Wednesday 25 August 2021

Springs appear when groundwater levels are high

For anyone wondering why a spring might appear in the area Aggregate Industries has designated for the storage of overburden, as we recently posted about here and here – an area where, to facilitate like-on-like soil storage, the company would first have to excavate topsoils and subsoils without breaching the maximum water table – the following rainfall anomaly maps should provide a clue:
Groundwater measurements were taken from all the boreholes around Straitgate Farm last week by consultants working on behalf of Aggregate Industries. The groundwater level in at least one borehole was as high as 2014 levels for the same time of year – 2014 being the year when most of the highest water levels were recorded at the site, even though there were only 6 boreholes around the proposed extraction area – not the current 13, with another 5 further afield.
 

Why are summer groundwater levels important? Aggregate Industries' unorthodox, untried, untested, seasonal working scheme relies on groundwater levels falling by at least 1m during the summer. We have pointed out that there are several areas where this seasonal scheme can't work

Will we be told if any of the other boreholes have recorded particularly high groundwater levels this summer? No. In 2018, when its model of the maximum water table – which had been "defined with confidence" and "builds in a conservatism" – was exceeded in four places by up to 1.6m, Aggregate Industries in its embarrassment put a stop to the public scrutiny of groundwater data for the Straitgate application, "in-line with company policy". 

AI has not assessed the impact of climate change on groundwater

The aquifer at Straitgate Farm supplies many people with drinking water.

For a proposal that would permanently remove a large part of the unsaturated zone above the aquifer, and permanently change the landscape, it beggars belief that neither Aggregate Industries nor its hydrogeology consultants have considered the effect of climate change on the groundwater at Straitgate.

In fact, the number of occurrences of the word climate in Aggregate Industries’ Hydrogeological Assessment is precisely zero. It’s a big omission.

It is an irrefutable fact that our climate is changing, that rainfall patterns are changing
The overarching picture is warmer, wetter winters; hotter, drier summers
It is important that project designers incorporate climate resilience into the design of the project at an early stage. This means evaluating what resilience measures may be appropriate to include in the design, and this should take place at all stages of design development – from optioneering through to detailed design, not just as a part of the EIA process.
Whilst Aggregate Industries has not considered the impact of climate change on groundwater levels at Straitgate, Professor Brassington has. His Note on the impact of climate change on the proposed quarrying at Straitgate Farm has now been submitted to Devon County Council: 
The main impact of climate change will be the fact that the winter water table will be at a higher elevation than it is now. If this planning permission is granted a common-sense view would be that the rise in the water table that will happen caused by climate change should be accommodated by adding an additional amount to the calculations to account for the additional recharge and the water table rise. 
Of course, the water table at a higher elevation could obviously affect surface water run-off and flooding to downstream communities; the water table at a higher elevation could leave parts of the restored landscape underwater and unfarmable. Aggregate Industries' consultants have assessed none of this.

And there's another problem. Prof Brassington has already warned that the proposal would permanently change the chemistry of the groundwater, making drinking water sources forever too acidic. In this new report he warns that climate change will exacerbate the problem. 
The proposal to remove the unsaturated zone will halve the time available for rock-water interaction which is the main process by which the pH of the water is neutralized from an acidic value of some pH 4.5 which will mean that the water will not be fit for drinking. As a result of the factors discussed in this report, climate change will exacerbate the problem. The BSPB aquifer in the Straitgate Farm area must be regarded as a fragile groundwater system because it lies at the upper end of an aquifer that has springs located only a short distance from the recharge area. 
Prof Brassington concludes: 
The simplest thing would be for the planning authority to refuse permission. 
And who can argue with that?

More greenwash from Holcim

The world’s largest cement producer is greenwashing again:
 

What Aggregate Industries' parent Holcim fails to mention is the industry’s monstrous CO2 emissions:
 

So, is concrete the ideal sustainable material for our future? Clearly this prize-winning writer doesn’t think so, in fact quite the reverse:
 

Some wonder if the cement companies are deliberately keeping us addicted to concrete:
 

As for all the sand needed to make concrete:
 

Monday 16 August 2021

EA maintains ‘no objection’ – despite warnings from award-winning Prof, despite not knowing ‘workability’ of S106, despite being unsure of base & extent of workings

It really is shocking – embarrassing even – that after all these years, the Environment Agency plainly still can’t get its head around Aggregate Industries’ plans to quarry Straitgate Farm. 

