What Strava tells us about AI’s haul route

Birdcage Lane is hardly used by anyone, argues Aggregate Industries' Transport Assessment. Someone apparently counted vehicles on Birdcage Lane at "peak hours", and came to the answer of one.

What a perfect place to put up to 216 44-tonne HGVs a day. Who on earth would notice?

But Birdcage Lane’s low frequency of traffic is what makes it so attractive to pedestrians, joggers, ramblers, dog-walkers, cyclists, horse riders, and even five-time Olympic runners. It was why, with the backing of highway consultants Vectos, another site access point was suggested to eliminate pedestrian and HGV conflict.

Aggregate Industries' Transport Assessment is silent on the pedestrian use of Birdcage Lane, save for:

1.1.6 To reduce the potential interaction of pedestrians and HGV’s in a rural environment a footway will be provided along Birdcage Lane to the point where the new section of Permissive footpath is proposed.

This would have a "1.2m maximum width" and be overgrown in no time. But it’s the thought that counts, and we should consider ourselves lucky.

In the past, Aggregate Industries' consultants have disputed that Birdcage Lane is used by pedestrians:

The roads adjacent to the application sites are not ideal for pedestrian use. 
4.1

It was of course nonsense. Aggregate Industries, if asked, would no doubt still dispute that these quiet lanes have amenity value. Show us the proof, they might say. And modern technology does.

Strava: a social fitness network, that is primarily used to track cycling and running exercises, using GPS data.

Click on the screenshot below to show the pedestrian use of Birdcage Lane:

Aggregate Industries' consultants should clearly have been counting bipeds and quadrupeds as well. But then again, that wouldn't have given them the answer they wanted, would it?

Strava also tells us about the B3174 – the road that Aggregate Industries wants to use to haul sand and gravel. The company's previous TA said the B3174 was unattractive to cyclists. The latest TA is silent on the matter of cyclists and the interaction with up to 216 HGV movements a day, save for:

3.2.13 There are no designated cycle routes within close proximity of the proposed mineral extraction site, however proficient cyclists may utilise the network of quiet lanes.

Clearly they use more than just the quiet lanes. The screenshot below shows cyclist use of the B3174:

Plainly – and this won't be the last example – Aggregate Industries' Transport Assessment has been found deficient. Consultants have not assessed ALL road users around the site. How very remiss. How very unsurprising.

Another accident on B3174 Exeter Road

There was yet another accident just outside Straitgate Farm last night – again highlighting the dangers of this road, and its unsuitability for Aggregate Industries' plans for up to 216 HGV movements a day.

Of course, the company’s Transport Assessment paints a picture of sunshine and roses. It claims:

3.2.28 In summary one serious and two slight collisions have occurred on the examined section of highway network over the five year period.

If only it were so. We have posted about various accidents that have come to our attention over just the last 3 years – here, here, here, here, here, here, here, here, here, and here. No doubt there will have been many others.

HGV movements at Straitgate would be 70% higher than UK’s biggest mining project

Aggregate Industries' proposal to quarry Straitgate would generate up to 216 HGV movements a day.

To put that number in context, let's look at the biggest mining project in the UK: the Sirius Minerals project to extract polyhalite at its mine at Dove’s Nest Farm in the North York Moors National Park.

The project has recently run into problems. Now – earlier than expected in an effort to 'de-risk' the project for investors – the plan is to transport the fertiliser above ground, from the Woodsmith Mine near Whitby to Teesside. According to TeessideLive, Sirius Minerals plan to bring polyhalite to Teesside by lorry – but only 63 journeys allowed a day:

Sirius Minerals plan to bring polyhalite to Teesside by lorry - but only 63 journeys allowed a day https://t.co/zkzUHjdU2s

— News on Teesside (@NewsonTeesside) November 18, 2019

Planning permission is already in place for Sirius HGV vehicles to make 63 return journeys a day, along the A171 and into Teesside.

It was sought by the firm from the outset to cover an interim period between reaching first polyhalite and building the remaining infrastructure needed to transport it underground.

Indeed, the North York Moors National Park Authority Planning Committee Report talks about:

the worst case scenario of 127 daily HGV movements 15.6.5

By contrast, the number of HGV movements that would be generated by Aggregate Industries if quarrying were to proceed at Straitgate are up to 70% higher – part of the route on a B road as little as 5.3m wide.

Rockbeare update

Further documents have now been supplied in connection with Aggregate Industries' 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."

We have already posted on this application: AI launches another retrospective planning application, AI’s latest plans for Marshbroadmoor & Rockbeare in trouble already, Natural England tells AI to make space for sand martins at Rockbeare, Both AI’s recent planning applications for Devon have run into problems with the EA.

Aggregate Industries, through its agent, says:

The changes deliver a significant reduction in the timescales for restoring Marshbroadmoor and the remaining areas of the Rockbeare site; provide a solution for securing the restoration of the RB2 void and provide long term alternative habitat for nesting sand martins at Beggars Roost.

It’s not clear how these revised proposals answer the concerns of Exeter Airport, which objected on the grounds of aviation safety, given that "any additional tree planting and landscaping works in this area have the potential to further increase the surface penetrations that Exeter Airport already suffers."

