Friday, 29 January 2021

Why is LafargeHolcim a member of API – the Big Oil lobby group ‘obstructing urgent climate action’?

LafargeHolcim – a company dependant on fossil fuels, a company with monstrous CO2 emissions, a company parent to Aggregate Industries – says "it is more important now than ever to unite around climate action." The company recently celebrated the Paris Agreement:


So why is LafargeHolcim a member of the American Petroleum Institute – a powerful Washington lobby group accused of obstructing climate change initiatives, of supporting the reversing of US regulation on methane emissions, of opposing electric vehicle subsidies, of backing the Trump administration’s efforts to open up protected Alaskan wilderness to drillers, of endorsing political candidates who argued against US participation in the Paris climate agreement?

LafargeHolcim’s membership fees to the API will have helped to fund all of that.

Clearly, whilst publicly LafargeHolcim claims to celebrate the Paris climate agreement, behind the scenes it is supporting an organisation that has been lobbying against it. Hypocrisy? Duplicity? Take your pick. 

API funds a group called the American Council on Capital Formation, which, along with the Chamber of Commerce, funded the debunked study claiming that the Paris Agreement would cause massive job losses and huge costs. This debunked report was cited by President Trump as justification for withdrawing from the Paris accord. So API funded the report used as a basis for withdrawal—but wait. It gets better. The authors of this API-funded study are the same two characters API hired way back in 1997 and 1998 to write similar reports critical of the Kyoto Protocol. The Kyoto Protocol, of course, was violently opposed in the Senate by the fossil fuel industry and API.
So why is LafargeHolcim a member of this Big Oil lobby group – when this month even Total, the French oil and gas giant, withdrew "following a detailed analysis of the climate positions of the American Petroleum Institute"?


Jeanett Bergan, head of responsible investment for Norwegian pension fund KLP, was quoted in the FT:
There is simply no justification for any association with lobby groups who roll back emissions regulation and undermine urgent climate action.
So why is LafargeHolcim still a member of API? According to this article, "LafargeHolcim... did not respond to a request for comment." Of course it wouldn't. What could it say?

Wednesday, 27 January 2021

‘History made 🙌’

This week, Aggregate Industries claimed history has been made.

Aggregate Industries, however, was not referring to the news this week that the largest opinion poll of its kind, with a million people in 50 countries taking part, found almost two thirds of people now view climate change as a global emergency:
The highest proportions of people saying there is a climate emergency are in the UK and Italy, both at 81%.
Aggregate Industries was not referring to the report this week that global ice loss is accelerating at a record rate:

The melting of ice across the planet is accelerating at a record rate, with the melting of the Greenland and Antarctic ice sheets speeding up the fastest, research has found.
The rate of loss is now in line with the worst-case scenarios of the Intergovernmental Panel on Climate Change...
Aggregate Industries was not referring to that sort of history. This week, it was celebrating 🙌, looking for recognition for some 50,000 tonnes of asphalt:


The UK’s first carbon-neutral pavement scheme. That’s quite a claim. How did a scheme boasting "a 43% carbon reduction compared with conventional resurfacing methods" achieve carbon-neutrality?
In an industry first, through the company’s partnership with Circular Ecology (a non-profit organization), Aggregate Industries purchased a number of credits to offset the remaining carbon on the scheme.
It may be an asphalt industry first, but there’s been a huge rise in companies – particularly aviation – buying "carbon offsets" in an effort to balance their pollution, as the article Licence to pollute: the sham of carbon offsetting makes clear:
The reason that the aviation and other large polluting industries like offsets is that they let them appear to be addressing climate change while at the same time continuing to burn fossil fuels.
The one guaranteed thing that happens under carbon offsetting is that the carbon emissions still take place... meanwhile the offsetting may not succeed.
Lest we also forget, Aggregate Industries sells more than 5 million tonnes of asphalt each year. So one might wonder about carbon-neutrality for the other 99%.

And if Aggregate Industries has suddenly become so keen on carbon progress, what is it going to do about the 1.3 million tonnes or so of CO2 emissions that the company is responsible for each year; the CO2 that it is now so embarrassed about it has seemingly given up reporting?

Why are companies trying to wring so much green spin from so very little? This week saw another story:


BlackRock is the world’s largest asset manager. Larry Fink, BlackRock’s chief executive, said:
I believe that the pandemic has presented such an existential crisis – such a stark reminder of our fragility – that it has driven us to confront the global threat of climate change more forcefully and to consider how, like the pandemic, it will alter our lives.
No issue ranks higher than climate change on our clients’ lists of priorities.
The parent company of Aggregate Industries is LafargeHolcim – the world’s largest cement producer with annual CO2 emissions more than many countries.

At the time of writing, BlackRock owns 29,921,681 shares in LafargeHolcim, 4.86% of the company.

Despite LafargeHolcim's assurances over the years that it is taking climate change seriously, the company emitted 148 million tonnes of CO2 in 2019, still 2% up on 2017.

Friday, 22 January 2021

Kerry warns ‘world is way off pace to avert catastrophic climate impacts’

As the UK suffers flooding again, and a new study suggests flooding across the country could increase by 15-35% by 2080, John Kerry, the US’s new climate envoy, has warned that the world is lagging behind the required pace of change needed to avert catastrophic impacts from the climate crisis:
We need to all move together, because today very few are on a trajectory of the steep reductions needed to meet even current goals, let alone the targets we need to avert catastrophic damage.

UK construction faces Brexit brain drain amid exodus of skilled EU workers

Another industry discovers the benefits of Brexit.


According to new research released by the Migration Observatory at the University of Oxford:
Numbers of European Union-born professionals working in the UK’s skilled construction and building trade dropped off by 46% in 2019.
Additional research released by the ONS this month found that the non-British resident population declined in the year through June 2020, with the biggest decrease among citizens of EU countries at -135,000.
These include migrants from Poland, Estonia and Slovenia, which make up 26% of the UK’s construction sector.

