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. 

Secondary aggregate sales in Devon continue to rise – whilst sand & gravel flatlines

In 2021, sales of secondary aggregates in Devon exceeded sales of sand and gravel – according to Devon County Council’s 11th Local Aggregate Assessment, published last week.

This is not a one-off – as previous LAAs confirm. It has been the case for the last 4 years. Indeed, sales have been growing for some time. Back in 2012, sales of secondary aggregates were 24% lower than sales of sand and gravel; in 2021, they were 30% higher. 

Devon County Council commented: 

the three years sales averages for... sand and gravel remain below the ten years sales averages for the second consecutive year [whilst] sales of secondary aggregates have increased by 14% in 2021 from the previous year 

With hundreds of millions of tonnes of this waste product blighting the landscape in Devon and Cornwall, secondary aggregates are a sustainable alternative to primary virgin aggregates – the sort that will be dug up with untold damage at Straitgate Farm. 

In the LAA, the Council 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 2021 accounted for 79% of the county’s production of secondary aggregates (a reduction of approximately 20% from 2020). 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. 

3.3.5 Two new sources of secondary aggregates are included in this year’s figures, one of which is Hemerdon Mine, near Plymouth, where the current operator, Tungsten West, has expressed a clear intention to re-start the winning of tungsten and tin, and commenced commercial secondary aggregates production in February 2021 through a new company called Aggregates West. At the time of publication of this report, Aggregates West were also seeking to vary a condition on the mining consent which currently restricts the export of secondary aggregates to 50 HGVs per day. The second new site is the incinerator bottom ash (IBA) recycling facility at Hill Barton Business Park, Exeter, which was granted permission in November 2019 and became operational in February 2020. Whilst the upturn in secondary aggregates sales figures for 2021 can be partially attributed to these two new sites, it is considered that the significance of Hemerdon as a source of secondary aggregate could increase in the future if the current planning application is approved. 

Since this was written, and as we posted, Tungsten West’s plans to increase HGV movements of secondary aggregates from the Hemerdon Mine from 50 to 200 per day have been put on hold, after its planning application DCC/4314/2022 – which attracted hundreds of objections – was withdrawn. 

Meanwhile, and as we record here, the new LAA charts the fall in Devon's sand and gravel landbank from 7.6 years in 2020 to 6.5 years in 2021. This is less than the 7 years suggested by the NPPF, which allowed the Planning Inspectors to boldly claim "a shortage of sand and gravel in Devon" and thereby "great weight in favour" of permitting mineral extraction of the 1 million tonnes – a relatively minor 2 years' worth of additional landbank – at Straitgate Farm. 

Inexplicably, the Inspectors chose to ignore the 23 million tonne resource at Penslade, sitting next door to Aggregate Industries’ processing plant at Hillhead, which will provide Devon with nearly 50 years' worth of the very same material.

DCC issues 9th and 10th LAA

Devon County Council is tasked with producing an annual Local Aggregate Assessment which includes information on sand and gravel production and reserve levels. 

The Council's 8th LAA was published in May 2020. At the time, we posted DCC says correlation 'broken' between aggregate sales and housing completions. It confirmed the long-term decline in sand and gravel sales in Devon. Since then, sales of sand and gravel have fallen further – as shown here. Last month, we posted that Sales of sand and gravel in Devon were down 12.6% in 2020.

This week, the Council published its 9th and 10th LAAs for the years 2010-2019 and for 2011-2020 respectively. The LAA highlights the ongoing decline in sales: 

For the three years to 2020, the average sales were 2.439 million tonnes for crushed rock and 0.493 million tonnes for sand and gravel, both falling below the ten years average for the first time in recent years. 

There has also been a significant "reassessment" of mineral reserves during 2020. 

At the end of 2019, reserves of sand and gravel were 4.199 million tonnes, and reserves of crushed rock 95.378 million tonnes. In 2020, after sales of 0.437 million tonnes of sand and gravel and 2.289 million tonnes of crushed rock, reserves had fallen to 2.880 and 81.323 million tonnes respectively – a loss in reserves of 0.9 million tonnes and 11.8 million tonnes in excess of sales. 

How careless. The LAA says: 

This can be attributed to a reassessment of reserves by operators. 

In other words, operators had overestimated the available resource, even misrepresenting the benefit at the time of applying for planning permission – something Aggregate Industries has made a habit. 

What about more sustainable sources of aggregates? The most recent LAA tells us that "despite the pandemic, sales of secondary aggregates increased by 2% in 2020 from the previous year": 

In addition to the existing sources of secondary aggregates outlined above, [there are] other potential sources that may be available in the future. This includes secondary aggregates from the processing of waste from tungsten and tin extraction at Drakelands Mine, near Plymouth, which commenced extraction in summer 2015 but ceased in autumn 2018. A new owner is looking to recommence operations at the site shortly.