Nevertheless, as we previously posted:

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."

Now, "a reduction in end date for the restoration of the Rockbeare site to the 31 December 2028 at the latest" has been proposed.

However, let’s not get carried away. If you look at the recent monitoring reports for Rockbeare – for 2019, 2018 and 2017 – you will see it has been a protracted effort to get Aggregate Industries to restore this site. Throughout these reports you will see the comment:

Mineral Planning Authority was notified on 11 October 2017 that mineral working/tipping operations ceased circa 1995

Yes, 1995. And in 2019 we're still discussing restoration.

Planning conditions for Rockbeare are governed by ROMP 7/11/98/P0050. Given that operations ceased at Rockbeare so long ago, let’s look at what condition "A20. RESTORATION IN THE EVENT OF PRIOR CESSATION OF WORKING" says:

In the event of a prior cessation of winning and working of minerals prior to the achievement of the final agreed levels, as referred to in Conditions A17 and A18 above, which in the opinion of the Mineral Planning Authority constitutes a prior permanent cessation within the terms of Paragraph 3 of Schedule 9 of the Town and Country Planning Act 1990, a restoration scheme, to include details of the aftercare (see Condition 19 above), shall be submitted for approval to the Mineral Planning Authority within 3 months of being so requested by the Mineral Planning Authority. The Approved Scheme shall be implemented within 12 months of approval, or within any such other period as may otherwise be agreed in writing with the Mineral Planning Authority.

So, even if restoration does get completed in 2028, that’s 33 years late. What a relief to know that quarrying is only "temporary in nature". 

Even now, in the latest Monitoring Report, with regard to condition "A2. DEVELOPMENT ACCORDING TO SUBMITTED PLANS", Devon County Council says:

A planning application has been received to address the above however this is yet to be determined. This is due to outstanding issues relating to; mitigation for sand martin nest holes; suitable restoration and infilling of RB2; and, conflict with haul roads and permissive paths in the restoration scheme. The operator is required to address this information on or before 31 January 2020 to avoid enforcement action by the County Council.

But then littering the 2018 Monitoring Report were also threats of enforcement action, as there were in the 2017 report too. Perhaps that’s just the way that Aggregate Industries operates.

AI’s application to continue to work secondary aggregates at Lee Moor approved

The above photo shows the production of secondary aggregates from china clay by-products at Lee Moor, near Plymouth. It is taken from the Devon Minerals Plan. In August, we posted that Aggregate Industries had submitted another planning application to work minerals in Devon:

Planning application DCC/4146/2019 seeks to continue to work secondary aggregates at Lee Moor, near Shaugh Prior on the outskirts of Plymouth. The site is not far from Drakelands – the tin and tungsten mine at Hemerdon that also sits as an unrestored scar on the Devon landscape after the operator went into administration last year.

AI wants to deepen the extraction area of Tip T1 from 256m AOD to 228m AOD, to realise 4 million tonnes and "secure the future of the site until 2049/50"

We later posted that the Environment Agency had objected:

The previous use of the development site presents a high risk of contamination that could be mobilised during operational phases and pollute controlled waters.

Devon County Council responded:

The issue is conflict with the already approved overarching restoration of the Lee Moor complex. Details of which can be found at: https://planning.devon.gov.uk/PlanDisp.aspx?AppNo=DCC/2977/2010

Requiring that the a landform be re‐created for the interim period could be very difficult to justify if not offered by the operator.

The Environment Agency replied:

We take your point.

When the ROMP comes around again, ideally we’d like to see some effort is made towards progressive land‐forming.

This would go some way to addressing those run‐off issues that we highlighted.

And that was that. Three months after being submitted, the application has now been approved with conditions, under delegated powers. This is the officer’s report for anyone interested.

Aggregate Industries – and possibly even the Environment Agency and Devon County Council – must surely wish that every planning application for 4 million tonnes of aggregate could be that simple.

Professor who criticises AI’s plans for Straitgate awarded Whitaker Medal

We recently posted Professor Brassington to be awarded the Geological Society's Whitaker Medal:

The Professor of Hydrogeology who said 'ANY quarrying at Straitgate would cause problems' is to be awarded the Whitaker Medal "in recognition of an outstanding contribution to hydrogeology."

Professor Brassington received the prestigious award in London today.

#Ineson2019 Prof Rick Brassington of ‘Field Hydrogeology’ book fame (now in 4th edition) receiving the 2019 Whitaker Medal 🏅for distinguished hydrogeologists👏 @geolsoc @Geolsoc_hydro @iahgroundwater pic.twitter.com/ZPh1n5x3gz

— Geoscience EnvAgency (@GeoscienceEA) November 25, 2019

Devon Climate Emergency Response Group

The Devon Climate Emergency Response Group – made up of Devon’s councils, emergency services and business groups – has set up a Net-Zero Task Force who "want your ideas on how to reduce carbon emissions as quickly as possible."

The Net-Zero Task Force has been tasked with delivering the Devon Carbon Plan.

The Carbon Plan will lay out in stark terms what every resident, organisation and business has to do to reduce emissions and help safeguard the planet for the next generation.