Natural England ‘cut to the bone’ and unable to protect wildlife – say staff

Everyone knows we can’t do basic statutory stuff, let alone the bigger, exciting projects we want to do.
The government’s conservation watchdog has been “cut to the bone”, with staff underpaid, undervalued and overworked and feeling unable to protect England’s most valuable wildlife sites, according to a new report and testimony from workers.
Mike Clancy, Prospect union general secretary, said there was a “yawning gap” between the government’s rhetoric on climate change and biodiversity, and the reality of years of underfunding environmental agencies.
“Protecting nature means investing in the people who do that work,” he said. “Natural England is at the heart of this agenda but it can only be effective if it is properly funded and the importance of its staff properly recognised.”

Monday, 18 January 2021

AI’s planning application for cattle crossing – consultation period extended

Last month, as we posted, Aggregate Industries submitted planning application 20/2542/FUL to East Devon District Council "to facilitate an efficient crossing point for the current dairy herd at Straitgate Farm" across the B3174 Exeter Road, Ottery’s busiest road. It was another twist in the company’s bungling and interminable struggle to win permission to quarry almost 90% of the farm’s acreage.

The application was submitted in an effort to assuage concerns raised by Devon County Council – concerns revealed by this FOI request. The Council had made it clear to Aggregate Industries that the issues of cows and their impact on road safety had to be dealt with before the company’s application to quarry Straitgate Farm could proceed any further; the cows being the 150 or so in number that currently graze the site, that would require to cross the road 4x daily to alternative pasture if quarrying proceeded. 

For anyone not lucky enough to watch cows crossing a road, here’s a video taken elsewhere in Devon.


East Devon District Council received almost 50 objections to Aggregate Industries’ cattle crossing proposal, including from West Hill Parish Council and Ottery Town Council. No response has yet been received from Devon County Highway Authority, but Highways England warned
Should any increase in the frequency and/or duration of closures of the B3174 be proposed in future (to facilitate the crossing of livestock), an assessment of the impact of this on the safe operation of the A30 trunk road must be undertaken.
Currently, livestock cross the B3174 Exeter Road infrequently, at quiet times, and in low numbers.

The application closed for comments on 12 January. Days later, however, the consultation was re-opened. Three further parties were added to the consultee list: Exeter Airport, Devon County Council Minerals Planning Authority and Devon Stone Federation.

Quite why these parties have only now been consulted is unclear. Straitgate Farm is in a Mineral Consultation Area. Although, the latter two bodies should be consulted on planning applications within those Consultation Areas, "the construction or alteration of an access or a fence or other boundary.." is exempt from the need for consultation, according to Appendix B of the Minerals Plan. What these parties can add to the debate over a proposal for "a new field gate" remains to be seen. 

For anyone still wanting to respond to this madcap proposal, the consultation period has now been extended to 7 February.

Importance of hedgerows


So why are we still ripping out these precious and often ancient wildlife corridors?
The last hedgerow survey, in 2007, recorded 500,000km of hedgerow in the UK. Extending this by 40% would require the creation of 200,000km of new hedges across rural and urban landscapes – which equates to about half the length of Britain’s road network.
Why is this needed? 
Hedges sequester carbon both in woody growth above ground and in roots, leaf litter and other soil organic matter at and below ground level. In addition, hedges across slopes capture eroding soil and can increase soil organic carbon for up to 60m uphill. In contrast to some of the other forms of carbon capture proposed in the report, hedges are a low-risk way of capturing carbon and provide multiple benefits.
The CCC report also explains that an increase in hedges “results in benefits to biodiversity through habitat creation […]and can help towards flood alleviation”. Hedges regulate air and water quality through intercepting pollutants, maintain essential diversity, and are already an important cultural landscape feature.
This video also reminds us of the benefits that hedgerows bring:


And yet, we continue to lose hedgerow at an alarming rate. 

Aggregate Industries' plans to quarry Straitgate Farm propose to grub up nearly 1500m of 'important' hedgerow – hedgerows up to 4m wide – hedgerows dating back hundreds of years – hedgerows that provide up to 6000m2 of habitat for protected bats and dormice.

As if Covid-19 wasn’t bad enough...

The world is failing to grasp the extent of threats posed by biodiversity loss and the climate crisis, according to an international group of scientists:
The scale of the threats to the biosphere and all its lifeforms – including humanity – is in fact so great that it is difficult to grasp for even well-informed experts.
Professor Paul Ehrlich from Stanford University warns:
Environmental deterioration is infinitely more threatening to civilisation than Trumpism or Covid-19.
Growthmania is the fatal disease of civilisation - it must be replaced by campaigns that make equity and well-being society’s goals - not consuming more junk.

Cllr John Hart: ‘Devon County Council is taking the lead on climate change’

Let’s hope so.


Professor Richard Betts MBE, who leads the production of the Met Office’s annual CO2 forecast, said: 
Since CO2 stays in the atmosphere for a very long time, each year’s emissions add to those from previous years and cause the amount of CO2 in the atmosphere to keep increasing. Although the Covid-19 pandemic meant that 7% less CO2 was emitted worldwide in 2020 than in previous years, that still added to the ongoing build-up in the atmosphere. Emissions have now returned almost to pre-pandemic levels, but their effect this year will be partly dampened for a while by the stronger natural sinks due to the La Niña.
The human-caused build-up of CO2 in the atmosphere is accelerating. It took over 200 years for levels to increase by 25%, but now just over 30 years later we are approaching a 50% increase. Reversing this trend and slowing the atmospheric CO2 rise will need global emissions to reduce, and bringing them to a halt will need global emissions to be brought down to net zero. This needs to happen within about the next 30 years if global warming is to be limited to 1.5°C.

Devon has a plan. A roadmap for how Devon can achieve net-zero emissions is open for consultation until 15 February. Cllr John Hart, leader of Devon County Council, writes:
I am very proud that Devon County Council has been taking a lead on the issue...
Now in case you are thinking this is just another talking shop, I can assure you it isn’t. 
If we are to tackle global warming then all of us need to change our behaviour – personally, in our communities and in the organisations and companies of which we are a part. 
And if people are going to change then they need to feel part of the process. So a major consultation’s been launched this month to enable everyone in Devon to have their say on what needs to be done.  