DCC says correlation ‘broken’ between aggregate sales and housing completions

Devon County Council has published its 8th Devon Local Aggregate Assessment for the years 2009-2018. It confirms figures we posted in Long term trend in sales of sand and gravel in Devon continues to decline, where we wrote:

Sales of sand and gravel in Devon declined by 10% in 2018, according to figures just released by Devon County Council – from 598,000 tonnes to 541,000 tonnes. Contrast this to the national situation where, according to the MPA, "total sales of land-won sand and gravel increased by 2.9% in 2018”.

At the end of 2018, Devon's sand and gravel reserves (material already with permission to be extracted) stood at 4.885 million tonnes – a drop over 12 months that was greater than the level of sales, after Aggregate Industries "lost" some 700k tonnes or more – as we posted in AI has lost sand and gravel reserves AGAIN, this time at Hillhead.

We also pointed out that:

It is noteworthy that the 2018 sales figure is 23% less than the finger-in-the-air projection DCC made in the 6th LAA.

DCC’s LAA is now under new authorship. What else does the report tell us?

Section 4, on "Future Aggregate Supply", has seen some changes since the last edition. We learn that "correlation between land-won aggregate sales and housing completions in Devon… has been broken", which DCC concludes "could indicate an increase in alternative methods of construction."

This was a subject we originally pointed to back in 2017, after DCC published its 6th LAA. In the post Is DCC's LAA living in LAA LAA land?, we pointed to the Council's whizzy new upwards projections for sand and gravel sales based on "housing trajectory models". At that time, DCC claimed its LAA had:

demonstrated that there is a correlation between land-won aggregate sales and housing completions in Devon over the past ten years.

We posted:

That’s hardly surprising for land-won aggregates you might think, but for sand and gravel the link appears more tenuous, given that while housing starts have bounced back from the recession, Devon’s sand and gravel sales continue to fall; given that in 2016, when housing starts hit a 9-year high, Devon's sand and gravel sales fell 14%.

DCC now concedes that correlation between housing completions and sales of land-won aggregate – which includes not only sand and gravel but crushed rock too – has become "broken":

Section 4.1 has demonstrated that there has been a correlation between land-won aggregate sales and housing completions in Devon, and that the next ten years are forecast to see significantly higher levels of house building together with other infrastructure development. However, this correlation has been broken most recently (whether this is an anomaly or new situation will established in future LAAs) and previous experience indicates that caution needs to be taken over the delivery of forecast levels of development, while 4.1.9 highlights a range of other factors that will influence demand for aggregates.

Did we learn anything else? Sales of marine aggregates in Devon apparently "declined to their lowest level in the past ten years."

The Devon Minerals Plan tells us that:

5.4.6 Small quantities of marine-dredged sand and gravel are landed at Appledore and Yelland to serve local markets in northern Devon that are remote from the land-won sources in the east of the County.

However, that's not the whole story, given that thousands of tonnes of aggregate have landed at Yelland Quay from Aggregate Industries' Glensanda quarry in Scotland.

DCC reports in this 8th LAA that:

In 2018 only a negligible amount of marine-dredged sand and gravel originating from the Bristol Channel was reported for this assessment, landed at Appledore.

More specifically, DCC reported landings of marine aggregate of 14k tonnes in 2017, and zero in 2018:

No tonnage was delivered to Appledore in 2018. Deliveries to Yelland were recorded for ‘beach nourishment’ in the report, but this use is not applicable to this assessment.

This may indeed be the case, although this 2018 tweet suggests otherwise:

We @Midhants can provide you with a new dredged marine sand from our unloading facilities in #Yelland in #NorthDevon. We currently have up to 45,000 tonnes in stock. To discuss your individual specification and needs please call a member of our sales team on 01256 861016 pic.twitter.com/NxPDRAllNq

— Mid Hants Ltd (@Midhants) July 16, 2018

And certainly in 2019, marine aggregates were being landed at Yelland again.

Sea sand is coming ashore! This is our Yelland site, supplying farmers, equestrians and construction customers across the South West #aggregates #sand #shingle #southwest #midhants #haulage pic.twitter.com/RGRwhCm9R7

— Mid Hants Ltd (@Midhants) March 5, 2019

Welsh Piper discharging lovely Bristol Channel sand at Yelland - concurrent activity! ⁦@CEMEX_UK⁩ pic.twitter.com/Taeg9AQA7O

— Paul Brown (@brownpaul65) April 18, 2019

Deo Gloria arriving at Yelland with lots of lovely Bristol Channel sand. @BoskalisWessie pic.twitter.com/0vh6PNuK9e

— Paul Brown (@brownpaul65) May 30, 2019

Aggregates delivered by sea keep trucks off roads. Last year saw aggregate from Somerset delivered by sea to Hinkley Point C, after a new jetty became operational:

EDF says each delivery keeps around 300 lorry loads off the roads and the jetty is expected to handle the equivalent of around 100,000 lorry loads over its life.

Much of it comes from Hanson UK’s Whatley quarry, near Frome, where it can be transported directly by rail to Bristol Port, before travelling the last 32 miles to Hinkley Point C by ship.

Long term trend in sales of sand and gravel in Devon continues to decline

Sales of sand and gravel in Devon declined by 10% in 2018, according to figures just released by Devon County Council – from 598,000 tonnes to 541,000 tonnes. Contrast this to the national situation where, according to the MPA, "total sales of land-won sand and gravel increased by 2.9% in 2018".