This Call for Evidence is open to everybody, and submissions can be made through the Devon Climate Emergency website, and every submission will be reviewed by the Task Force.

Evidence can be submitted through to early 2020.

Of course, one idea for the Devon Carbon Plan for a start would be for Devon County Council to adhere to their own existing climate change policies. Look at page 36 of the Devon Minerals Plan, for example:

How is Aggregate Industries’ multi-million-mile haulage plan for Straitgate supposed to fit with that... and our existential crisis?

All this comes as the climate crisis is seen as the 'most important issue' by the public, an eight-country poll shows. In the UK, concern about climate change has also reached record levels.

The climate crisis will have a huge impact on racism, division and conflict in future years unless it is tackled now. HOPE not hate has commissioned polling to better understand the issue and how we confront it: https://t.co/hBvJuj6RR2

— HOPE not hate (@hopenothate) September 19, 2019

Nick Lowles, from UK-based anti-racism group Hope not Hate, which commissioned the survey, said the findings showed that the public were "way ahead" of politicians in recognising the scale of the climate crisis. "They understand the scale of the problem and want governments to take the strong and decisive action that this emergency requires."

Plans to turn Incinerator Bottom Ash into secondary aggregates in East Devon

Planning application DCC/4135/2019 will come before Devon County Council's Development Management Committee this week, proposing:

Change of use from In-Vessel Composting Facility to Incinerator Bottom Ash (IBA) Recycling Facility to import and process up to 90,000 tonnes of IBA per annum, Former TEG In Vessel Composting Site, Stuart Way, Hill Barton Business Park, Exeter

The processing of IBA has been a long running issue in Devon. Readers may remember the plans to process IBA at Buckfastleigh’s Whitecleave Quarry, which we posted about at the time, and which were rejected at appeal. Plans were then in play to build a processing plant in Plymouth – which came to nothing. Now the material – currently shipped to the Netherlands – is set to be processed in East Devon.

Concerns have been raised by local residents on noise, traffic, visual impact, dust and the nature of the material to be processed. According to the officer’s report:

6.5. The application proposes processing up to 90,000 tonne of material per annum, with this figure derived through the current contracts of the applicant and potential future operations: 60,000 tonnes from the Plymouth energy from waste facility – this is currently operational with IBA being transported to the Netherlands; 15,000 tonnes from a Bridgwater energy from waste facility – this facility is consented, and construction has commenced; and 15,000 tonnes from Hill Barton energy from waste facility – this facility is consented.

6.6 It is understood that the IBA generated by the Exeter energy from waste facility is currently contracted to be managed in Avonmouth.

The IBA will be processed into aggregates (IBAA) which will "reduce the need for land-won aggregates":

6.30. The primary benefit of the application would be the management of a waste material and production of a secondary aggregate within Devon that would reduce the need for land-won aggregates and the use of natural resources, an approach supported by the Aggregates Hierarchy in the Devon Minerals Plan.

Each year, "approximately 7,450 tonnes of metals will be recovered" and "67,500 tonnes of IBAA will be exported from the site".

6.30. Plymouth City Council require 95% of the IBA produced at the Plymouth energy recovery facility should be recycled to optimise the use of the IBA in the most sustainable way. Details to secure the use of the treated bottom ash as an aggregate for local infrastructure and engineering projects has also been approved by Plymouth City Council, which includes a marketing strategy.

To put that IBAA figure in context, figures for 2017 – still the most recent available – showed that Devon’s land-won sand and gravel sales were 598,000 tonnes.

Bovine movements revisited – more than 2 years on

With Xmas fast approaching it must be time to talk about the cows again. We’ve had some fun with the issue of cows before: You have two cows being one example, this helpful suggestion being another.

Aggregate Industries may know something about the the quarrying industry – although given what a pigs-ear it’s made of its application to dig up Straitgate Farm that’s questionable – but it's got into a real mess with the cows. Incredibly, more than two years on, according to information released recently through a Freedom of Information request, the subject is still taxing both Devon County Council and Aggregate Industries: the cattle crossing issue is still not resolved, and safety assessments of cows crossing this road have still not been made.

As long as it’s done safely, a farmer has as much right to drive cattle on a public highway as an aggregates company has to fill it with 44-tonne HGVs. After all, many of our public roads had their origins in the movement of livestock. And lest we forget, farming needs our support:

Agriculture is an integral part of the Devon economy and wider community, and in difficult and rapidly changing times this sector needs support, to ensure local food production continues to exist and grow for the future.

Not our words, but those of Devon County Council. Natural Devon adds:

Farming is intrinsic to Devon. Today, agriculture and food production accounts for 13% of the county’s economy, compared to 7.6% nationally. As well as providing us with food and drink, over the centuries farming has created diverse and beautiful landscapes and wildlife habitats.

Straitgate Farm – the farm that Aggregate Industries wants to take for quarrying – has indeed been around for hundreds of years; the land has been farmed for thousands. For the last 80 or so of those, it has been a dairy operation. The majority of the land is classified as "best and most versatile". The Devon Minerals Plan reminds us that "a proposal affecting the best and most versatile land should provide for the restoration of the land to its former quality 8.7.9". The Plan also states:

The [Straitgate] site should be restored to enable resumption of agricultural use… The working and restoration phasing should minimise the area of land not in cultivation, as soil is best conserved by being farmed rather than stored where some deterioration may occur. C.4

Aggregate Industries’ Supporting Statement on the other hand warns that, after the mineral has been worked "in a series of phases over a period of between 10 and 12 years 3.2.1", the land will be no good for anything but "light intensity agricultural grazing 3.8.7".