EA admits: ‘We don’t have the money to beat polluters’

The Environment Agency is tasked with looking after our groundwater – specifically "the prevention of pollution of groundwater and protection of it as a resource... to protect and enhance this valuable resource for future generations".


How ‘well’ do you understand groundwater? It’s a good question, and one – given the responses by Professor Brassington – that might be put back to the Environment Agency. The EA are only human and make mistakes too, as we have previously posted: EA admits it may have made Dawlish sea defences worse, Does the state of our rivers mirror the competency of the EA? EA’s model of Otter Valley groundwater levels “as much as 15m adrift”.

But it's not just that. Plainly the EA isn't properly funded anymore either.
 

Ms Boyd is quoted as saying: 
All this is allowing more people and businesses to break the environmental rules
That admission will obviously worry private water users surrounding Straitgate Farm, concerned their water supplies would be – as Professor Brassington warns – 'irreversibly damaged' by Aggregate Industries' quarry proposal.

Locals will be looking for more reassurance than the EA putting out a few tweets.
 

Nevertheless, the EA is right. Groundwater should never be far from our minds, particularly when a sand and gravel quarry is proposed in an area where springs supply drinking water to more than 100 people, an area upstream of precious historical assets like this:
 

AI releases 2019 accounts

Aggregate Industries has released its "Annual Report and Financial Statements for the year ended 31 December 2019"; i.e. for the period before Covid.

The company reported sales of £1330m (£1297m) and pre-tax profits of £87.5m (£68.5m). Profits are still short of the £105m reported for 2016. A pre-tax margin of 6.6% compares unfavourably with the 10.2% recorded by competitor Breedon for the same calendar year. Clearly, Aggregate Industries is still not firing on all cylinders  despite staff numbers falling again.

Unsurprisingly, the Annual Report paints a subdued outlook:
It is anticipated that the UK Construction Output will reduce in 2020 as a result of the global COVID-19 pandemic. As a result, it is envisaged that demand levels for our products and services will be lower than 2019. 
The company "implemented a number of cost reduction initiatives" in 2020:
The initiatives are aimed at reducing the input costs of the business in line with reduced activity to remain profitable.
On "Environment and Sustainability", Aggregate Industries says:
The Directors regularly discuss the Company’s impact on the environment and the sustainability of the Company’s operations.
Really? Given the company’s plans for Straitgate Farm – with its 2.5 million mile HGV extravaganza – it clearly hasn’t made any difference.

On "Purpose and Leadership", Aggregate Industries claims it’s "reinventing how the world builds". Crikey. Who makes this stuff up?
Central to our strategy is the idea that the construction sector plays an important role in building a more sustainable future. We believe in building a world that works for people and the planet. A world that keeps people safe, connected and thriving. With our customers and partners we are advancing society and uplifting communities. But today we want to play an even bigger role. That’s why we are reinventing how the world builds on our way to becoming a net zero company.
Again, from the perspective of the company’s unsustainable plans for Straitgate, that also looks unlikely.

Friday, 15 January 2021

AI’s proposal to rewrite S106 agreement suffers 7-0 defeat in Somerset

Two applications from Aggregate Industries SCC/3742/2020 and SCC/3748/2020 to re-open a limestone quarry in the Mendips came before Somerset County Council Regulation Committee yesterday.
The two applications seek the same outcome in enabling recommencement of extraction within Bartlett’s Quarry in parallel with, rather than upon completion of, extraction at Torr Works. Application SCC/3742/2020 proposes the removal of Condition 2 of permission 2016/0025/CNT that was imposed in February 2020, while application SCC/3748/2020 proposes the following changes to the existing S106 Agreement for Torr Works…
Officers recommended permission be granted. Let’s say that again. Planning officers – including the one who championed Straitgate Farm's inclusion in the Devon Minerals Plan – recommended that previously agreed planning conditions and S106 agreements, intended to protect local communities, be cast aside for the benefit of Aggregate Industries.

The justification put forward for recommencing limestone extraction at Bartlett’s Quarry, before extraction is finished at nearby Torr Works, another of Aggregate Industries' limestone quarries, was based on the company securing a new contract "along with its partner PORR, to construct concrete beds for the HS2 project, the material for which shall be supplied from Torr Quarry":
As one of two Somerset rail-linked quarries (the other being Whatley), Torr Quarry supplied 3.65 million tonnes of crushed rock by rail in 2018, predominantly to London and the South East, with a further 1.85 million tonnes transported by road to more local markets. To meet anticipated increased demand arising from infrastructure development in these other regions, notably from HS2, the applicant proposes to increase the volume of crushed rock transported from Torr Quarry by rail to 4.6 million tonnes, with road-based output to reduce to 0.9 million tonnes, and to recommence extraction at Bartlett’s Quarry to provide an additional 0.9 million tonnes to deliver the balance of the local need.
The Section 106 agreement was in place to prevent resumption of extraction at Bartlett’s Quarry until working at Torr Works ceased in an effort to limit the cumulative impact on surrounding villages and on groundwater. In fact, permission had only just been granted for one of these applications that Aggregate Industries now wanted to change. The Officers’ Report gives more detail: 
3.3 In February 2020, permission was granted (2016/0025/CNT) for the variation of Condition 1 of Schedule B of the ROMP conditions (077905/015) to alter the expiry date for Bartlett’s Quarry to 21 February 2042. However, a new condition (numbered 2) was imposed to reflect the Torr Works S106 Agreement (see 3.6 below) requiring that: “No further extraction of Carboniferous limestone or dewatering shall be undertaken within Bartlett’s Quarry prior to the permanent cessation of commercial extraction of Carboniferous limestone and associated dewatering at Torr Works Quarry.
3.6 When the separate Torr Works complex received planning permission (2010/0984) for deepening and a time extension to 2040 in July 2012, the accompanying Section 106 Agreement included the following covenant on the mineral operator: 11.1 not to resume extraction of carboniferous limestone or dewatering within Coleman’s Quarry until such time as the commercial extraction of carboniferous limestone from the Operative Torr Land and associated dewatering as authorised by any subsisting and current planning permission shall have ceased.
3.7 As extraction at Torr Works is expected to continue until around 2040, the effect of this covenant is to prevent any further extraction within Bartlett’s Quarry (which contains the major part of the remaining reserves) or other part of the Coleman’s Quarry complex before a short period prior to their expiry date in 2042.
Section 106 agreements are legal agreements between local authorities and developers "to make acceptable development which would otherwise be unacceptable in planning terms."