We posted about figures for 2017 and 2016 in AI’s Blackhill closing down sale distorts Devon’s S&G sales figures for 2017 and Devon sand and gravel sales down 14% in 2016. Previous figures can be found on the Devon reserves page.

At the end of 2018, Devon's sand and gravel reserves (material already with permission to be extracted) stood at 4.885 million tonnes – a drop over 12 months that was greater than the level of sales, after Aggregate Industries "lost" some 700k tonnes or more – as we posted in AI has lost sand and gravel reserves AGAIN, this time at Hillhead.

The 4.885 million tonne figure provides a landbank of 9.7 years, based on the 10 year average sales figure of 504,000 tonnes. The Devon Minerals Plan runs a further 15 years until 2033. There could therefore be a potential shortfall of 2.7 million tonnes (15x0.504 - 4.885) at the end of this period.

Two sites have been allocated in the Plan to cover any shortfall: Straitgate is identified as having up to 1.2 million tonnes – if no unquarried buffer is maintained above the maximum water table to protect water supplies; Penslade is identified as having up to 8 million tonnes. Aggregate Industries owns both sites.

Whilst Devon has more than provided for its friends in the aggregates industry to cover any potential shortfall – and even now has nearly 10 years’ supply of sand and gravel at current rates – elsewhere, whilst preparing its mineral plan in 2018, Warwickshire admitted that "falling demand for sand and gravel means it needs to provide almost two million tonnes less than its original estimate."

Because estimates can be wrong. In 1967, Devon’s planning authority was forecasting annual sales of sand and gravel of "2.11 million tons" by the year 2000. Sales are now less than a quarter of that figure.

It is noteworthy that the 2018 sales figure is 23% less than the finger-in-the-air projection DCC made in the 6th LAA – as we addressed in Is DCC's LAA living in LAA LAA land? – the so-called housing trajectory scenario "to 'stress test' the capacity of Devon’s landbanks of land-won aggregates to cope with increased sales that mirror the predicted housing trajectory over the next ten years."

Sales of sand and gravel tank in 2019

How do we know? The Mineral Products Association kindly tells us:

As demand failed to pick up again in 2019Q4, sales volumes for construction mineral products were lower in 2019 compared to 2018, falling 3.9% for ready-mixed concrete (RMC), -2.2% for aggregates, -1.7% for mortar and -0.8% for asphalt #MPAEconomics pic.twitter.com/G70WEiH5Ok

— Mineral Products Association (@MineralProduct) February 4, 2020

Is there a significant fall in sand and gravel sales here too? In Devon, we still don’t know what happened in 2018 – let alone 2019. Despite repeated requests by Devon County Council, one aggregates producer had still not supplied figures for 2018 by the first month of 2020.

The latest figures available for Devon are for 2017, contained in the Council’s 7th Local Aggregate Assessment. We have written about LAAs before. This document tells us:

1.2.3 The LAA will continue to be 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.

The MPA has some helpful advice on LAAs for its members:

...operators can assist the programme for the production of a LAA by the timely return of survey forms (see Section 9). Meeting these deadlines is important to the overall aggregate planning process, to ensure information is up to date and accurate.

Section 9? Completed survey forms should be returned to mineral planning authorities by... "the end of March", not the following year.

Without timely, accurate sales figures of sand and gravel for the last two years, you might think, therefore, that it would be difficult for "the LAA... to inform development" – particularly mineral development, particularly when it comes to, say, determination of a planning application for a brand new sand and gravel quarry in East Devon.

LAA

Two weeks ago, we posted about Local Aggregate Assessments. The LAA is a requirement of the NPPF. We pointed out that DCC’s last LAA was for the period to 31 December 2016, published July 2017.

The LAA will continue to be 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.

Readers with an interest in such matters will no doubt be relieved to learn that DCC has just published its 7th Devon Local Aggregate Assessment for the period to 31 December 2017.

LAAs

In line with NPPF requirements, DCC is tasked with producing annual Local Aggregate Assessments – which include information on sand and gravel production and reserve levels.

Whilst the Devon Minerals Plan was being prepared and examined, the LAA was regularly produced – even multiple versions in some years.

For anyone wondering, the last time the council reported on the local mineral scene was "for the period to 31 December 2016." The Minerals Plan was adopted in February 2017.

At the end of 2017, Devon's sand and gravel reserves stood at 6.23 million tonnes.

Is DCC's LAA living in LAA LAA land?

It looks like someone at DCC has too much time on their hands now the Minerals Plan has been adopted.

DCC has just issued its 6th Local Aggregate Assessment, and with it some whizzy new projections and fancy new buzzwords; buzzwords such as "stress test" and "housing trajectory". The Executive Summary spells it out:

The ability of Devon to maintain land-won aggregate supply in the event of predicted increased construction levels has been tested by modelling ten year sales average and housing trajectory models. This test indicates that the crushed rock landbank will enable supply to be maintained, but that the present sand and gravel landbank would fall below the seven years minimum during the period 2020 to 2023.