In its latest response, which continues to offer no objection, the Environment Agency seeks clarification on the central and most fundamental aspect of the proposal: 
we request clarification as to whether the February 2021 Maximum Winter Water Table (MWWT) contours are the same as the contours of the intended quarry base.
Firstly, many will wonder how, without knowing the elevation of the base of the proposed quarry, the Agency could possibly be in a position to produce a reliable response on the impact to groundwater. 

Secondly, by seeking such clarification, the Environment Agency provides ample evidence to show it isn’t fully familiar with Aggregate Industries' planning application, because such information is already contained in a number of documents, such as:
In the Non-Technical Summary, 3.8: "The depth of working is set by the level of the maximum winter water table." 

In the Supporting Statement, 2.4.7: "The resource declared assumes a working base that coincides with, and never drops below the Maximum Winter Water Table (MWWT) modelled by hydrogeological specialists AMEC Foster Wheeler following extensive monitoring and analysis since January 2013." 

In the Hydrogeology Assessment, 1.1.3: "Mineral will be worked down to a level defined by the maximum winter water level and then a layer of overburden replaced." 

In the Hydrogeology/Drainage Reg 22 responses, 2.2.1: "...the Maximum Winter Water Table (MWWT) used as the basis of extraction models,..."; 2.2.8: “... derived from the MWWT (i.e. the final proposed depth of working)..."; 2.4.6: "The quarry will be worked dry and down to a level defined by the maximum winter water level...". 

In the Hydrogeology/Drainage Reg 22 response, Appendix C: "... will be extracted to the MWWT." 

In the Resource Assessment, February 2021, 2.1, "The MWWT will ultimately form the base of the workable deposit, and any variation will impact the potential resource." 

In Aggregate Industries' letter, April 2021: "In respect of the revised Mineral Resource Assessment based on the latest modelling of the Maximum Winter Water Table the revised figure of the reserve is still over 1 Million saleable tonnes...". 
But it’s not only the depth of the proposed quarry that the Environment Agency isn’t clear on, it’s also the extent – advising Devon County Council: 
we suggest that your authority may wish to consider whether you want to see an updated plan of the extent of the extraction area (taking into account the near-surface MWWT contours in the north- east part of the proposed excavation area) prior to determination. 
However, if the Environment Agency had been up to speed, they would know that Devon County Council had already asked Aggregate Industries this very question, and the company argued that despite such near-surface MWWT contours "The extraction area... remains unchanged."

The Environment Agency isn’t clear on the "workability" of the S106 either, happy to continue to offer Aggregate Industries "no objection" whilst not knowing how or even if alternative water supplies could be provided – to more than 100 people, livestock farms, businesses, Grade I listed Cadhay and its mediaeval fishponds, wetland habitats in ancient woodlands – advising the Council: 
We recommend that your authority obtains legal opinion on the workability of the proposed S106 agreement.
The Environment Agency was also told about the threat to groundwater in the proposed overburden areas, but, despite being the guardians of our precious groundwater, not a mention in the response. 

And yet, despite these failings, and despite still seeking clarification on the extent and depth of the proposed quarry, the Environment Agency feels sufficiently competent to entirely dismiss all the warnings from Professor Brassington, an eminent authority in the field

How on earth could Devon County Council possibly rely on the Environment Agency’s conclusions when they are so clearly flawed?

Tuesday 10 August 2021

Chard Junction Quarry

Aggregate Industries’ planning application WD/D/19/000451 for an extension to Chard Junction Quarry in the Dorset AONB has been the subject of a number of posts.