Local residents submitted some 93 objections. Two of the main issues raised in these objections, according to the Officers’ Report, were:
the S106 Agreement was entered into by Aggregate Industries in good faith, and its amendment removes any trust in them; 
Condition 2 was only imposed in February 2020 following objections to a previous application, with no change of planning policy or other circumstances since then, and the proposal does not meet current policy;
The applications came before committee yesterday. This Twitter thread helpfully tells the story. Chair Cllr John Parham said:
The case that Aggregate Industries has made about the justification for running both quarries in tandem is weak. The capacity of Torr is a business issue for them, not a planning issue for us.
He proposed the application be rejected on the grounds that the company had "not provided sufficient justification for running both of these quarries in tandem". Fortunately, the committee voted to refuse the application by 7 votes to 0.

Wednesday, 13 January 2021

Glendinning’s proposal to extend Linhay Hill Quarry to finally be determined

A planning application for a major quarry extension will be determined this week by the Dartmoor National Park Authority. The DNPA’s Development Management Committee will meet on 15 January 2021 to determine Glendinning’s planning application 0322/16 to extend Linhay Hill Quarry, a limestone quarry near Ashburton adjacent to the A38 in the Dartmoor National Park in Devon.

But has a conflict of interest arisen by the DNPA’s engagement of consultants Wood – a company which works closely with Aggregate Industries, owner of the other three limestone quarries in Devon?


The application for Linhay Hill has taken several years to arrive at committee, after a tortuous journey. The DNPA’s website currently shows some 763 documents. The South West Business Council, which produced "a report into impacts on the Devon economy following delays securing planning permission", points out Glendinning has taken "6 years of effort and nearly £2 million of expenditure" to get this far.

The Officers' Report, found here, here and here, recommends:
 i) that the proposed scheme constitutes Major Development; (ii) that there are exceptional circumstances and the development would be in the public interest; (iii) that permission be GRANTED subject to conditions and the completion of a s.106 Planning Obligation Agreement.
whilst recognising:
Officers consider that the proposed development would lead to significant environmental effects on landscape and visual impacts which cannot be fully mitigated. These effects are localised and mitigation has been proposed to reduce the level of effect which would result. Officers are of the opinion that there are exceptional circumstances for the proposed development and that it would be in the public interest. There is considered to be a need for the development, that it will contribute to the national need for minerals and that there are no feasible means of meeting the need in another way. 
According to the Report, public representations amount to "22 letters of objection; 214 letters of support; 10 ‘other’ letters; 1 petition objecting with 24 signatories."

It may surprise some to know that this 'delayed' application has still taken less time to arrive at committee than Aggregate Industries’ application to quarry Straitgate Farm – despite the difference in scale.

Aggregate Industries’ application for Straitgate, which has dragged on since its first application was validated in June 2015, is to extract barely a million tonnes of saleable sand and gravel.

Glendinning’s application for Linhay Hill Quarry, which was validated by the DNPA in June 2016, is for more than 30 times that amount.

Glendinning is seeking to deepen its existing quarry, established in 1958, and extend into 32 hectares of adjacent land. The company’s Environmental Statement says this “will yield sufficient material for a further 60 years at the quarry’s current rate of extraction”. Given that Linhay Hill Quarry "produces over 500,000 tonnes of this limestone annually", the proposal would be for 30 million tonnes or more.
 
