete liveried vehicle, driving on behalf of LondonConcrete by a driver vetted by LondonConcrete, dispatched by LondonConcrete, paid by LondonConcrete, on a route likely selected by LondonConcrete.

— Jess Pants (@Janderso549) July 5, 2019

@AggregateUK whomever came out with that statement, and whomever approved it really should lead courses in Corporate Tone-Deafness and the Art of Not-Giving-A-F***

— Jess Pants (@Janderso549) July 5, 2019

The company which owns London Concrete is @AggregateUK. No mention on SM of the tragedy with one of your trucks in #Wandsworth today. And no apology for the most crass “nothing-to-do-with-us, the driver was self employed” ‘statement’ on awful death of cyclist. Appalling.

— Dan Whitworth (@bbcdanw) July 5, 2019

Yesterday a young lady was killed on Wandsworth Road by a cement truck from London Concrete. Three and a half years ago one of their lorries was involved in another serious collision with a cyclist on the same road.https://t.co/BoFrSOdEyA https://t.co/6MfZOIdaCS

— 4 Chords No Net (@4ChordsNoNet) July 5, 2019

We have only recently posted about AI’s HGVs in the real world.

Crikey, yet another change at the top of Aggregate Industries’ aggregates division

Barely 12 months into his role, Pablo Libreros – appointed as "new managing director to lead aggregates business into the future" – is off already. Mr Libreros has moved to LafargeHolcim France. No news of any replacement yet.

Another case of musical chairs, or rats deserting a sinking ship??

It was only last year that we posted AI appoints new head of Aggregates division, again:

Readers may remember that in July [2017] AI appointed Mike Pearce as managing director of its Aggregates division, only to see him move on to Breedon two months later. 

And of course, it was only in December that AI lost another CEO:

During the time that AI has been trying to get its act together in East Devon – to gain permission to butcher a successful farm and risk water supplies for more than 100 people for the sake of a relatively small amount of sand and gravel that could only be processed off-site 23 miles away – the company has gone through three CEOs, and will now be looking for its fourth.

We asked:

Is this simply an indication of how long the Straitgate Farm fiasco has been staggering on, or an indication of deeper problems?

Certainly there seems to have been an attrition of directors recently. In the last few months two other directors have gone: Duncan Reaney, Growth and Innovation Director – who only joined in May 2018, with "a portfolio covering Marketing, Sales Excellence, Internal sales and Pricing" – and James Atherton-Ham, General Counsel – who amongst other duties, "was responsible for the planning and estates and geological services teams".

Closer to home – as we have previously posted – people behind the Straitgate Farm proposal have been leaving too. In fact, the regional director who had been driving the Straitgate project for so many years, before moving elsewhere in the company, can now be found working for a competitor – part of the same company that purchased AI’s bagging operation at Uffculme. Small world.

‘Proposed quarry could affect safety of flights at Airport’

RAF Boeing C-17 Globemaster flying low over Straitgate Farm

Perhaps they have higher standards in New Zealand, where Christchurch International Airport (CIAL) and Air New Zealand say a proposed quarry poses a risk to passengers and pilots from the increased probability of bird strike:

In its submission, CIAL says the proposed quarry "is likely to have more than a minor adverse effect on the safe, efficient and unrestricted operation" of the airport. Ponds for quarry wash and sediment treatment, along with puddles after heavy rain, could attract seagulls and other scavenging birds, "increasing the risk of bird strike". The proposed quarry was also in line with the centre of the main northeast-southwest runway and as a result directly beneath the flight path for arriving and departing planes.

Air New Zealand says it opposes the quarry development for the same reasons. "The risk of bird strike occurring is increased by factors such as bird concentrations as a result of storage of water on sites near to flight paths. Bird strike has the potential to cause serious damage to aircraft and consequently impact the safety of passengers and crew."

Exeter Airport has not objected to quarry proposals at nearby Straitgate Farm, directly below its landing approach –

– but then again they were spun a story from Aggregate Industries that no bodies of water would be created by its quarry proposals; Aggregate Industries being the same people who plan to dig down to the maximum water table at the site, but have not yet been able to work out exactly how high the groundwater rises, the same people whose infiltration ponds can't work in the areas proposed because the groundwater is so close to the surface, the same people whose restoration plans propose "Ephemeral water bodies and species-rich wet grassland to be encouraged in low-lying infiltration areas", the same people who made similar assurances about dry-working elsewhere in the area.