This conclusion may seem odd to some people, given that at the end of 2016 Devon had sand and gravel reserves of 7.04 million tonnes, enough to last 13.4 years (based on a rolling average of 10 years sales data as advised in the NPPF).

So how has DCC arrived at this doomsday scenario "with the landbank dropping below [the required] seven years in 2020"?

DCC starts by saying that the LAA has "demonstrated that there is a correlation between land-won aggregate sales and housing completions in Devon over the past ten years" 4.2.2.

That’s hardly surprising for land-won aggregates you might think, but for sand and gravel the link appears more tenuous, given that while housing starts have bounced back from the recession, Devon’s sand and gravel sales continue to fall; given that in 2016, when housing starts hit a 9-year high, Devon's sand and gravel sales fell 14%.

source: tradingeconomics.com

But DCC has looked in its crystal ball. It has ignored headlines such as "A recession is 'almost inevitable'...", and says "the next ten years are forecast to see significantly higher levels of house building together with other infrastructure development" 4.2.2, and thinks that:

it is feasible to ‘stress test’ the capacity of Devon’s landbanks of land-won aggregates to cope with increased sales that mirror the predicted housing trajectory over the next ten years. This test has used two scenarios whereby, for the ten years to 2026, land-won aggregate sales follow either the ten year averages given in Table 9 [sic] or the forecast housing trajectory illustrated in Figure 9. 4.2.4

The bottom line of this stress test is that "the housing trajectory scenario would see the sand and gravel landbank exhausted by the end of 2026, with the landbank dropping below seven years in 2020" 4.2.5.

Amazing. But all this should be taken with a huge pinch of reality:

For a start, DCC has mis-calculated. As shown below, even using this fantasy scenario, the landbank in years as defined by the NPPF - "reserves" divided by "10yr average" - wouldn’t fall below 7 years until 2021, even with an inconceivable quantum leap in demand.

Secondly, "the average annual predicted sand and gravel sales in the housing trajectory scenario (0.705Mt)" 4.2.8, is a staggering 51% higher than sales in 2016 - and this is the year, as previously noted, that housing starts already sit at a 9-year high.

And thirdly, even DCC recognises:

A note of caution should be attached to predictions for future rates of house building, as experience shows that these may not be realised. In 2008, the Draft Regional Spatial Strategy for the South West identified an annual average housing requirement for Devon of 6,960 for the period 2006 to 2016, which exceeds by 71% the house completions achieved over the last ten years. 4.1.4

So, given that our council tax pays for these pie in the sky forecasts, is this 'stress test' of any use at all?

Or is it just a way of trying to help a certain aggregates company justify a planning application to quarry a small greenfield site in East Devon when there’s already 13 years of permitted sand and gravel reserves?

LAA LAA LAA LAA LAA - who can keep track of the changes?

The NPPF introduced a requirement for mineral planning authorities to prepare annual Local Aggregate Assessments. By August 2016, DCC had produced its 5th Devon LAA 2006-2015. This document is currently at version 2. How many more versions there might be or when they will be issued is unknown. The LAA is obviously not a document that DCC wants the public to read or keep up with; nobody, other than the author, will be able to keep track of what changes between each version or each edition.

And changes do creep in. Take the Second Draft of the 4th Devon LAA 2005-2014 released in December 2015. This is what it said on the issue of gravel:

We posted some comments in Cozy relationships: We said

Take one look at DCC’s 4th Local Aggregates Assessment published late last year. Some of its conclusions are supported by references. When one of those references - backing the flawed argument for both 'southern' and 'northern' sites because the "proportion and size of gravel decreases from south to north" 2.5.4 - is taken from AI’s own undetermined-catalogue-of-errors planning application for Straitgate, you know you're in trouble.

We’ve already dealt with the issue of Gravel at Hillhead, and the fact that this didn’t stop Hillhead Quarry operating for decades, the fact that this doesn’t stop Hanson working Town Farm Quarry near Burlescombe, the fact that this won't stop AI from applying to quarry Penslade if its application for Straitgate founders, and the fact that this hasn't stopped DCC from relying on Penslade to cover the sand and gravel shortfall indicated in its Minerals Plan.

Indeed, one of the planning applications DCC received last year was the "variation of existing permission at Blackhill Quarry to allow for importation of sand and gravel from Houndaller (Hillhead) Quarry for processing to end of 2016 (awaiting validation)" 2.5.7.

But some people in DCC gave up listening to anybody other than the quarrying industry years ago. Consultation with the public has been a charade. In reality, Devon’s new Minerals Plan has been shaped by the minerals industry, for the minerals industry. Silly of us for thinking it could be any other way.

But how wrong we were. Some people were listening. Because by the Fourth Draft of the 4th Devon LAA 2005-2014, published shortly after our post, we find the reference to that undetermined-catalogue-of-errors planning application for Straitgate has gone, and a Table 5 inserted:

DCC is of course getting carried away with itself because, however much the Council might have prejudged matters, Straitgate Farm and Penslade are not, as Table 5 says, Pebble Bed Quarries. Furthermore, the percentage figures will still have been supplied by AI, and we know by now that numbers are not the company's strong point.