This extension is not about increasing productivity or profit for Glendinning. It is about maintaining our current business activity which employs 240 people directly, sustains an estimated 180 further jobs in the wider economy and contributes £6 million a year to the Devon and Dartmoor local economy from the procurement of goods and services.
Glendinning’s quarry and proposed extension are in the Dartmoor National Park. According to the NPPF:
Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks… The scale and extent of development within these designated areas should be limited. Planning permission should be refused for major development other than in exceptional circumstances, and where it can be demonstrated that the development is in the public interest… etc.
The company’s Environmental Statement, however, argues:
There are only three other major quarries in Devon producing limestone (which are all operated by the same international company). As such, the quarry is an important strategic asset for the South West, both for supply of limestone and for providing competition in the market.
Around 2 million tonnes of limestone are sold in Devon each year. According to Devon County Council's latest, but now out of date, Local Aggregates Assessment, 2018 saw crushed rock sales of 2.45 million tonnes, of which limestone made up 84%. The LAA says:
If the life of Linhay Hill Quarry were not to be extended through the application referred to..., then Devon would face a position whereby the remaining limestone supply from within Devon would be controlled by one company with no effective competition other than through importation of limestone from outside the county.
The one company referred to is Aggregate Industries – subsidiary of cement giant LafargeHolcim, which would surely welcome the closing of Linhay Hill Quarry: less competition, higher prices, higher profits.
The delays in securing permission for the Linhay Hill extension have been caused by a range of problems. In particular, concerns have been raised about the groundwater implications of deepening the quarry and the effects of dewatering, particularly on land stability and sinkholes, including under Ashburton and the A38 Devon Expressway. Professor PL Smart warned "there is a significant risk that dewatering may extend under Ashburton":
I do not know of any other quarry site in the UK where planned abstraction may lead to the dewatering of mature buried karst underlying a large urban area (Ashburton). I do not believe that there has been adequate consideration of these issues in relation to the area of the CBLF which underlies Ashburton, and has most probably already, and certainly will be impacted by the proposed Quarry development.
It has been argued that existing sinkholes around the area have been caused by the Linhay Hill Quarry, and that the deepening and extension will only make matters worse. The Officers' Report says:
The limestone geology (the Chercombe Bridge Limestone Formation) on which Linhay Hill Quarry is located is a karst formation. Karst formations are where parts of the rock formation have been dissolved by acidic waters, forming systems of cracks, caves and channels through which water can flow. As water flow changes through the karst system, such as from seasonal changes to rainfall, the different areas of the limestone can either open up to create new routes through which water can flow (from dissolution or erosion) or the closure of existing routes through the deposition of sediments carried by the water. Changes to the water flows and the subsequent geological changes that can occur can create changes to both ground and surface water flows, and potentially issues like flooding and also can create land stability issues through the creation of sinkholes.
...our Society is not convinced that E. & J.W. Glendinning is a sufficiently responsible, reliable or suitably informed outfit to be allowed to remove a large mass of Devon’s mature karst. The insufficiently researched environmental consequences are not worth thinking about. When the karst has gone, it will be too late to meliorate the inevitable environmental damage.
Glendinning instructed consultants Atkins to fight its corner. The DNPA engaged consultants Wood:
Wood (Wood Environment & Infrastructure Solutions UK Ltd), then known as Amec Foster Wheeler, was appointed by the DNPA to review the planning application and ES. Two requests have been made by Wood since June 2016 for further information to ensure that the ES meets the requirements of the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (the EIA Regulations). These requests were made in December 2016 and September 2018 under Regulation 22 of the EIA Regulations...
What did Wood have to say? Quite a lot, but here’s a taster:
…as the quarry deepens and extends shallow groundwater conditions in an area around the quarry and extension could be affected, with potential consequences for groundwater-dependent surface water features and the possibility of further sinkhole development.
Wood considers that there is benefit in further investigation, in that it would allow more informed decisions to be made regarding the impacts that the proposed quarry extension could have on the water environment and also in terms of land stability.
Wood considers that the applicant’s proposals with regard to mitigation are not yet adequate, particularly given the current limited understanding of the hydrogeological regime and the potential impacts of the quarrying proposals.
...a number of concerns have been expressed regarding the adequacy of the EIA. Wood considers that the importance criteria are not sufficiently rigorous in a number of respects...
Wood considers that the current consideration of mitigation in the HIA and ES is limited, particularly given the current level of hydrogeological conceptualisation.
It was an interesting choice of consultants for the DNPA to make. Wood, previously Amec Foster Wheeler, is responsible for groundwater monitoring and associated annual reports for the three limestone quarries owned by Aggregate Industries listed above. Did the DNPA ask Wood if it had any ongoing relationship with Aggregate Industries, the party who would stand to gain most from Linhay Hill’s demise? Did the DNPA not wonder whether engaging Wood might appear to be a conflict of interest?

Has the use of Wood affected the application in any way? It would certainly seem so. In July 2020, Atkins provided "a comparative overview of the information submitted in support of planning applications for three different limestone quarries in Devon, namely Stoneycombe Quarry, Moorcroft Quarry and Linhay Hill Quarry", making the case:
...the comparison is considered useful because the Water Environment Impact Assessments prepared for Moorcroft and Stoneycombe Quarries were undertaken by Amec Foster Wheeler Environment & Infrastructure UK Limited, now called Wood Environment & Infrastructure Solutions UK Limited. Wood is acting as consultants to the Dartmoor National Park Authority in the consideration of the planning application for the extension of Linhay Hill Quarry, and therefore the documents submitted in respect of these other quarries can be considered as a useful guide to the level of detail considered sufficient and appropriate as supporting information in each case.
All three quarries operate in karstic limestone with instances of sinkholes / stream sinks in the surrounding water environment. In all cases the limestone deposit extends beyond the immediate environs of the quarry, and underlies built up areas and strategic transport infrastructure nearby
Furthermore, Wood seems to have influenced the Environment Agency's position:
We understand that Wood (as DNPA’s consultant) have recommended staged monitoring and mitigation conditions. We are inclined to support such an approach.
The Officers' Report recommends "given the uncertainty…. a further 3 years of hydrological monitoring works prior to any extraction", and concludes:
The proposed development will lead to changes in the groundwater regime in the vicinity of the application site through the process of drawdown. These changes are also likely to lead to some effects on surface waters and possibly land stability in this area. However, the type of effects that are likely to result are considered able to [be] appropriately managed by the monitoring and mitigation schemes: which can be managed by the proposed conditions. This approach is considered to be in accordance with Environment Agency guidance on hydrological assessments within karst formations.
This month, correspondence from Atkins points to Glendinning agreeing to additional monitoring,
in order to provide a further level of comfort reassurance to the DNPA, the EA, and hopefully to members of the Caton Group as well as the wider public, which is consistent with Glendinning’s responsible approach to the environmental context of the quarry and the proposed extension.
Be that as it may, and any conflicts of interest aside, it’s not surprising that many see extending a major hard rock quarry in a National Park, with unknown impacts on land stability and groundwater, as misguided – however much monitoring is in place. 

EDIT 29.1.21 
RESOLVED: That, permission be GRANTED subject to the amended conditions as detailed below and the completion of a s.106 Planning Obligation Agreement.

Friday, 8 January 2021

Planning application for school and 150 homes in Ottery refused

A planning application by Devon County Council 20/1504/MOUT for a new school and 150 homes to pay for it at Thorne Farm, Ottery St Mary, was refused this week by East Devon District Council.

The site was outside the Built-Up Area Boundary and not allocated for housing in either the East Devon Local Plan or the Ottery Neighbourhood Plan. Councillors rejected the planning officer's recommendation to approve, accepting that whilst it might have been the right location for a school it certainly wasn’t the right location for 150 new homes.

There was a minerals angle to this application given the site's proximity to sand and gravel deposits – although these deposits would in all likelihood never be workable. 