The application is to quarry some 830,000 tonnes of sand and gravel, "approximately 90%" of which would be for the "decorative market." Dorset Council planning officers recommended approval – despite the fact that "Great weight should be given to conserving and enhancing landscape and scenic beauty in... Areas of Outstanding Natural Beauty which have the highest status of protection", and despite the proposal's "significant adverse landscape impact on the character of the designated Area of Outstanding Natural Beauty". How screwed up is that?
However, determination has been delayed following discovery that "officers had sent the notification to an old email address for the Tatworth and Forton parish council." That parish council has now "resolved to strongly oppose the planning application", one reason being: 
1. As it is a major new development in an Area of Outstanding Natural Beauty (AONB), paragraph 172 of the National Planning Policy Framework applies. This states that such a development must meet an ‘exceptional circumstances’ test. Since the need for the stone is not primarily for construction but for decorative purposes, the Council considers there is not a sufficient reason for severely damaging an AONB. 
Hear, hear. The parish council also pointed to the support from Devon County Council, saying: 
Devon Council supports this application, but says that "if permission were refused the knock-on effect for Devon is likely to be quite small."

UN climate change report sounds ‘code red for humanity’

"The alarm bells are deafening," warns UN Secretary-General António Guterres.

 
How is this urgency reflected in UK planning? On 20 July 2021, a new version of the National Planning Policy Framework was released. We posted about it here. The NPPF sets out the government’s planning policies for England and how these are expected to be applied. 

According to this article, the term "climate change" appears three more times than the predecessor document published two years before. The NPPF has not been updated to reflect the UK’s 2050 net zero obligation approved by Parliament in 2019. The section on "planning for climate change" still reads: 
152. The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience; encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure. 
However, reference to the UN’s 17 Global Goals for Sustainable Development has been added to the NPPF, and the paragraph which defines sustainable development in more detail has been toughened up with "much more binding" language about protecting and enhancing the environment: 


Nevertheless, it seems a meagre response to the crisis we now find ourselves in. This editorial argues: 
Without an accelerated reduction in greenhouse gases during the next decade, the ambition of the 2015 Paris climate agreement to limit global heating to 1.5C will not be met. The price of failure will be a world vulnerable to irreversible and exponential effects of global heating: there will be worse floods more often, more terrible and frequent heatwaves and devastating and repeated droughts. 

The science is irrefutable. Less certain is the strength of political will to act upon it. An awesome burden of responsibility now rests upon this generation of leaders as humanity finds itself at a fork in the road. The actions taken or foregone during the next 10 years will define the parameters of the possible for future generations. A step-change is required, but across the world green rhetoric continues to translate into policymaking at a pace which is fatally slow.

How has Holcim, the world's largest cement producer responded to this dire warning, given that cement is responsible for about 8% of CO2 emissions? Just as if it has played no part at all:
 

This of course is the same company that in 2020 alone pumped out 146 million tonnes of those greenhouse gas emissions choking our planet, the same company that would ultimately profit from the multi-million-mile-CO2-belching-haulage-scheme planned for Straitgate Farm. The hypocrisy.

‘With the risk of #flooding increasing, it's vital that planners take pre-emptive action’

... says Aggregate Industries. 

How ironic then that the company’s flood mitigation plans for its planning application to quarry Straitgate Farm are in such disarray, with Devon County Council’s Flood Risk Management Team indeed having to take pre-emptive action, with an objection to the proposal lodged in May this year.


Of course, it is the CO2 emissions from Aggregate Industries – and the monstrous emissions from parent Holcim and other polluters – that are forcing planners to take such pre-emptive action and review their flood defence strategies.

Monday 9 August 2021

Devon Garden Trust maintains objection to Straitgate proposal

Aggregate Industries’ "final response" for its planning application to quarry Straitgate Farm has not persuaded Devon Gardens Trust to lift their previous objection to the proposal.

Last week, Devon Gardens Trust – part of The Gardens Trust, and statutory consultee on development affecting registered parks and gardens in Devon – wrote
On the basis of the supplementary documents now provided, we conclude that, if implemented, the proposed scheme would cause more than substantial harm to the Grade II designed landscape at Cadhay, which forms the designed setting for the Grade I house. This level of harm to two, inter-related, nationally designated heritage assets, clearly conflicts with Government planning guidance contained in the National Planning Policy Framework (especially paras 193-195), and with local and County planning policy. 