Nevertheless, the Hillhead ROMP application plainly indicates that AI is unwilling to see the Houndaller permission expire, and apparently sees merit in working the reserve - whatever DCC says about "the very low proportion of crushable gravel at Houndaller".

Cozy relationships

It might look to many - from the debacle last Wednesday - that Devon County Council’s Minerals Planning function is joined at the hip with a global cement conglomerate.

Aggregate Industries' planning applications have yet to be determined, but many of the numbers and arguments contained within them have already fallen down on scrutiny; some of these can be found in the draft Minerals Plan.

But it goes further. Take one look at DCC’s 4th Local Aggregates Assessment published late last year. Some of its conclusions are supported by references. When one of those references* - backing the flawed argument for both 'southern' and 'northern' sites because the "proportion and size of gravel decreases from south to north" 2.5.4 - is taken from AI’s own undetermined-catalogue-of-errors planning application for Straitgate, you know you're in trouble.

We’ve already dealt with the issue of Gravel at Hillhead, and the fact that this didn’t stop Hillhead Quarry operating for decades, the fact that this doesn’t stop Hanson working Town Farm Quarry near Burlescombe, the fact that this won't stop AI from applying to quarry Penslade if its application for Straitgate founders, and the fact that this hasn't stopped DCC from relying on Penslade to cover the sand and gravel shortfall indicated in its Minerals Plan.

Indeed, one of the planning applications DCC received last year was the "variation of existing permission at Blackhill Quarry to allow for importation of sand and gravel from Houndaller (Hillhead) Quarry for processing to end of 2016 (awaiting validation)" 2.5.7.

But some people in DCC gave up listening to anybody other than the quarrying industry years ago. Consultation with the public has been a charade. In reality, Devon’s new Minerals Plan has been shaped by the minerals industry, for the minerals industry. Silly of us for thinking it could be any other way.

*SLR Consulting Ltd (2015) Proposed Extraction of Sand & Gravel at Straitgate Farm, Devon and Retention of Quarry Processing Plant at Blackhill Quarry, Woodbury, Devon: Environmental Statement Volume 2. Sheffield: SLR.

Revised landbank

The last figures published by DCC showed that Devon had sand and gravel reserves of 8.535 million tonnes, which included a small reserve on the Somerset side of the Devon/Somerset border. DCC’s Minerals Officer has now advised that:

I’ve just heard from Somerset County Council that they now regard the planning permission for this reserve to have lapsed. The reserve in Somerset should therefore no longer be included, and the correct sand and gravel reserve figure (at the end of 2013) is 8.135 million tonnes. We’ll be using this amended figure for the purposes of the emerging Minerals Plan.

In other words, Devon still has 10 years more than the 7 required.

Mineral industry prefers 'simple' sums

DCC published its 3rd Local Aggregate Assessment shortly before Christmas. This is an annual document required by the NPPF "to provide a rolling evidence base to inform the approach to be taken in the Local Plans of the individual Mineral Planning Authorities to the supply of aggregates".

This LAA puts Devon's permitted reserves of land-won sand and gravel at the end of 2013 at 8.53 million tonnes, adjusted upwards from 8.14 million tonnes (to include a small reserve located in Somerset) giving a landbank of 13.8 years - using the ten year average sales of 0.62 million tonnes per year.

Changes are made to the LAA each year, changes that are not helpfully highlighted or contained in a table of modifications at the start of the document, changes that are not merely of a factual nature, changes that are not debated or ratified by councillors. One such change this year is how that figure of 13.8 years is calculated, more specifically how the ten year average of 0.62 million tonnes is calculated. The draft for the first LAA was put out for consultation beyond the mineral industry and other mineral planning authorities; subsequent LAAs were not. The consultation for the first LAA asked:

Do you support the use of weighted 10 year averages as a more responsive indicator than a simple 10 year average of sales data?

We answered "Yes" - the use of a weighted average was, after all, our suggestion.

A weighted average produces a more relevant, more responsive landbank figure by giving less weighting to out of date figures, more weighting to recent figures; for the last 5 years, sand and gravel usage has been less than half a million tonnes per annum, 10 years ago it was almost double that. Of course, the minerals industry, in the form of Devon Stone Federation et al., disliked the move to a more meaningful number, and said "No". To its credit, DCC stuck with the new calculation in its first and second LAA.

However, DCC has now reverted back to the simple average following discussions with the South West Aggregates Working Party, a group of minerals industry and planning representatives, but without any wider consultation; the Devon Stone Federation for one "is very pleased to see that the weighted average has been dropped". "Pleased"? Because the weighted average would indicate a landbank of sand and gravel in Devon of 15.8 years; the NPPF looks for at least seven years.

But the Devon Stone Federation and others may be less pleased in the future if sand and gravel sales take off, and the landbank remains stubbornly high by relying on the unweighted inclusion of low and outdated data; a weighted average would have highlighted resource shortages sooner.