If HGVs working minerals at the Thorne Farm site "is unlikely to be appropriate" for the B3174, how on earth can up to 200 HGVs a day from a quarry at Straitgate – just 1000m to the west of the proposed new school – be appropriate for the same stretch of road, particularly given the level of accidents on this stretch – some documented here – and when the impact of 150 cows crossing 4 times daily has still not been assessed?
The Officer's report from EDDC said:
The proximity to mineral extraction has been questioned. Whilst there is the potential for future extraction within 200 metres of the site boundary, the degree of separation between quarrying and sensitive properties is likely to be adequate to prevent future mineral extraction within the area having adverse impacts through noise and dust on future residents and school users, assuming that standard environmental control measures are included in any future mineral planning permission.
The above statement was based on responses from DCC’s Planning Development Manager and Devon Stone Federation. The former was rather late to the table, only responding some months after the application was validated in July. He was plainly annoyed that he had been left out of the loop – despite the applicant being the County Council itself:
I refer to your consultation of 1st October 2020 concerning the above application, which was sent some time after validation of the application. My understanding is that the consultation was prompted by an enquiry by the applicant, and I wish to underline the importance of your Council meeting its statutory obligation to consult with the County Council in its role as mineral planning authority for applications falling within a Mineral Consultation Area.
He didn't agree with the Mineral Resource Assessment that had been prepared for the Council:
The application is accompanied by a 'Preliminary Mineral Resource Assessment', which concludes that "the proposed development will not sterilise important mineral resources" and that "the mineral resource at the site is not of strategic importance". However, it is considered that this Assessment is flawed…
But he was nevertheless able to arrive at the conclusion:
Based on the discussion above, it is concluded that the proposed residential and school development would not sterilise or constrain sand and gravel resources within the nearby Mineral Safeguarding Areas and that the proposal accords with Policy M2 of the Devon Minerals Plan. Devon County Council therefore has no objection in its role of mineral planning authority.
Devon Stone Federation replied shortly after, and again disagreed with the MRA:
Details of this application have been passed to the Devon Stone Federation (DSF) by... the Devon Minerals Officer... The application is accompanied by a Mineral Resource Assessment, but the DSF does not support the conclusions that as there are no aggregate resources within the site itself, the development does not have potential to sterilise the nearby mineral resources… 
Nevertheless, DSF was also still able to arrive at the same view as DCC:
the DSF does not consider that these uses are sufficiently sensitive to potential future extraction of the sand and gravel in the deposit to the north west to justify grounds for objection in principle to the proposals in this outline application.

Which was all jolly convenient given the applicant was DCC.

In the end none of it mattered. Councillors voted against the proposal by 11 votes to 2, with 2 abstentions.

EDIT 15.7.2021 Devon County Council has decided not to appeal the decision.

LafargeHolcim in $3.4 billion deal to buy Firestone Building Products

Being seen to be green is rapidly moving up the business agenda.

Sustainability is becoming an important consideration in the investment world. There has been a boom in funds focusing on companies with high ESG ratings. ESG? Environmental, social, governance.

If you are the world’s largest cement producer – a massive CO2 polluter and long-time contributor to our climate crisis – that might be seen as a problem. There’s surely a limit to the amount of greenwash that can be sprayed around, so, with the obvious FOMO, what is LafargeHolcim – parent company of Aggregate Industries – to do?

This acquisition announced yesterday gives a clue.

LafargeHolcim... announced a $3.4 billion deal to buy Firestone Building Products from Japan’s Bridgestone Corporation in its biggest acquisition in more than a decade.
It will help LafargeHolcim tap increasing demand for roofs that generate solar energy and cool buildings, with cities such as San Francisco requiring solar panels on new buildings.
LafargeHolcim's CEO Jan Jenisch has dreams "to become the market leader in flat roofing systems":
Jenisch said his company’s focus was now on growth, with plans to roll out Firestone Building Products beyond the United States where it currently generates nearly 90% of its $1.8 billion in annual sales.
With headquarters in Nashville, Tennessee, Firestone Building Products, claims "our environmental mission is simple": 
to help ensure a healthy environment for current and future generations. We are constantly striving to develop eco-friendly products and processes that pave the way for a brighter tomorrow. 
But this repositioning towards a brighter tomorrow came "at a high price". Firestone Building Products had been expected to fetch around $2.5 billion. According to Bloomberg Intelligence:   
The high price being paid and the ambition to achieve $110 million in synergies a year, over two years, is questionable when the company has so much to invest in the decarbonization of its core business.
Reuters calculated: 
Adding $55 million of expected cost savings and taxing the total at Bridgestone’s 27% rate means the deal would add $232 million to LafargeHolcim’s bottom line – implying a 7% return on investment versus Morningstar’s estimated 9% cost of capital for the company. 
The deal had been rumoured for some days. Morgan Stanley thought the purchase offers "very little overlap" with LafargeHolcim’s main cement and aggregates focus. Citigroup however recognised that:
A potential acquisition in this space should also boost the ESG credentials of the company as a supplier of energy saving products in the building and construction sector.
As we know, cement is responsible for about 8% of global CO2 emissions. LafargeHolcim – a company that in 2019 added nearly 150 million tonnes of CO2 to our atmosphere – is now shamelessly keen to profit from the climate crisis it helped to create. In the FT, Mr Jenisch claimed "the future of the roof is flat, green and insulated": 
Climate change is unfortunately an amazing new business for us and I think we have a solid market ahead. 
And isn't that great? That climate change has presented a new way for this CO2 polluter to make money.

Monday, 4 January 2021

Highways England says risk to A30 must be assessed if livestock movements across B3174 were to increase

Highways England has responded to Aggregate Industries’ planning application 20/2542/FUL, the one wishing "to facilitate an efficient crossing point for the current dairy herd at Straitgate Farm."