Straitgate Farm has around 150 cows and access to around 150 acres on the north side of the B3174 Exeter Road. Of those, 120 acres are owned by Aggregate Industries, 105 acres of which are the subject of its planning application. The farmer has access to 82 acres to the south of the B3174, which are not owned by Aggregate Industries.

As we told Devon County Council back in March 2017, in our response to the application, and as we posted in Bovine movements the following month: In Aggregate Industries’ rush to get its hands on the sand and gravel, it had forgotten all about the cows:

With less pasture, the dairy herd would need access to more fields, available on the south side of the B3174. What safe provision would be provided for the dairy herd to cross this road four times a day?

It was, in Devon County Council’s subsequent Regulation 22 request and as we posted, the number one thing that AI had to answer. The Council wanted Aggregate Industries "to assess the implications of the farmer moving cattle across the B3174 as a result of the proposal":

It has been suggested that the reduction in available farmland on the Straitgate side of the B3174 means that there will have to be cattle movement across the road to land on the south for grazing and milking. As the applicant is the landlord for the Agricultural Tenancy then the MPA would request a joint statement of the likely impact and number of such agricultural movements on the safety of the public highway. If it is the case that this will happen as a result of the proposal then the impacts should be factored into the safety assessments and traffic calculations.

Aggregate Industries' response?

The new route would include a proposed cattle crossing on the B3174 Exeter Road. The number of daily movements over the proposed cattle crossing at times when the dairy herd is grazing the land south of Exeter Road would be twice in each direction.

The issue made the front page of local papers:

The MP got involved. The Leader of Devon County Council advised Hugo Swire MP in 2018:

...the applicant was also asked to provide a joint statement with their tenant with relation to farm crossing movements and how they might be managed.

However (and with this application there’s always a however) neither "a joint statement" or "safety assessments and traffic calculations" have since been provided. More on the latter in a future post, but on the former, as recently as February of this year, Revision C of the Transport Assessment did contain a joint statement, authored by Aggregate Industries but unsigned:

3.2.4 At the request of the Mineral Planning Authority a Joint Statement has been prepared which reproduces the information provided by the Tenant Farmer above and outlines the commitment of Aggregate Industries UK to the proposed mitigation that will negate the need for additional livestock movements across the public highway that currently forms the baseline, a copy of this statement is reproduced within Appendix E for reference.

3.2.5 Although the purpose of the Joint Statement is to assist in formalising the information already provided by both parties the Tenant Farmer has been advised by their Solicitor and Agent not to sign the document. However, the fact that the document has not been signed does not detract from the validity of the baseline information supplied to date by the Tenant Farmer.

Since then, Aggregate Industries has had that unsigned joint statement removed, to be replaced in Revision E with a no-more-binding email instead. The company’s TA now says:

1.1.8 It has been agreed with the Tenant farmer that by the provision of new cow tracks, access points and other appropriate infrastructure, preceding or in parallel with the quarry development, that there will not be a need to intensify livestock crossings over the B3174 Exeter Road above that already stated as the baseline.

1.1.9 The Applicant, Aggregate Industries UK, will work with any current or future operator of the farm to maintain sufficient grazing such that livestock crossings will not need to increase above the baseline stated within the email from West Country Rural Ltd.

That referenced email concludes by saying:

In the event that no cow tracks were installed at Straitgate, and in time that no additional cubicle housing were erected to house the dairy herd these movements would need to occur daily.

So, to be clear: When Aggregate Industries says "it has been agreed", it has not. Aggregate Industries is just relying on a third party email. There is no agreement, no signature, no signed joint statement of the type promised to our MP.

So, to be clear: When Aggregate Industries says "other appropriate infrastructure" – cubicle housing, or whatever – the TA is not offering to supply that.

So, to be clear: When Aggregate Industries says "maintain sufficient grazing", Phase 1 alone of any quarry would take away 56 acres, which – according to 3.4.10 of Aggregate Industries’ Supporting Statement – would not be restored until Phase 3:

Initially, the applicant will need to resume some 22.5ha to facilitate the first stage of the proposed development (Phase 1). In addition to the area required for mineral extraction, this area will include the land required for temporary soil storage bunds and access. 2.1.10

But more of that another day.

So, if land is taken away for quarrying, it goes without saying that the farmer – to maintain a viable operation – would have no choice but to regularly take the cows to the other side of the road for replacement pasture, cows that would need to be returned to the parlour to be milked, crossing the B3174 Exeter Road up to four times a day in the process. It's what farmers do elsewhere in the county, and the country – see the post below.