Holidaymakers returning to Exeter Airport, flying low over Straitgate Farm

Canada geese flying over AI’s nearby Blackhill Quarry:

UK construction sector suffers worst output in 10 years

If Aggregate Industries is waiting for the economic headwinds to improve – before progressing its application to quarry Straitgate Farm after continued delays – they may be in for a long wait:

Activity in the UK construction sector "dropped like a stone" last month as it suffered its steepest fall in output since the height of the financial crisis, according to a closely followed industry index.

The headline seasonally adjusted IHS Markit/CIPS UK Construction Total Activity Index posted 43.1 in June, down sharply from 48.6 in May and below the 50.0 no-change mark for the fourth time in the past five months. The latest reading signalled the steepest reduction in overall construction output since April 2009.

Not only that. Construction firms are going under at the highest rate for four years; after the failures at Carillion and Interserve, witness the recent problems at Keir and Costain:

There are now signs that the sector may be facing some serious issues once again as output declines and employment numbers fall.

Last year we pointed to another aggregates company, posting that whilst AI’s profits were down 56% in 2017, Breedon’s profits were up 52%. Now even Breedon is finding the going tough:

On a like-for-like basis, underlying EBIT declined by six per cent... reflecting the slow start to the year due to severe weather, challenging markets, rising input costs and the general uncertainty around Brexit.

Of course, a no-deal Brexit is looking more and more likely as the pantomime in the Tory party plays out – "as though facts are meaningless":

If a no-deal Brexit is as catastrophic as predicted, this could create a perfect storm of job losses, citizens unable to pay off their debts and the economy tanking. This in turn, could lead to a run on the pound and interest rates rising – which is bad news for those with large debt.

Moody's, the international credit rating agency, predicts that the UK is likely to fall into recession after a no-deal Brexit.

So, if Aggregate Industries – and parent company LafargeHolcim, holder of the purse strings – are waiting for things to improve, it may be some time.

‘Time is running out for sand’

Across the world, sand and gravel are being extracted faster than they can be replaced, according to a new report published in the journal Nature:

Most of the trade in sand is undocumented.... Illegal sand mining is rife in around 70 countries, and hundreds of people have reportedly been killed in battles over sand in the past decade in countries including India and Kenya, among them local citizens, police officers and government officials.

A group of scientists has now called for a global monitoring programme for sand resources – "A Global Agenda For Sand":

In order to move towards globally sustainable sand extraction, we need to fully understand the occurrence of sustainable sources, and reduce current extraction rates and sand needs, by recycling concrete and developing alternative to sand (such as crushed rocks or plastic waste materials). This will rely on a knowledge of the location and extent of sand mining, as well as the natural variations in sand flux in the world’s rivers. A global sand monitoring program is thus imperative.

The researchers say there are seven components essential for sustainable sand extraction: Source. Replace. Reuse. Reduce. Govern. Educate. Monitor.

At least three of those components are as applicable in the UK as they are elsewhere:

Replace. Local and national governments and planning authorities should encourage greater use of alternatives to sand, such as crushed rock, industrial slag and waste (including copper, fly ash and foundry sand) and recycled plastic. For example, roads, car parks and driveways made from plastic waste embedded in asphalt can lessen demand for bitumen and aggregate.

Reuse. Sand-based materials should be reused when possible. For example, demolition waste and concrete can be crushed and mixed into cement. Rubble can be used as a base aggregate for building foundations and roads, for filling holes and as gravel for walkways, gardens, noise barriers and embankments. Legislation and controls on the disposal of concrete, and financial incentives to reuse old concrete, will be needed.

Reduce. Cutting the amount of concrete required in new structures would also lessen the demand for sand. This could be achieved by using more efficient materials (such as concrete blocks and printed construction panels with hollow cores). Industry standards for material qualities will be needed and should be backed up by regulations to enforce usage.

Comment: Sand and gravel are being removed faster than they can be replenished. Sand mining, both legal and illegal, needs to be monitored and managed globally. https://t.co/GgpKZjjMgq

— nature (@nature) July 3, 2019

Deep sea mining: Have we lost our minds?

In too deep: why the seabed should be off-limits to mining companies | Chris Packham | Opinion | The Guardian ⁦@GreenpeaceUK⁩ https://t.co/jNAlHNekE5

— Chris Packham (@ChrisGPackham) July 3, 2019

On practically every mission down to the deep, scientists discover new species. We know more about the surface of Mars and the moon than about the bottom of the ocean. Mining the deep sea sounds just as ludicrous as mining the moon.

We’ve already seen the huge destruction ravaged upon our planet by corporations mining on land. Are we really prepared to give the go-ahead to the mining industry expanding into a new frontier, where it will be even harder for us to scrutinise the damage caused?