Highways England reminds us that "development that results in an unacceptable impact on highway safety can be refused on highways grounds in line with paragraph 109 of the NPPF", and warns:
Whilst the B3174 forms part of the local highway network and therefore falls within the responsibility of Devon County Council, given the proximity of the crossing point to the A30 westbound offslip, any increase in the frequency of livestock crossing movements and therefore the period of time the B3174 will be closed may result in queuing vehicles extending further back towards the A30, and potentially onto the A30 mainline.
The closure of the B3174 during the network peak periods when traffic is at its heaviest may result in queues extending back to the A30 and should more frequent crossings be proposed than set out above (i.e. no longer by exception only), the impact of this on the daily operation of the A30 would need to be assessed to ensure an unacceptable safety impact would not occur.
Highways England offers no objection to Aggregate Industries’ application, providing "the frequency of livestock crossing movements does not increase... subject to the following advice":
Should any increase in the frequency and/or duration of closures of the B3174 be proposed in future (to facilitate the crossing of livestock), an assessment of the impact of this on the safe operation of the A30 trunk road must be undertaken.
Currently, livestock cross the B3174 Exeter Road infrequently, at quiet times, and in low numbers.
 
What assurances has Highways England sought from Aggregate Industries to arrive at this recommendation? Highways England says:
The applicant’s agent, Clive Tompkins of Aggregate Industries UK Limited, has confirmed to Highways England that no increase in the frequency of livestock crossings/B3174 road closures is proposed by the application.
And that's right. The application does not propose an increase. The application is for a gate.

In fact, Aggregate Industries expressly fails to mention the frequency of crossings to alternative pasture on the south side of the B3174, save to say that moving the herd may be required in "certain circumstances". As we posted:
What "certain circumstances" means for this efficient crossing point for the current dairy herd we are not told. Four times a day? For ever more? Who knows?
However, Aggregate Industries’ planning application to quarry Straitgate is another matter entirely. That application would obviously necessitate an increase in crossings. How could it not, if almost 90% of the available pasture is swallowed for mineral extraction? In which case, according to Highways England, "an assessment of the impact of this on the safe operation of the A30 trunk road must be undertaken."

To date, Aggregate Industries has not wanted to assess such an impact. One can only guess why not.

FOI request from DCC reveals more on murky cattle crossing issue

Last month, Aggregate Industries submitted a planning application for a cattle crossing. Application 20/2542/FUL is open for comments until 12 January. The company’s Supporting Statement reads:
AIUK is seeking permission for a new agricultural access onto the B3174 Exeter Road to facilitate an efficient crossing point for the current dairy herd at Straitgate Farm. 6.2
Straitgate Farm is let under an Agricultural Holdings Act Tenancy and supports a dairy business comprising a herd of some 150 cows. In certain circumstances it may become necessary for the farm tenant to move the dairy herd over to the south of the B3174 to access other grazing land owned by the tenant’s family. 6.1
What "certain circumstances" means for this efficient crossing point for the current dairy herd we are not told. Four times a day? For ever more? Who knows? Aggregate Industries does not even try to quantify the increase of livestock movements over the established "baseline". But more on that later, together with another phrase bandied around, "worst case scenario".

Aggregate Industries didn’t submit this application as some charitable gesture for the tenant farmer. The application is critical if the company is ever to quarry Straitgate Farm. Devon County Council has made it clear that it needs to see how the issues of cows and their impact on road safety can be dealt with before proceeding further.

This is an issue that has been kicking around since 2017. Documents released after an FOI request last year give an indication of what’s been going on behind the scenes.

In a letter to Aggregate Industries in November 2017, DCC admits "the proposed location would present safety concerns":
...having discussed this with highway colleagues on the basis of the information submitted with the Regulation 22 responses, initial indications are that the proposed location would present safety concerns. This needs to be clearly addressed if the need for the cattle crossing situation is arising as a consequence of your proposed development.
...any impact on road safety is likely to be a material consideration. Therefore, in order to assess the potential highway safety impacts the MPA needs to have reliable information on existing and potential agricultural crossings of the Exeter Road and, in particular how this would be controlled in the future in the interests of highway safety.
But safety concerns were not addressed, clearly or otherwise. Reliable information was not forthcoming. Quite the reverse. By 2018, things were still no clearer. In internal correspondence within DCC:
We don’t know quite where the crossing point is, or how many cows they have. We have the transport guy saying 15-30 cows and I have also seen 80 and 100 quoted. We also have the time of milking. The transport consultant suggests, to avoid peak traffic, that they could be milked at 10.00-11.00 in the morning – with no indication of what time of night they would need to be milked or if the farmer would agree to that. In fact it is not even clear if the transport consultant realises cows are milked twice a day!
In another internal DCC email, the Council was wanting Aggregate Industries to demonstrate that any quarry "wouldn’t increase the danger to highway users by increasing crossing movements":
I don’t think what we asked for was unreasonable – which was the baseline to be adjusted to include the cattle movements and for the applicant to demonstrate that the proposed development wouldn’t increase the danger to highway users by increasing crossing movements because there is less land to graze on the northern side of the road whilst the quarry is operating.
Fast forward to 2021. Has anything been resolved? Has Aggregate Industries demonstrated that more frequent cattle movements wouldn’t increase the danger to highway users? Of course not. No safety assessment on this issue has yet been provided. Consultants Vectos had previously warned:
The provision of a Cattle crossing over the B3174 may have severe impact on the operation of the B3174
In Aggregate Industries' Supporting Statement, the company claims:
The proposed crossing... provides betterment to the current situation in terms of enabling a shorter traverse of the highway, effectively reducing crossing times which both the tenant farmer and road users will benefit from.
Betterment? Straight across the road rather than diagonal is not betterment when we’re talking about introducing 150 slow moving cows, with set-up and clear-up times. In what parallel universe does Aggregate Industries operate??

Let’s remember, the current situation is that livestock cross this road a) infrequently, b) at quiet times, and c) in low numbers. Dairy cows DO NOT generally cross this road. The farmer has no requirement for such crossings, given the amount of pasture north of the B3174. It’s not complicated.

However, if almost 90% of the grazing pasture from the farm were taken for quarrying, the farmer would be forced to seek alternative pasture on the south side of the road; 150 cows would be forced to cross the road four times daily during the lifetime of the quarry. Again, this is not complicated.