Where does that leave us? At the end of September, Devon County Council – following advice from their Highways Management department – wrote to Aggregate Industries saying:

The application needs to include the proposed agricultural access (TA 5.5.10) to the west of the existing farm access and directly opposite the existing field gate, to improve upon the current diagonal crossing point. That would enable a shorter traverse of the highway by livestock, effectively reducing crossing times. The Highway Authority also considers that these proposals should include holding pens on both sides of the road to assist in the efficient movement of the livestock. It appears that this would be a betterment of the existing situation and is related to the proposed mineral working based upon the worst case scenario of the available cattle movements, as put forward (TA 3.2.3) in the email from the Tenant Farmer [sic] to the Mineral Planning Authority dated 26 February 2018. The inclusion of the above is, we believe, outside of the application site and therefore it would possibly require a resubmission of the application to include it. However we do not believe that it is sufficient for the applicant to merely offer this to the Tenant Farmer and the Highway Authority without any means of the MPA being able to condition it.

Of course, Aggregate Industries does not control any land to the south of the B3174 that could be used for "holding pens" and be part of its planning application. What’s known as a Grampian condition would be needed: "a planning condition attached to a decision notice that prevents the start of a development until off-site works have been completed on land not controlled by the applicant." Devon County Council’s solicitor advised the Council’s head of planning by email that "the conditionality of the Grampian must be within the applicant’s gift to deal with, and there must be a reasonable prospect of so doing." So, that’s another complication.

And that’s where – more than two years on – we stood at the end of September, the date of our FOI, regarding just one of the issues raised by this contentious application.

Clearly – and for such a busy and fast road – this is something that needs to be carefully assessed before determination, otherwise we could end up with situations similar to this:

Only in Devon 😂🐮🚨👮‍♂️🤷🏾‍♂️ @DevonAlert @BBCDevon @DevonLiveNews @DevonLife @DC_Police #A30eastbound #Cows #Devon #Devon&Cornwallpolice #Moooooooove pic.twitter.com/xjXYtgYzK1

— Ben Hosgood (@bhosgood) May 9, 2019

Bovine movements revisited – cows crossing roads, in Devon and elsewhere

Aggregate Industries' plans to quarry Straitgate Farm – removing pasture for 150 dairy cows – would result in increased livestock movements across the B3174 Exeter Road to access replacement grazing; see the post above.

Aggregate Industries are not farmers. Their traffic consultants Horizon are not farmers. Their Transport Assessment – which was supposed to address the issue that cows crossing the B3174 would have on safety and traffic – does however claim: 

3.2.6 Dairy herds of similar size have been observed at other farms in Devon crossing a similar distance, without splitting the herd, in 4 minutes.

Despite Aggregate Industries' expert un-biased observations, cows can't be hurried – holding pens or not.

The photos below are from the geograph web site. Click on any photo for more detail.

Professor Brassington to be awarded the Geological Society’s Whitaker Medal

The Professor of Hydrogeology who said 'ANY quarrying at Straitgate would cause problems' is to be awarded the Whitaker Medal "in recognition of an outstanding contribution to hydrogeology."

Very pleased to hear that Prof Rick Brassington will be awarded with the @geolsoc_hydro Whitaker Medal at #Ineson2019. There is still time to register. It's on 25th November 2019 at the Geological Society, Burlington House, London https://t.co/ie8HCweCG5 pic.twitter.com/6sobu4Zt97

— Tim Besien (@timbesien) November 12, 2019

The Whitaker Medal is awarded in memory of the distinguished geologist, William Whitaker and was first awarded by the Institution of Water Engineers in 1930 to R.C.S. Walters for his paper on the hydrogeology of the Chalk in England. Since that time, the Institution and its successors awarded the Medal a further fourteen times to a total of 24 individuals. Since 1996, the Medal has been awarded by the Hydrogeological Group in recognition of an outstanding contribution to hydrogeology.

Earlier in the year, Prof Brassington was asked to give his view on what impact Aggregate Industries' proposal to quarry Straitgate Farm would have on Grade I listed Cadhay and local water supplies. Along with the above-mentioned post, we also posted Professor rebuts EA’s response to his report. Has the EA got it all wrong? and EA wants AI to address Professor’s water concerns.

The news of Prof Brassington’s award was retweeted by the Environment Agency's Groundwater & Contaminated Land team. It’s ironic, because a member of this team has decided to dismiss this eminent hydrogeologist's view on the Straitgate proposal – in favour of their own, and that of the consultants working on behalf of a multinational cement conglomerate. There's more about this in the post One person below.

Another damning response from Professor of Hydrogeology on AI’s Straitgate plans

Part 1:

For the third time, Professor of Hydrogeology Rick Brassington has weighed in against Aggregate Industries’ plans to quarry Straitgate Farm, setting out in no uncertain terms the damaging effects this would have on Grade I Cadhay and local groundwater supplies.

Prof Brassington was responding to a letter from Aggregate Industries’ consultants Wood, that was itself written in response to his earlier report and letter.

The Environment Agency – or rather, the person at the Agency overseeing this proposal – had previously accepted, at face value, the various statements made by Wood, and had advised Devon County Council that the EA was nevertheless maintaining its earlier position – without first giving Prof Brassington the opportunity to respond. What does that say about the EA? More of that in Part 2.

Prof Brassington’s dismissal of Wood’s response is forthright:

There are many aspects of the letter from Wood to Aggregate Industries that I find disturbing because they are inaccurate.