In these circumstances we urge your Authority to withhold consent for this highly detrimental proposal.

Friday 6 August 2021

More overburden storage problems

According to Aggregate Industries, 159,000 cubic metres of overburden material from above the sand and gravel resource would need to be stored elsewhere on site in 5m high mounds if Straitgate Farm were to be quarried, material that would in time need to be restored. 

The issue of soil storage is important. The Devon Minerals Plan states "a proposal affecting the best and most versatile land should provide for the restoration of the land to its former quality." Natural England had asked for more information on the storage of subsoils, information that was not supplied

The different categories of retained soils must be stored like-on-like. Overburden can only be stored on overburden. Topsoils and subsoils S1 and S2 would first need to be removed from those storage areas, and stored elsewhere. At the same time, in line with proposed conditions from the Environment Agency, "no working shall be undertaken below the ‘Maximum Winter Water Table (MWWT) grid’" or "closer to the contemporaneous measured groundwater level than 1m." 

We have recently posted that – in the middle of summer – a new spring was discovered exactly where Aggregate Industries wants to stockpile 82,000 cubic metres of overburden in the area designated OB1. The new spring is close to the borehole location SG21/90 where groundwater was recorded just 1.26m below the ground surface in June 1990. 


However, there’s clearly a further problem. The geological plan shows groundwater close to the surface in the other area designated for overburden storage, OB2, where Aggregate Industries wants to stockpile another 77,000 cubic metres of overburden. Borehole SG12/90 recorded groundwater at 1.59m below the surface – again in the middle of summer, in June 1990. 

The EA has stipulated that these 1990 groundwater levels should inform the application

There is clearly an unmistakable pattern beyond the eastern boundary of the extraction area, along the geological fault line, exactly where Aggregate Industries wants to store overburden. 


This is a photograph of another spring, issuing to the north of the planning red line boundary as indicated at the top of the above plan, taken just last week. 


So, where could overburden be stored where the removal of topsoils plus subsoils would not breach the maximum water table, where groundwater would be at least 1m below any working? Given that no groundwater monitoring has been carried out in the proposed overburden storage areas, no one knows.

EDDC Environmental Health calls for S106 improvements before determination

East Devon District Council, who is required by law to monitor private water supplies to ensure safety standards are met, has responded to Aggregate Industries’ planning application to quarry Straitgate: 
However unlikely, it’s clear that a residual risk remains to the private water supplies from the application, in terms of maintaining sufficiency and quality of the water. As such, there is a potential risk to health for consumers... 
We consider the Head of Terms to be currently insufficient to mitigate any temporary risks to health which could arise from contamination or derogation of private supplies, as substantial delays in provision of temporary arrangements are likely to manifest while the attributable cause is agreed or contested. Improvement to the 106 Agreement should be obtained prior to any permission being granted, whereby temporary wholesome supplies should be provided in lieu of the likely cause of any water deficiency being investigated and determined.
The draft Heads of terms referenced can be found here. We last posted on this issue here

#DYK Greenwashing Holcim has taken to reading the Guardian

Who would have thought that the world’s largest cement producer – whose cost to society in 2020 was 146,000,000 tonnes of CO2, about the same as Venezuela – would have taken to reading the Guardian?


Is the parent of Aggregate Industries about to wake to the realisation that its emissions from cement production are helping to destroy our planet? Or is one of the world’s largest polluters simply greenwashing again – making it look as though it cares, when every single day it adds to the problem? 

For context, let’s add the next sentence from the quote that Holcim picked out: 
While no one is suggesting planting trees to that extent, the report’s authors said it gave an idea of the scale of planting required, and how limited offsetting should be if food price rises are to be avoided. 
Nafkote Dabi, climate policy lead at Oxfam and co-author of the report, explained: 
It is difficult to tell how much land would be required, as governments have not been transparent about how they plan to meet their net-zero commitments. But many countries and companies are talking about afforestation and reforestation, and the first question is: where is this land going to come from?
Which seems like a valid point. Danny Sriskandarajah, chief executive of Oxfam GB, called for companies and governments to cut their emissions drastically rather than relying on offsets:
Too many companies and governments are hiding behind the smokescreen of ‘net zero’ to continue dirty business-as-usual activities. 


