Aggregate Industries delays PWS monitoring scheme visits

In June, Aggregate Industries wrote to Private Water Supply owners surrounding Straitgate Farm, advising that the company would visit them in the Autumn "to agree how, and where, we would monitor your private water supply". 

Aggregate Industries has now written to PWS owners, advising that the company is "not currently in a position to undertake the proposed visits to agree monitoring locations this Autumn. Instead we are hoping to undertake these visits during January 2024...".

Aggregate Industries was granted permission to quarry Straitgate Farm on appeal on 5 January 2023.

Secondary aggregates continue to outsell sand & gravel in Devon

This month, Devon County Council published its 12th Local Aggregate Assessment. The LAA is:

… published annually to inform development and monitoring of Minerals/Local Plans, including recent sales and revisions to levels of reserves and the length of landbanks. 

According to the LAA, sales of land-won sand and gravel in the county have continued to flatline, with 0.521 million tonnes sold in 2022, down 4% from 0.541 the previous year. As the chart below shows, sales have not recovered since the financial crisis of 2008.

Sales of secondary and recycled aggregates across the county, however, tell another story. 

In 2022, secondary aggregates continued to outsell sand and gravel. The LAA explains:

3.3.1 The major source of secondary aggregates in Devon is the by-products derived from the extraction and processing of china clay in the Lee Moor area of Devon, which in 2022 accounted for 85% of the county’s production of secondary aggregates (an increase of approximately 6% from 2021). For each tonne of saleable china clay, up to nine tonnes of other materials are produced, with two main elements capable of use as secondary aggregate:  stent (rock), which can be used as general fill or, after crushing and screening, for other aggregate purposes; and  tip sand (washed material comprising quartz, unaltered feldspar and mica) which, with grading and washing, can be used for a variety of aggregate purposes including concrete and building sand. 

And sales of recycled aggregates grew in 2022, approaching sales of sand and gravel. 

Despite the current economic uncertainty, sales of recycled aggregates increased by approximately 12% in 2022 from the previous year.

The LAA describes recycled aggregates as: 

the waste arising from construction, demolition and excavation activity comprises a range of materials, of which the ‘hard inert’ elements (e.g. concrete, bricks, stone) can be recycled for use as aggregates.

With regard to future availability, there are hundreds of millions of tonnes of china clay mining waste piled all over Devon and Cornwall. A planning application by Aggregate Industries to continue to work secondary aggregates at Lee Moor was approved in 2019. In relation to recycled aggregates, according to the LAA: 

4.2.9 ... the annual processing capacity of Devon’s fixed CDEW recycling facilities (estimated as 1.28 million tonnes in the 2020/21 Devon Waste Plan AMR) is more than adequate for current and potentially greater levels of recycled aggregates production.

The hope must be that sales of the more sustainable secondary and recycled aggregate alternatives will displace the need for digging up primary virgin sand and gravel, including material from the Budleigh Salterton Pebble Beds. 

Hanson’s Town Farm Quarry, near Burlescombe, is one source of material from the Pebble Beds. The LAA reports that the site was mothballed this year: 

2.5.7 Town Farm forms part of Hanson’s Whiteball operation, for which the processing plant lies in Somerset adjacent to its border with Devon. An application for the continuation of extraction of existing sand and gravel reserves for a further 10 years was received in November 2022 and permission was granted in March 2023. The site was still operational in 2022, however, it was temporarily mothballed on 1st February 2023. 

So, clearly, material from the Budleigh Salterton Pebble Beds – the same material that underlies Straitgate Farm –  is not in such high demand, nor so profitable, for Hanson to be persuaded to keep the gates at Town Farm open. 

Aggregate Industries postpones Straitgate public meeting

In February of this year, Aggregate Industries informed us that: 

... we agree with your suggestion of a public meeting but would propose that this may be best held in the Autumn when there will be more information to report on. 

Last week, the company advised that this meeting has been postponed: 

You may recall previously we indicated the possibility of holding some sort of public event in the Autumn to update people on Straitgate.  However matters have not moved as quickly as we had hoped and therefore we are not in that position but I would like to reassure you that this remains part of our plans and when we are ready I will be in touch.

This follows a number of months of apparent inactivity, as we posted here.

We all know Aggregate Industries will have difficulty complying with Straitgate’s ‘no water body’ condition – Google Earth images confirm why

One of the first posts on this blog, back in 2012, asked: Could Straitgate be quarried without water? 

We noted that Exeter Airport's request that "no ponds or body of water be allowed as part of this development" to ensure aircraft safety from bird strikes, would surely be an impediment to any scheme. 