Aggregate Industries’ Supporting Statement states:
The tenant farmer has made it known to Aggregate Industries UK in its capacity as Landlord that in certain circumstances it may become necessary to move the dairy herd and other livestock over to the south of the B3174 Exeter Road to access other grazing land owned by the tenant’s family.
But let’s get this clear. The crossing would ONLY be needed if any quarrying were to proceed. No farmer would want to be forced to cross this road with 150 cows four times a day, any more than any driver would want to wait the 15 minutes or more while they do so.

So how on earth can Aggregate Industries claim such a crossing "provides betterment to the current situation"? Since when has introducing a new hazard on a road – designated with warning signs 35m each side of the crossing for any one in doubt – been called betterment?


Furthermore, how on earth is it that Aggregate Industries’ application fails to mention that up to 216 HGVs a day – one every 3 minutes – would be put into the mix from its own operations, fails to assess the safety implications on this 60mph limit road, fails to mention the frequent accidents along this stretch of road, fails to assess the resulting queues of traffic, fails to assess the impact of such queues on the A30 Daisymount junction, fails to assess the impact on emergency traffic to the hospital, fails to assess the creation of rat runs to avoid the queues, fails to assess the implications of muck on the road?

How on earth – for Ottery’s main and busiest road – is it that none of this is mentioned? How is it that Aggregate Industries has the gall to claim "there are no material considerations why planning permission should not be granted"?

In fact, how have the issues of road safety connected with this crossing been swept so neatly under the carpet? What has been going on behind the scenes? What false illusions might Devon County Council have been labouring under? Fortunately, previous Freedom of Information requests to the Council tell us.

In an email from DCC in 2019, advising Aggregate Industries to seek planning permission for a cattle crossing to 'improve' upon the current diagonal crossing point:
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 to the Mineral Planning Authority dated 26 February 2018.
The email referred to, from the Tenant Farmer’s Land Agent, details the existing infrequent movements. But what the email also says is:
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.
How very selective of Aggregate Industries to have chosen to omit this line from its Supporting Statement for the cattle crossing.

But why is DCC talking about "betterment", given that Aggregate Industries’ Supporting Statement makes clear that the application is "to facilitate an efficient crossing point for the current dairy herd at Straitgate Farm"? Has DCC been labouring under the illusion that cattle numbers crossing the road would not increase? Perhaps so. Look at Aggregate Industries’ draft Transport Assessment:
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. 6.3.7
This is plainly nonsense given that a quarry would remove almost 90% of the land.
The area of the existing agricultural holding extends to some 120.78 acres (48.9ha)… The application site covers an area extending to some 42.5ha, with mineral extraction proposed to take place within 22.6ha with the remainder of the site occupied by temporary soil storage bunds, mitigation planting and site management and access areas. 2.1.10
And what is the "worst case scenario" Devon County Council mentions? In an internal DCC email dated 4 September 2019:
Basically I want [DCC Highways officials'] opinion on if we take the ‘worse case scenario’ of the uncorroborated report of cattle movements across Exeter Road in the revised TA, including an email from the Tennant (App E) and plan showing the livestock crossing point (App F). Then should we be recommending that these cattle movements are mitigated by a condition requiring realignment of the crossing point to be at 90 degrees to the highway and/or cattle pens are required on the south side to aid quickness of movement.
But what is the "worst case scenario"? Existing numbers? It’s not entirely clear people know. In an internal DCC email 23 August 2019:
...is it clear that it’s the worst case scenario this time?
In another internal DCC email dated 21 November 2018
I didn’t read the worst case scenario so not entirely sure what the difference is.
And another dated 21 February 2018:
If we, in one of the most rural counties in England, go before our committee ‐ which has one or two farmers on it, without a realistic baseline on the agricultural activities we would be rightly chastised ‐ and the objectors would make sure that happened…. It is incomprehensible that [AI's traffic consultant] is saying 15‐30 cows.
So what is the "worst case scenario" everyone is referring to? Has a worst case ever been presented? Aggregate Industries’ traffic consultant, the one that seemed unsure whether "cows are milked twice a day", the one saying "15‐30 cows", originally claimed:
Our interpretation is therefore based on a logical ‘worst case’ situation from the base line information.
This is the baseline information referred to in the email dated 26 February 2018 from the tenant farmer’s land agent. This email details existing movements, NOT the worst case scenario where the entire dairy herd would have to cross the road four times daily.

So when DCC refers to betterment, it appears to be referring to the existing movements, NOT the future movements that would need to occur should quarrying remove 105 of the farm’s 120 acres on the north side of the B3174. Aggregate Industries’ application however is "to facilitate an efficient crossing point for the current dairy herd at Straitgate Farm", an entirely different set of numbers altogether.

Where might the confusion arise from? DCC had initially asked for a joint statement between Aggregate Industries and the farmer. The company produced a statement, and put it – unsigned – in its Transport Assessment. The document claimed:
The approach outlined above negates the need for the Tenant to arrange to move livestock across the public highway at a greater frequency than that of the baseline and therefore there will not be a requirement to construct a new crossing point.
The problem was that the statement remained unsigned. Aggregate Industries’ traffic consultant, in an email to DCC 21 May 2019, was forced to admit:
We have removed the joint statement from the appendix and replaced it with the email from the land agent which sets out the livestock movements.
The existing movements email is what all parties are relying on. Indeed, Revision E of the company’s Transport Assessment reads:
The Tenant Farmer, through their Land Agent, provided the following information (reproduced below for ease of reference) direct to the Mineral Planning Authority, by email dated 26 February 2018, in relation to annual livestock movements across the B3174. The data below fixes the current baseline based on the current Tenant Farmer’s operational practices. 3.2.3
Again, this is the very same email that warns:
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 betterment? Of course not. Clearly Devon County Council is trying everything possible to make this work, but 150 cows crossing four times daily across Ottery's busiest road for up to 12 years cannot just be magicked away, neither can "the danger to highway users by increasing crossing movements".