Somerset

Somerset’s Minerals Plan is at a much more advanced stage than Devon’s - after DCC’s prolonged wait for Aggregate Industries to prove the viability of Straitgate Farm. Somerset’s Plan was examined in September, and a list of modifications is now out for consultation from 5 November to 17 December.

Somerset has limited resources of sand and gravel, but is a significant producer of crushed rock. This meets some of its demand for sand and gravel, but otherwise Somerset is supplied by quarries in Dorset, Devon and elsewhere. Of the 378k tonnes of sand and gravel that Somerset 'imported' in 2009, 65% came from Dorset (mainly AI’s Chard Junction Quarry on the Dorset/Somerset border) and, if the numbers are to be believed, less than 10% came from Devon (mainly from Hanson’s Town Farm Quarry at Burlescombe, on the Devon/Somerset border, which produces around 170k tonnes pa) [SCC LAA 2013]. In 2009, Devon 'imported' 93k tonnes of sand and gravel from elsewhere; 'much is likely to have originated' from AI's Chard Junction Quarry [DCC LAA 6.4], which produces around 160k tonnes pa.

SCC LAA 2013

What worries Somerset, and plainly the Planning Inspector, is what happens when these quarries finish:

Somerset County Council is mindful that reserves at the Town Farm site in Devon are expected to run until the early 2020s and that the planning permission at Chard Junction expires in 2023 [SCC Statement Sep'14 5.3]

There is a potential resource of around 400k tonnes near Hanson's plant at Whiteball, near Wellington:

Extraction at Whiteball may be proposed on the Somerset side of the border during the next 10 years, moving from extraction on the Devon side of the border. Whilst this is unlikely to change Somerset’s approach towards sand and gravel policy, it will alter the import/export figures, leading to Somerset exporting to local markets in Devon. [SCC LAA 3.10]

But following public examination, SCC has been prompted to add a new paragraph, 6.78:

Somerset County Council encourages proposals to come forward for sand and gravel extraction that are in accordance with relevant policies in the Development Plan and contribute to sub-regional supply. Informed by updates to the Somerset Local Aggregate Assessment, the need for new sources of sand and gravel is anticipated to become more pressing in the early 2020s, notwithstanding there may be benefits of proposals coming forward more quickly. [SCC Statement Sep’14]

If Somerset is now looking for sand and gravel supplies from within its own borders, does this reduce how much Devon needs to allocate in its new Plan? Probably not. SCC said:

It would be premature for the Plan to allocate sites for sand & gravel at this stage, noting the lack of interest from industry in sites for sand and gravel extraction in Somerset (except for interest in the continuation of Whiteball operations) and the lack of information on available resources other than those around the Whiteball operations. [SCC Statement Sep'14 6.9]

And DCC has already recognised the issue. In its latest LAA:

...during the later part of the period to 2031 covered by the LAA, some of the sand and gravel supply previously delivered from Devon will be met from Somerset through continued working at Whiteball. [3.25] However, this supply from Somerset will be offset by the likely cessation of supply of sand and gravel from Dorset, as Chard Junction Quarry, located close to the boundary with Devon and supplying materials into the east of the county, is anticipated to cease working in 2022/23. [3.26]

From a strategic point of view, this likely cessation of supply of sand and gravel from Dorset into the east of the county is probably another reason why Straitgate is so important to AI.

‘Moving Mountains to build a Greener London’

Runs a press release headline. The mountains referred to are in Cornwall. They consist of china clay mining waste - secondary aggregates, an effective replacement for primary or virgin sand & gravel. Six hundred million tonnes are piled up all over Devon and Cornwall; 40Mt more are created every year.

The subject of Secondary vs. Primary was discussed here over a year ago. We pointed out that china clay secondary aggregates were being used in major London building projects, including the Olympic Park, and that, according to Aggregate Industries, secondary aggregates are a "substitute for primary aggregates in the vast majority of cases”.

We asked that "if the economics can work supplying London, why not Devon?"

We also pointed out that Imerys, with existing contracts coming to an end, was "actively developing the growth of their secondary aggregates (china clay waste) products from Cornwall” and was "seeking partners to realise the full potential of the materials in the markets they serve”.

Last week it was announced that AI - having processed Cornish china clay waste for 40 years - lost the Imerys supply contract to S Walsh, an Essex based company, who will ship it for use in the South East. The implication is that AI could not, or would not, realise the full potential of this waste material. Forty people now stand to lose their jobs at two AI sites in Cornwall.

Here’s what S Walsh had to say:

S Walsh recognises the growing demand for “green” construction materials and sees this agreement as the catalyst for realising the potential of this material in the market... We have undertaken extensive research and know that these products can be used more widely for infrastructure, residential, commercial, education & health construction projects.

Secondary Aggregate from china clay waste meets the requirements of sustainable building in the UK. There is a huge lack of understanding of availability and potential for this ‘secondary’ resource and we expect that through our commercial relationships we can share what the possibilities are.

Products sourced from S Walsh can be used to produce high specification construction products such as asphalt, ready-mix concrete and various concrete products such as blocks, kerbs, flags, bricks and precast products such as tunnel segments, constituting up to 100% secondary aggregates.