Unfortunately, Wood has a fundamental misunderstanding of how [the Cadhay fishponds] operate.. It is both shocking and disappointing that consultants who have been working on this project for so long have made such a fundamental mistake.

The proposal to quarry the Straitgate Farm area to the MWWT will impact on the Straitgate and Cadhay Springs and cause a significant deterioration in the water quality.

[The removal of most of the unsaturated zone] will inevitably mean a redistribution of the groundwater discharges and lower flows during dry periods that could easily cause water shortages to those using the springs for water supplies.

I find it incredible that Wood has dismissed my suggestion that the local aquifer is of limited extent and is both fragile and unique with the large number of people and businesses depending on the springs it supports for their water supply. The streams that flow from the springs also support local habitats especially Cadhay Wood and Cadhay Bogs. It is my view that this application should be turned down and that no quarrying be permitted as to allow it will threaten these water resources for many years to come.

Clearly, Prof Brassington is in no doubt about the damage this proposal would do, to this aquifer "both fragile and unique". Some of his closing remarks are particularly scathing:

Aggregate Industries has a cavalier attitude to meeting deadlines in agreements that they have signed up to and consequently cannot be trusted.

Wood’s arguments dismissing the water level reading recorded in borehole SG1990/021 have been shown to be untrue… the water level reading in SG1990/021 measured on 12th June 1990 is a true measure of the local water table and should not be dismissed as Wood has done.

Their statements in the hydrogeological report [on the Salston Stream] are in conflict with their present opinion that now show a convenient opposition to the points raised in my report.

The significant removal of most of the unsaturated zone will cause a change in the groundwater chemistry… Wood seems incapable of grasping this simple fact.

On the issue of the Section 106:

I welcome the fact that Aggregate Industries now have “no objection” to including the Cadhay Spring, mediaeval fishponds, and wetland habitats of Cadhay Bog and Cadhay Wood’s ancient woodlands in the Section 106 agreement. However, I am keen to learn from Devon County Council exactly how any damage to these water features could be undone in the event of adverse impacts from quarrying.

On revising the model of the maximum water table, the MWWT, the base of any quarry:

This should be done before planning permission is determined so that the new MWWT surface can be seen by Aggregate Industries, the Environment Agency, Devon County Council and local residents in order that the implications and the need for mitigation measures can be assessed.

To remind readers: It was in May of this year that we posted Professor of Hydrogeology says ‘ANY quarrying at Straitgate would cause problems’; in July, Professor rebuts EA’s response to his report. Has the EA got it all wrong?; and in August, EA wants AI to address Professor’s water concerns. In September, Aggregate Industries' consultants Wood did indeed respond, and on that basis – without first giving Prof Brassington the chance to address Wood’s letter – the EA said:

Having reviewed the further information submitted we maintain our position in respect of this proposal. We have no objections to the proposal only if the conditions we have previously recommended are included on any subsequent planning permission. We are pleased to note that Aggregate Industries have no objection to Cadhay House Spring being included within the Section 106 agreement.

In light of Wood’s dodgy dossier, Prof Brassington says:

I strongly urge the Environment Agency to review the comments that I have made here and revise their views on this application.

Devon County Council also have a duty to protect groundwater, as set out in Policy M21 of the Devon Minerals Plan 2011- 2033. It seems to me that such duties are made more important when many of the springs that represent discharges from the area it is proposed to quarry are used as private drinking water supplies and the proposal threatens their water quality.

Prof Brassington's latest response can be found here.

One person

Part 2:

The impact on water supplies is one of the most contentious aspects of the proposal by Aggregate Industries to quarry Straitgate Farm.

Perhaps the Environment Agency no longer cares whether this planning application is built on truth, or whether people lose their water supplies, or whether heritage features are ruined, or whether wetland habitats in ancient woodlands are destroyed. But if the EA had bothered to wait for the Professor’s advice – advice from an independent expert, author of scientific papers and hydrogeology textbooks, and now winner of the prestigious Whitaker Medal "in recognition of an outstanding contribution to hydrogeology" – rather than rushing to accept the advice of a say-anything cement conglomerate, they would have discovered that Woods’ reply was in fact inaccurate. That’s covered in Part 1 above.

However, a word of warning: It might shock readers to learn that the Environment Agency’s technical position on this application – and therefore Devon County Council’s position, because it blindly follows – for the whole groundwater environment: the private water supplies to businesses and 100 people, the wetland habitats in ancient woodlands, the listed fishponds – is based on the views of just one person at the Agency. Yep, JUST ONE.

Even when concerns have been sent through legal channels to the Area Director for Devon, Cornwall & Isles of Scilly, a Freedom of Information request has now revealed that it has been this one person who has provided all the arguments for the response, who has dismissed the views of a Professor in Hydrogeology, who has sided with the incorrect views of Aggregate Industries’ consultants. When Prof Brassington says "the EA has not recognized that the hydrogeology and groundwater resources of this area are very sensitive and fragile", it is this one person at the Agency who is both judge and jury.

