Tuesday, 26 July 2022

DCC’s statement of case

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SAG’s statement of case

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Friday, 22 July 2022

Landbank above 7 years at time of Straitgate decision – revision shows

This week, Devon County Council issued a revision of the county's sand and gravel landbank as it stood at the end of 2020. 

This was the landbank figure applicable last December when Aggregate Industries’ planning application to quarry Straitgate Farm was determined. The figure should have been 7.6 years – not the 5.7 years put forward by the Council. 

We pointed to the spurious fall in 2020's sand and gravel reserves – a loss of 0.9 million tonnes in excess of sales – at the time. The 10th Devon LAA claimed: 
There has been a significant reduction in reserves during 2020. This can be attributed to a reassessment of reserves by operators. 
Devon County Council has now sent a correction – Appeal Note – Landbank - 20/07/2022 – to the Planning Inspectorate, which states: 
1.3 In the course of preparation of the [as yet unpublished] 11th Devon LAA, based on aggregates sales and reserves data for 2021, it has been identified in July 2022 that an inaccurate figure for reserves provided by a mineral operator [not the Appellant] for the 2020 aggregates survey has resulted in the calculation of an incorrect duration for the sand and gravel landbank.

3.7 Contrary to the statements made in the committee report as outlined in paragraph 1.1 above, Devon’s sand and gravel landbank was, using the revised landbank figure of 7.6 years, above the seven years minimum required by Policy M11 of the Devon Minerals Plan [CD8.02] and paragraph 213 of the National Planning Policy Framework [CD8.01]. 
Indeed, the notion that the landbank was less than the 7 years suggested by the NPPF featured heavily in the committee report that informed councillors determining the Straitgate application: 
6.1.10 The 10th LAA for Devon... shows that, at the end of 2020, the landbank for sand and gravel was 5.7 years and it has therefore fallen below the seven years minimum required by paragraph 213 of the NPPF and Policy M11 of the DMP. 

6.1.12 In this context, Part 2 of Policy M11 presumes in favour of permitting proposals for a new or extended sand and gravel site as the relevant landbank is below the minimum duration… 
Crucially, the apparent shortfall guided the "Planning Balance and Reasons for Recommendation": 
7.5 A number of objectors have pointed out that the reduced amount of aggregate to be derived from the site must now mean that the harm caused by the proposal would outweigh the benefit of working the site; however, the current aggregate landbank has also fallen below the required seven years supply and this would weigh significantly in favour of this proposal in the absence of any other site coming onstream in the near future. 
Clearly, with more than 7 years’ worth of permitted sand and gravel, the size of the landbank should NOT have "weigh[ed] significantly in favour of this proposal". 

Indeed, knowing the true figure, the officers might even have had to recommend refusal, given what "a fine balance" the whole decision was: 
7.22 Although this site is allocated in the current Devon Minerals Plan, the length of time it has taken to bring it to determination has reflected the complicated issues that needed to be addressed, and it is acknowledged that the benefits of delivering the Minerals Plan proposal and maintaining the required aggregates supply, set against the impacts of the proposed development, has been a fine balance 
Aggregate Industries' statement of case for the appeal also plays heavily on the fact that the landbank for sand and gravel was below 7 years. 

One might reasonably conclude that the company's case is now even flimsier.
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Holcim’s cost to society in 2021? 156 million tons of CO2 emissions

As the UK hit 40°C this week, a milestone in UK climate history, spare a thought for residents of an Indonesian island threatened by rising sea levels who have begun legal action against the cement producer Holcim – parent company of Aggregate Industries. 


You can see why. We have posted about Aggregate Industries’ parent, and its record on CO2 emissions. Last year we posted LafargeHolcim’s cost to society in 2020? 146 million tons of CO2 emissions – more than many countries. 

Since then the name has changed but the pollution goes on. In 2021, Holcim's cost to society has INCREASED to 156 million tons. 


So much for all the claims, for all the greenwash:


Holcim maintained its focus on CO2 emission reduction in 2021... we acknowledge we must accelerate our CO2 reductions in the coming years.
And what about Aggregate Industries, Holcim's UK subsidiary? 


Kirstin McCarthy, sustainability director at Aggregate Industries, says: 
We need to transform our business and we have already made progress.
This is the same sustainability director who spoke in support of the company’s wholly unsustainable 2.5 million mile haulage plan for Devon. 

She says: 
Our priorities are to reduce our impact on the climate, protect and enhance nature and the environment, drive the transition to a circular economy and protect and support our people and communities.
More greenwash. 

But for how much longer can companies make meaningless, hollow claims? Lawyers and environmentalists have greenwashing companies in their sights.


As one article in the financial press remarked: 
The popular ploy of marketing everything from burgers to investment funds as 'green' doesn’t look sustainable any more.
Suggest they include concrete in that list.

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Concrete lobby takes swipe at sustainable timber

We all know that timber is a sustainable building material. It’s renewable and locks in carbon.

Not only does wood remove more CO2 from the atmosphere than it adds through manufacture, but by replacing carbon-intensive materials such as concrete or steel it doubles its contribution to lowering CO2. 
Could we return to wood as our primary building material? One architect says: 
It’s not only realistic, it’s imperative. It has to happen. In architecture you always go back to the sketch: the sketch is climate change.
The concrete industry plainly feels threatened.
 

Steve Elliott, chairman of BAR, the trade association for UK manufacturers and fabricators of concrete reinforcement products, claims: 
When you consider the destructive harvesting, industrial manufacturing process, additional chemicals and monoculture plantations it may be that too much credit has been given to timber being a green material. Indeed, it may better to keep the ‘wood’ alive rather than cut it down and build with it.
David Hopkins, chief executive of Timber Development UK refuted such "strawman arguments": 
This report from BAR really brings nothing new to the table other than a desperate attempt to smear a sustainable construction material by those sectors which have a less than positive tale to tell about their environmental impact 

There are already fully verified environmental product declarations behind all timber construction products which consider the whole supply chain. This means the impacts of timber products are measured, assessed, and verified by independent experts from forest to factory to operational building – right through to the product’s end of life. 

The truth is that timber is a renewable material which comes from sustainably managed resources – growing throughout Europe – which absorbs and stores carbon and requires very low energy inputs to process into high-performance low-carbon construction products. 

Concrete, on the other hand, requires materials such as sand – produced from dredging rivers and seabeds, destroying ecosystems and habitats in the process – and huge inputs of energy and water to manufacture. It’s a very high carbon material – and an issue which must be tackled to decarbonise construction. 

Rather than a constructive attempt to find solutions to the climate crisis, they would rather waste time dreaming up strawman arguments like this report because they know they cannot compete in a market with a greater focus on sustainability.
In other news:
 

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