Until recently, and until lobbying by mineral trade bodies, china clay secondary aggregate was free from the £2/tonne Aggregates Levy - a government incentive to encourage its use. The EU is looking into whether this exemption constitutes illegal state aid, and it has been temporarily suspended. Apparently, however, the EU has been fed "some odd and biased information about what is and what is not secondary aggregates” and representations have been made by government and by members of the House of Lords to maintain the exemption to promote secondary aggregates use. Hundreds of jobs in Cornwall are at risk. It seems odd therefore that this temporary suspension of the Aggregates Levy was played upon by DCC in its most recent LAA:

the removal of the Aggregates Levy exemptions for secondary aggregates introduces significant uncertainty into the prediction of future requirements for land-won aggregates

DCC is the biggest customer for local aggregates. Does it have an inbuilt bias against secondary material? Many people new to the world of minerals planning will be dumbfounded to learn that the council is looking at new virgin primary aggregate sites when it already has a ready source - hundreds of millions of tonnes of waste blighting the landscape.

So why is Devon not demanding that more be made of this material, before assigning new green field sites? DCC writes a Minerals Plan not to make life easier for multinational aggregates conglomerates, but for the good of the County and its inhabitants as a whole. Secondary aggregates are a waste product - a sustainable product - a ‘greener' product; what more could be done to promote its use? Since secondary aggregates can replace primary in the “vast majority” of cases according to AI, “up to 100%” according to S Walsh, it could be argued that some of the millions of tonnes available should be added to the primary sand & gravel landbank - to extend the time before new sites are called upon. That might focus some minds. Few other counties have such large secondary aggregates supply - Devon could be argued to be a special case. After all, what's the sand & gravel shortfall DCC is looking to cover in its plan to 2031? 1.6Mt How much secondary aggregate is there again? 600Mt By tackling this issue, DCC's Minerals Plan really would leave a lasting positive impact on the County. The industry would kick and scream - but hey, they shouldn't leave the landscape in such a mess.

So we ask exactly the same question that we asked over a year ago: "if the economics can work supplying London, why not Devon?”

DCC publishes 2nd Local Aggregate Assessment 2003-2012

DCC has just released its 2nd Local Aggregate Assessment; a requirement of the NPPF "to provide a rolling evidence base to inform the approach to be taken in the Local Plans of the individual Mineral Planning Authorities to the supply of aggregates”.

Despite protestations from the minerals industry, through the South West Aggregate Working Party and Devon Stone Federation, the weighted 10 year moving average to calculate future landbank requirements has been maintained.

The status of permitted sand and gravel sites in Devon, table 3.6, has been updated: 

Blackhill, Woodbury: Extraction of remaining reserves was completed in 2011. Plant is retained for processing materials transported from two other sites until December 2016 

Hillhead, Uffculme: No extraction undertaken since 2009, although small quantities have been sold from stockpiles. Renewed extraction of sand and gravel at Houndaller is being considered for 2014.

DCC points out that "the removal of the Aggregates Levy exemptions for secondary aggregates introduces significant uncertainty into the prediction of future requirements for land-won aggregates".

Devon's sand and gravel production figures for 2012

Figures provided by DCC show that Devon's sand and gravel demand continued to flatline in 2012, with just 0.49 million tonnes produced - only 50,000 tonnes more than 2011, despite heightened construction activity at Cranbrook and the Exeter Science Park. Last year was the fourth consecutive year where production was less than 0.5Mt - about half the figure required a decade earlier. However, the county's sand and gravel reserves - resource with planning permission for extraction - fell by 0.87Mt to 8.29Mt - a drop of 0.38Mt more than the level of production - as operators reassessed reserve levels at a number of quarries. Whenever reassessments of reserves are undertaken by operators, invariably the net result is down rather than up, as operators over-promise and under-deliver; something local people should be mindful of when revised resource figures are presented by Aggregate Industries for Straitgate Farm.

Despite the reserves reassessment, the 10 year weighted moving average detailed in DCC's Local Aggregate Assessment still gives Devon a sand and gravel landbank of 14.5 years - double that required by the NPPF. That's not something AI cares about. It thinks Devon needs another quarry, and no doubt expects to get its way - fully aware of the helpful guidance in the Government's new Managed Aggregate Supply System, which says that the size of a county's landbank should play no part in deciding a planning permission. Completely the reverse of housing then, where a 5 year supply of ‘deliverable’ housing is certainly - and some would say the only - material consideration in determining planning applications. MASS may stand for managed aggregate supply system but means something altogether more muddled, inconsistent, irrational, and unsustainable. In other words, all the signs of mineral industry lobbying.

Landbanks - government guidance says they don't matter any more

At least when it comes to deciding if a new quarry should be permitted. Which is bad news for anybody looking to Devon's 15 year landbank of sand and gravel as a reason for denying Aggregate Industries permission to quarry Straitgate Farm.