Concerned? We should be. What checks and balances are made on the views of this one person? Why is this one person so entrenched in their position? Why has this one person dismissed all of the ever-increasing catalogue of contradictory evidence put before them? Why, given all the higher water levels, does this one person not want Aggregate Industries to recalculate the MWWT, the base of any quarry, before determination? Why are a number of the Environment Agency’s views beginning to look perverse?

Is it because they rushed to make a decision on this proposal before fully thinking things through? Is it because they naively trusted everything delivered to them by Aggregate Industries and its consultants – wild fantasy stuff, some with errors the height of houses? Is it because they are inexperienced at dealing with this sort of proposal? Is it because changing direction now would be embarrassing? Is it because no ladder could ever be big enough to climb down?

Answers on a postcard.

“Real, measured improvements, not conjectural.” Really??

In September, we posted Climate emergency? Not at Aggregate Industries. CO2 emissions increase again. Over the last 20 years, Aggregate Industries' annual CO2 emissions have increased five-fold – from 228,267 tonnes in 1999, to nearly 1.3 million tonnes now. This from the company committed to tackling #climatechange.

We're committed to tackling #climatechange. Our climate targets reflect that commitment and we have set ourselves two distinct targets as a step towards our 2030 goals https://t.co/AMvvMcFBqM #GreenGB #CleanUK #mpacement @beisgovuk pic.twitter.com/srQrG2brKP

— Aggregate Industries (@AggregateUK) October 16, 2018

The Mineral Products Association – the trade body that represents Aggregate Industries and friends – has recently called for its industry’s contribution towards carbon efficiency and biodiversity to be recognised, claiming "our industry is as committed to the environment as anyone else."

MPA calls for industry's contribution to be recognized | IQ celebrates high-achieving students | Banks Plant Solutions service contract | Job opportunities with Aggregate Industries and R & B Rockdrillers; plus much more..... - https://t.co/K6XaRhU0NN pic.twitter.com/XIS9hF0R7G

— Agg-Net (@aggnetweb) November 7, 2019

At a recent address – transcribed in "Uniquely placed for Net Zero and Net Gain" – Nigel Jackson, the chief executive of the MPA, told attendees at another back-slapping minerals function that the industry is doing something about climate change, making "Real, measured improvements, not conjectural", being "practitioners not preachers".

Bravo – if that's the case at other companies, but at Aggregate Industries? Of course not. Emissions per tonne have been flatlining for years, indicating a company unresponsive to the climate crisis. 

Here are bits of Mr Jackson's speech, interspersed with the track record of one of its biggest members:

These are serious times for far too many species, habitats and our planet. I know that, MPA knows that, that is why we have not been wasting the last 30 years doing nothing. We have focused on delivering action rather than just adding to too much hot air.

Some say ‘industry is doing nothing about climate change’ or more accurately global warming, or biodiversity loss, our twin and linked challenges, Net Zero and Net Gain.

We are.

In 2007 we produced our first ‘carbon advice card’ setting out the measures members could take to reduce their carbon footprint...

Unlike many industries, we have reduced our production carbon emissions from cement by 51% since 1990, far better than the UK overall. Real, measured improvements, not conjectural.

If we can get to net zero before 2050, we will. But we will not join those who arbitrarily nominate unrealistic and opportunist target dates for short term PR gain. This is not a time for empty gestures and virtue signalling.

Quite right. This is not the time for empty gestures and virtue signalling. Virtue signalling?:

public, empty gestures intended to convey socially approved attitudes without any associated risk or sacrifice

Surely no member of the MPA would do such a thing, make themselves look virtuous on climate change when their record indicates inaction and apathy – would they?

We're determined to reduce our #emissions per tonne by improving the #energy efficiency of our production facilities. To view our 2020 #climate targets, head on over to our website 👉 https://t.co/zAqrcHgcwz pic.twitter.com/b0x0xTTmLO

— Aggregate Industries (@AggregateUK) January 11, 2019

#Sustainability is at the heart of everything we do 🙌 We’ve defined specific targets which are fundamental to achieving and maintaining sustainable climate goals. Download our report to discover our focus areas https://t.co/Eq5uZY3iXM pic.twitter.com/wkKoGo8Rcu

— Aggregate Industries (@AggregateUK) February 20, 2018

Reduce emissions! We developed our transport plan to manage the #environmental impact of our transportation activity https://t.co/nRspVr3eTm pic.twitter.com/O5toKlbKTx

— Aggregate Industries (@AggregateUK) May 4, 2017

But yes. The boss of the MPA is correct. This is not the time for empty gestures. This is not the time for flatlining emissions per tonne. This is not the time to be plotting 2.5 million mile CO2 intensive climate-busting haulage schemes in Devon.

Hugo Swire is no longer MP for East Devon

Over the years, concerned constituents have made various representations to Hugo Swire on the subject of Aggregate Industries' proposal to quarry Straitgate Farm.

The latest representation was in late summer of 2018, on the subject of hydrogeology, and highways and site access concerns. The MP subsequently met with a representative from Aggregate Industries and Horizon, the company's traffic consultant. It was apparently a "good meeting":

Good meeting with Aggregate Industries regarding their planning application and proposals for the access road to Straitgate. pic.twitter.com/eyEP2mo5fq

— Hugo Swire (@HugoSwire) October 24, 2018

Read into that what you will. Others also wanted to know what he meant:

Are you able to provide any details of what discussed that made it a 'good' meeting. I'm sure residents of Ottery very interested to hear any potential impact on road infrastructure and road safety.