And indeed this impediment has now been formalised.

Earlier this year, the Planning Inspectors, in granting permission to quarry Straitgate Farm, conditioned: 

No water body shall be created within the site other than the approved weighbridge lagoon. 

As we posted in January, this makes Aggregate Industries' plans for Straitgate incompatible with the Inspectors’ planning conditions, given that the company's approved plans rely on the formation of water bodies – both for flood mitigation and for restoration. As we wrote, the Inspectors' condition: 

...is clear and unambiguous. It is not limited by the size or duration of any water body – large or small, permanent or temporary.  

What exactly is a water body? As we previously posted: 

Wikipedia says "The term most often refers to oceans, seas, and lakes, but it includes smaller pools of water such as ponds, wetlands, or more rarely, puddles." LawInsider goes further. This helpful graphic also explains.  

In that 2012 post, we wrote about Aggregate Industries' nearby sand and gravel quarries at Blackhill and Hillhead, quarries that extracted the same type of material from the Budleigh Salterton Pebble Beds that would be extracted at Straitgate Farm. We wrote that Google Earth images: 

...reveal several bodies of water in each and it is inconceivable that Straitgate, particularly with all its water related issues, could ever be quarried without the formation of ponds or lagoons of some kind.

In fact, Hillhead suffered ponding problems only this year. 

Further back, we posted how the water body at Aggregate Industries' quarry at Thorn Tree Plantation at Blackhill was meant to be ephemeral but is instead present all year round. 

The company's quarry at Venn Ottery also suffered ponding issues. 

Hanson’s Town Farm Quarry works the same type of material and also has bodies of water. 

But let's build on that 2012 post, and, using Google Earth’s historical imaging, look at all five BSPB quarries in Devon that have been worked in recent times. The images below show the quarries at Venn Ottery, Marshbroadmoor at Rockbeare, Thorn Tree Plantation at Blackhill, Houndaller at Hillhead and Town Farm, at a time when extraction was actually underway. 

Venn Ottery

Marshbroadmoor

Thorn Tree Plantation

Houndaller

Town Farm

Clearly, sizeable new bodies of water were introduced at all of them.

So, even if we were to overlook Aggregate Industries' flood mitigation and restoration plans for Straitgate – that actually encourage water bodies – the above images underline, if any more underlining were needed, just how unworkable the whole scheme really is. 

‘Tyre wear particles now the leading cause of traffic pollution’

Aggregate Industries claims to be:

... a progressive, future-facing business. A company that is intrinsically sustainable - trusted and respected by stakeholders and the communities in which we operate.

Fine words, but in the real world the company's scheme at Straitgate Farm will see as-dug aggregate hauled 23 miles between quarry face and processing plant, more than any other UK quarry operation, some 2.5 million HGV miles in all. 

So, unless Aggregate Industries' HGVs magically run without tyres, Devon communities will pay the price.

Health impact of tyre particles causing ‘increasing concern’, say scientists https://t.co/8zMT8McSeq

— The Guardian (@guardian) February 23, 2023

The warning follows UK government data that shows significantly more tiny pollution particles now come from tyre erosion than are emitted from vehicle exhausts. The report estimates 52% of all the small particle pollution from road transport came from tyre and brake wear in 2021, plus a further 24% from abrasion of roads and their paint markings. Just 15% of the emissions came from the exhausts of cars and a further 10% from the exhausts of vans and HGVs.

Forget Dieselgate — a bigger emissions problem hides in plain sight https://t.co/eKCHnRdThJ

— Financial Times (@FT) October 30, 2023

As we drive, our tyres wear down and release invisible particles that we inhale and ultimately ingest. Strikingly, the rate of release of these particles is almost 2,000 times greater than the mass of particles from a modern exhaust pipe. It looks likely, then, that these apparently mundane yet economically vital and technically sophisticated products are a source of pollution that will make Dieselgate — the exhaust emissions cheating scandal of 2015 — look minor. The difference? No rules are being broken, yet current US and EU polices promoting battery electric vehicles through subsidies are set to make the problem worse.

Sand & gravel sales slump

The Mineral Products Association has reported "a further deterioration in demand for heavy-side materials over the summer":

The third quarter saw notable declines in the sales of ready-mixed concrete and sand & gravel, with drops of 15.0% and 12.2%, respectively. For ready-mixed concrete, the magnitude of the decline is comparable to 2009Q1, when macroeconomic and construction conditions were severely impacted by the global financial crisis.