The Government published Guidance on the Managed Aggregate Supply System in October 2012, and such advice was apparently considered when DCC prepared its LAA. However, the LAA did not allude to what surely every mineral operator will latch on to, and what was relied upon by AI in its submission to the Competition Commission (CC) released earlier this year, namely:

Moreover, as the CC notes, the new planning guidance issued by the Department for Communities and Local Government states that adequate landbanks should not be used as a reason for declining a planning application. (5.14)

Which goes some way to explaining why AI is merrily proceeding with Straitgate, despite the county having 8 years' supply of sand and gravel over and above what's required by the NPPF, and despite what DCC said as recently as 2011:

For as long as adequate sand and gravel reserves (i.e. a minimum of seven years’ supply) continue to be present at the existing quarries, there are no grounds to allow their further extension or new quarries. (5.1.4)

AI plainly couldn't care how DCC's landbank is calculated - weighted ten year average or otherwise. To AI it's irrelevant, since government guidance clearly states:

each application for minerals extraction must be considered on its own merits, regardless of the length of the landbank… an adequate or excess landbank is not a reason for withholding planning permission unless there are other planning objections which are not outweighed by planning benefits. (25,26)

Yes, such advice is but one of a number of material considerations by which a planning application would need to be judged, but government planning policy would tend be relied upon by the legal might of an aggregates giant. Straitgate would therefore have to be assessed on its "own merits" if AI were to advance an application, in which case there are a number of other substantive planning objections, as this blog has attempted to highlight.

DCC finalises 1st Local Aggregate Assessment

DCC has published the final version of its first LAA, following consultation with various parties. As a requirement of the NPPF, "the LAA will be published annually to inform development and monitoring of Local Plans, including recent sales and revisions to levels of reserves and the length of landbanks".

The NPPF specifies a sand and gravel landbank of at least 7 years "based on a rolling average of 10 years sales data and other relevant local information". Since Devon's 10 year average is significantly above current production, DCC has adopted in its LAA a 10 year rolling average weighted more towards recent data (A.18), and is the only council to have used such an approach. Devon Stone Federation, representing Aggregate Industries and others, did not support the move.

A new paragraph (5.18) added to the final version of the LAA states that the Pebble Beds (PBs) - measuring an "effective" PSV of 60-64 - are now approved for high friction road surfacing "reducing Devon's reliance on gritstone imported from elsewhere in the UK". This is at odds with the Jacobs report, commissioned by DCC, which recognises (4.3.2) the use of the PBs for roadstone, but "with a PSV in the mid 50s, it is suitable for general use, but not for high-specification applications". Neither were the PBs identified for such use in DCC's Technical Report. In fact for Straitgate the PSV is recorded as 53 (P.7). Whatever has changed, the amounts in question should be relatively small.

DCC did acknowledge in one response that "while an economic recovery is likely to lead to increased construction activity, increasing emphasis on sustainable construction may see increased use of materials other than aggregates, together with use of alternatives to land-won aggregates", which is welcome after so many people raised the same issue during the consultation.

Fly ash - adding it to cement and china clay waste could save the Pebble Beds

Fintan264

The Devon Stone Federation advised DCC, Local Aggregate Assessment (LAA, 5.15), that as an alternative to the "qualities of the Pebble Beds resource" china clay waste has a number of issues including "increased water demand and proportion of cement required in concrete". However, as posted earlier, this did not stop china clay waste being used in the construction of the Olympic Park or One Coleman Street in London.

What the Devon Stone Federation, whose five quarrying members include AI, failed to mention was that any extra cement required can be offset cost effectively with 'fly ash'. Fly ash was not referred to in DCC's otherwise comprehensive LAA, yet it "has been in common use as a cementitious component in concrete in the UK for several decades". The construction of One Coleman Street used "30-40% fly ash in place of Portland cement" to reduce its environmental impact.

Fly ash is a residue from coal-fired power stations. Worldwide, more than 65% of fly ash produced from power stations is disposed of in landfills and ash ponds. However, "as a very fine, inert and lightweight material, fly ash is ideal when used in the concrete mix as a substitute for cement". "As well as reducing the amount of water required in the mixture, fly ash can limit demand for natural resources. Studies conducted by the UKQAA and partnership bodies have shown that fly ash can be included in the concrete mix at rates of up to 80% of the cement content, significantly reducing the need for both natural aggregates and water, while reducing the concrete’s carbon footprint. While [each tonne of] cement creates approximately one tonne of carbon in the manufacturing process and contains 913kg/tonne of embodied carbon, fly ash contains 4kg/tonne".

Cement production worldwide "produces more than 5% of mankind's carbon dioxide emissions" - more than the entire aviation industry; using fly ash at Coleman Street alone saved 500 tonnes of CO2. AI itself does not produce cement, it sources it from UK producers and a Holcim plant overseas. AI does however supply fly ash, and it is used in 25% of Holcim's cement output.

So, DCC should recognise (at least for concrete applications, which is where two thirds of sand and gravel end up) that with the help of cement additives there are sustainable, environmental, economic and viable alternatives to the Pebble Beds piled up all across Cornwall and Devon, that should be used before plundering more virgin resource. It may not be in the Devon Stone Federation's interests to promote the use of waste china clay aggregates, but surely it must be in the interest of the county, its people and the environment, and this should be reflected in Devon's mineral policies.