Holcim makes a lot of noise about reducing its CO2, but – as we posted earlier in the year – progress has been glacial: 
…there was an overall reduction of 7.5% in LafargeHolcim’s total CO2 emissions from an adjusted 157.8 million tons (148m + 9.8m) in 2019. Bravo, you might think.  

However, given that LafargeHolcim sold 8.4% less cement in 2020 – 190.4 million tons vs. 207.9 million in 2019 – progress looks rather less impressive, implying total CO2 emissions actually rose per unit of material sold. Given the attention LafargeHolcim claims it is devoting to the problem, and the urgency of our climate crisis, that’s concerning. 

What’s also concerning is the company's claims on carbon efficiency. LafargeHolcim's main Sustainability Key Performance Indicator is net CO2 emitted per ton of cementitious material. In 2020, this was reported as 555kg net CO2 per ton – down 1.1% on the previous year. The reduction mirrors 2019, down 1.4%, and 2018, down 1%. If 2020’s rate of reduction were to be maintained, the company’s revised 2030 target of 475kg net CO2 per ton would not be met.
Who knows where our climate will be by 2030, 2040, let alone 2050 – at the rate of change we have been seeing. As for carbon offsets: 


The UK is already undergoing disruptive climate change with increased rainfall, sunshine and temperatures, according to scientists. The year 2020 was the third warmest, fifth wettest and eight sunniest on record, scientists said in the latest UK State of the Climate report. No other year is in the top 10 on all three criteria. 

Mike Kendon, senior climate scientist at the Met Office National Climate Information Centre, and lead author of the study, said: “We see a continuing emerging pattern of more high temperature and more rainfall extremes. The baseline of our climate is changing and what we regard as normal is changing.” 

Dr Jess Neumann, a hydrologist at the University of Reading, said: “Flooding from intense summer rainfall is going happen more frequently. No city, town or village is immune to flooding and we all need to take hard action right now if we are to prevent impacts from getting worse in the future.” 
Meanwhile, in other news:

Tuesday 3 August 2021

‘AI’s claims must be trusted,’ says Somerset CC, ‘otherwise RTPI cast into disrepute’

Over the years, we have catalogued the fiction that Aggregate Industries has produced to support its planning application to quarry Straitgate Farm, saying
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?
Last week, Aggregate Industries’ second planning application to re-open Bartletts Quarry in Somerset, a limestone quarry in the Mendips, and to cast aside previously agreed planning conditions and S106 agreements intended to protect local communities, was determined in the company’s favour. We’ve posted on this issue before. The first application had been flatly turned down in January. The second, lodged in May, was essentially the same, and again attracted the wrath of locals.


What had changed? According to objectors, very little. Having plainly got things so wrong with the first application – suffering a 7-0 defeat – Aggregate Industries supplied revised documentation
1.2 This revised submission therefore seeks to provide additional evidence on the benefits of allowing Bartletts Quarry to re-commence quarrying of carboniferous limestone including the nationally significant contribution Somerset makes to the country’s mineral supply and the benefits of enabling Torr to maximise rail exports and the local employment, investment and training opportunities that the minerals industry provides. 
1.3 The key benefits of our application are considered to be: • Jobs and investment in the local economy, re-opening Bartletts would create up to 8 new permanent jobs and at least 6 to 10 jobs within the wider supply chain. This will complement the existing AIUK employment in Somerset of over 200 people through direct and supply chain... 
Additional evidence was a moot point. Objectors questioned whether assertions made by Aggregate Industries amounted to evidence. Picking just three of the many objections at random: 
much of the "evidence" cited was either known at the date of the original (rejected) application or is merely a forecast of the applicant's own making. 

The resubmission relies on statements that could sound persuasive but are not substantiated by detail. Up to 8 jobs could be created but there could be fewer, even none.