— Jim Gregory (@JimGregoryUK) October 24, 2018

What was the outcome Hugo? It would be good to know as this whole process has been going on for years and years... and neighbours are understandably anxious - thanks @straitgateactgp

— Claire Wright (@ClaireWrightInd) October 24, 2018

We have written to Hugo Swire three times since that meeting, asking him to shed light on what was achieved. We've received no reply.

Having now had sight of the latest Transport Assessment, readers may not be surprised to learn that, if it was a "good meeting", it had no bearing on the site access or the concerns that were raised.

Transport Assessments & HGVs: How consultants create an alternative reality

We’ve previously posted about how parts of Aggregate Industries' application to quarry Straitgate Farm have been a catalogue of fiction. We said:

It all makes this multinational and its consultants look like a bunch of cowboys, willing to say whatever it takes. It begs another question: If AI can’t act honestly before winning any keys to dig, what hope would there be afterwards?

Amazingly, Aggregate Industries is on its third Transport Assessment to support this proposal – and its third set of traffic consultants. The first Transport Assessment was from SLR in 2015, when the plan was to haul material to Blackhill. The second was from David Mason Associates in 2016. The third – the current one – is by Horizon Consulting Engineers. This last one, written in 2018 and still being updated this year, is (at least with the copy we have) already at Revision E.

These documents are supposed to be "thorough assessments of the transport implications of development", and yet each one from Aggregate Industries has played with the truth – the latest being no exception.

SLR, with the first Transport Assessment, underplayed the number of HGV accidents on the B3180. They even covered up the fact that one of Aggregate Industries’ own HGVs had been involved in a collision with a coach.

David Mason, produced more fiction – and was later ditched by the company. His traffic numbers for the B3174 bore no relation to reality. Highways England counts two months earlier showed almost 60% more traffic – numbers subsequently borne out by Horizon.

You won’t find the third Transport Assessment on Devon County Council’s planning website. It has only been sent to us after we made a Freedom of Information request.

How much better will this one be? First indications don’t bode well. On the matter of highway safety, Horizon claims for the "three year period" until the end of 2016:

6.3.1 Three accidents have occurred within the study period of which only one occurred at the junction which is the subject of improvement works. None of the accidents involved an HGV…

It's not true. This accident happened on Monday 4 April 2016 – within a stone’s throw of Straitgate – on the relevant stretch of the B3174 Exeter Road that Aggregate Industries propose to use:

Fortunately no-one was injured, but police closed the road for the best part of a day.

If Horizon can overlook this sort of accident, what else can it overlook?

Perhaps, in an effort to be thorough, and given that this application will not now be determined before 2020, we should look at these accidents too – both involving an HGV, both in 2019, both involving police, and both a matter of yards from Straitgate Farm.

Yet another HGV crash on the B3174 Exeter Road

OtteryMatters

Another lorry in the ditch outside Straitgate

As these photos evidence, the B3174 Exeter Road is not as safe as Horizon makes out.

Devon County Council is aware of the accidents on this stretch. Earlier this year, in connection to the Straitgate proposal, the Council’s Neighbourhood Highways Officer advised of "HGVs going into unlined ditches" between Daisymount and Birdcage Lane.

And what – with plans to put another 200 HGV movements a day on this road – was the advice to the case officer responsible for the Straitgate application from the Council's highways planning department?

I really don’t know if this changes anything or not !

Why are so many trucks coming off this road? It's quite simple – but again it's not something that's been discussed in the Transport Assessment.

Consider that HGVs are 3.0m wide or more, including wing mirrors.

According to Horizon itself, the B3174 Exeter Road is as little as 5.3m wide. In other words, in places, the road is too narrow by as much as 70cm for two HGVs to pass each other with no room to spare. Consider also, with the speed limit of the B3174 Exeter Road at 60mph, how little margin for error there is, with vehicles approaching each other at speeds of up to 120mph.

You might have thought this would have rung warnings bells – given that the Straitgate proposal could generate in addition as many as "216 HGV trips per day" – but no. Firmly in alternative reality mode, Horizon says "the proposed development complies with policy M22: Transportation and Access of the Devon Minerals Plan 2011 - 2033", or in other words this the proposal "would not have a significant effect on: (a) road safety".

But Horizon’s grasp of M22 is tenuous, and not just on the safety front.

Because despite showing a map of the proposed haul route, Horizon fails to assess the distances involved. Horizon fails to say that each load would need to be transported 23 miles for processing. Horizon fails to say that there would be more than 105,000 such movements, and even more if, as Horizon says, we were "to account for the use of HGV’s with a lower load capacity". Horizon fails to say that this would amount to some 2.5 million miles, or perhaps even more with smaller loads.

Clearly, in trying to paint a rose-tinted vision of Aggregate Industries' HGVs criss-crossing Devon, Horizon does not provide "thorough assessments of the transport implications of development", and clearly the proposal does not comply with Minerals Plan policy M22, given that the same policy says:

mineral development should minimise the distance that minerals are transported