I disagree that these applications contain any new information that would require review by the committee. This is a blatant exercise in throwing enough applications in the hope one will be approved or be missed by the local residents who are objecting. AI claim to listen to the local community, but in fact appear to ignore them and previous decisions made.
However, Somerset County Council’s planners sided with the company
8.10.1 Objectors seems to be questioning the claims of extra employment that are raised by the applicant and whilst this is understandable the planning statement is written by a qualified professional who is a member of an institute whose claims must be trusted so as not to bring disrepute to said institute. 
Given the amount of fiction uncovered in Aggregate Industries’ planning application for Straitgate, why – without seeing any evidence – was Somerset County Council so trusting? And of which institute does membership – in the eyes of Somerset County Council – bestow immunity from cross examination? 

In line with legislation introduced in 2017, Aggregate Industries’ Environmental Statement included a "Statement of Competency": 
In accordance with Regulation 18(5) of the EIA Regulations, the ES must be accompanied by a statement outlining the relevant expertise and qualifications of the experts who have been involved in its preparation.
A list of names was duly included, starting with an Aggregate Industries’ Planning Manager (MRTPI) who "has 30 years' experience in minerals planning", including at a Minerals Planning Authority. Which one? Somerset, of course. And which institute? The Royal Town Planning Institute (RTPI), "the professional body representing planners in the United Kingdom and Ireland". MRTPI, signifying Chartered Town Planner, "represent the gold standard of planning practice" and are "recognised by employers, clients and members of the public for their skills, expertise and professional practice". The RTPI has a Code of Professional Conduct
All Institute members are required to abide by the Code of Professional Conduct. If you feel that a member has breached the Code then you should consider making a complaint to the Institute. The Code of Professional Conduct requires (amongst other things) that all members should: act with competence, honesty and integrity; give their impartial professional judgement to the best of their ability... and not bring the Royal Town Planning Institute into disrepute.
This obviously raises questions in relation to Aggregate Industries’ error-ridden planning application for Straitgate Farm. Because if MRTPI represents "the gold standard of planning practice", why did the above Planning Manager put his name to this farcical half-hearted effort – "our final response to the queries raised as part of the consultation", which contained some cock-and-bull story about the 23 million tonne resource at Penslade, and utterly failed to address the majority of concerns that have been raised, including from statutory consultees on soil management and flooding – no more than 3 months after putting his name to another letter, "our final submission of additional information". Clearly, whatever MRTPI is meant to signify, one resident local to Straitgate was prompted to write
But what do we get from Aggregate Industries in response to all these pressing unresolved issues? A cursory four page letter from a non-specialist representative saying, to all intents and purposes, that as far as they are concerned there is nothing to add, and that the matter is now closed. Interpreted more colloquially this is "two-fingers to the lot of you!" Plainly AI want a quarry approved at Straitgate, come what may, and they have finally lost patience with the general public.

Sales of sand and gravel in Devon down 12.6% in 2020

In 2020, sales of sand and gravel in Devon were 437,000 tonnes, down 12.6% on the previous year, according to figures recently released by Devon County Council. Nationally, sales of sand and gravel were down 12.4% in the same year, according to the MPA.

The long term trend in sales of sand and gravel in Devon continues to decline; the fall in 2020 comes on top of a 7.6% fall in 2019, and a 10% fall in 2018

Since 1990, annual sales of sand and gravel in Devon have fallen by 74%.

 


At the end of 2020, reserves of sand and gravel in Devon stood at 2.88 million tonnes, a landbank of 5.7 years. Reserves fell by 1.3 million tonnes from the previous year, 0.88 million tonnes more than sales. 

It would seem that Devon's aggregate suppliers have carelessly lost millions of tonnes of reserves yet again. According to Devon County Council:
The reduction can be attributed to a reassessment of reserves by the operators and their reporting of these to us. It is not just the sand and gravel reserve which has been affected by this in 2020, there has also been a significant drop in the crushed rock reserves too (from 95.378mt in 2019 to 81.323mt in 2020).