Straitgate’s ‘revolutionary’ working scheme not being deployed at Penslade

Holcim UK (formerly Aggregate Industries) doesn’t intend to deploy Straitgate’s "revolutionary" working scheme at Penslade. 

For a scheme that allows more material to be recovered, isn’t that funny? How many aggregate companies would forgo another metre's depth of material given half a chance? 

For the company’s new application for Penslade – where there are few people nearby wholly reliant on private water supplies: 

4.1.3 The base of mineral extraction has been set at 1m above maximum recorded groundwater levels. 

One metre. It’s as clear and simple as that, and the Environment Agency has already said it has no objection to the application. 

Oh, what a different story it has been for Straitgate Farm, where for 12 months back in 2015 the company wouldn’t even come clean that the base of mineral extraction has been set at 0m above maximum recorded groundwater levels – or at least an imprecise model of them – and that a "revolutionary" seasonal working scheme is to be deployed: As we posted at the time: 

AI's seasonal working scheme has now been described as "revolutionary"; not by us, but by someone on the other side closely connected to all this. 

How exciting! Local people will be thrilled. Thrilled at the prospect of being part of an experiment, where their drinking water supplies are reliant on the success of this "revolutionary" scheme; a scheme that relies on groundwater levels falling over the summer months to allow AI to quarry down to the maximum water table level, rather than leaving the 1m unquarried buffer above the maximum water table typically employed to safeguard surrounding water supplies.

So, a 1m buffer is to be retained at Penslade to protect the water environment, whilst a 0m buffer is to be retained at Straitgate – where there are more than 100 people reliant on private water supplies, as well as farms and businesses. 

No, it doesn’t make any sense to us either. 

It’s a story we won’t dredge up again, although it has been covered in these posts from 2015 to 2018 for anybody at all interested: 

Clarification from the EA 

How many AI suits does it take to have a meeting with the EA? 

Finally, in writing, how AI thinks it can wrestle 1.2 million tonnes from Straitgate 

AI was asked a very simple question

No wonder AI wants to keep Straitgate’s groundwater data secret

 

Aggregate Industries submits planning application to extend Hillhead Quarry

Aggregate Industries has submitted a new planning application to quarry sand and gravel in Devon – despite not yet implementing its permitted plans to quarry Straitgate Farm, and despite complaining that current economic conditions mean its plans for Straitgate may need to be mothballed. 

Today, Devon County Council validated the company’s application to quarry land south west of Penslade Cross, DCC/4424/2025, an extension to its quarry at Hillhead near Uffculme, that is expected to yield 3.9 million tonnes of saleable sand and gravel over a 13-year period: 

Proposed extension of Hillhead quarry for the winning and working of sand and gravel with restoration using imported inert fill, inclusive of a new internal haul road and the retention of the existing mineral processing facilities

The land is owned by Aggregate Industries, and has the same type of material that underlies Straitgate. In total, there are thought to be some 23 million tonnes at Penslade, 8 million tonnes of which are allocated in the Devon Minerals Plan. The site sits a short distance from the company's processing plant. 

Aggregate Industries’ planning application for Penslade has been expected for some time. In 2021, the company was granted permission to drill boreholes around Penslade to monitor the watertable. At the Straitgate appeal, it became clear that the company had told Devon County Council that an application would be submitted in 2023. However, only in September 2024 did the company issue a newsletter inviting locals to a drop-in event the following month to publicise its plans.

 

In this newsletter, the company reminded us – despite having won permission to quarry Straitgate – that: 

Hillhead Quarry is the main source of sand and gravel in Devon and is Aggregate Industries’ only sand and gravel quarry in the south west.

The proposed Hillhead extension is identified as a minerals allocation in the Devon Minerals Plan as the replacement resource for the existing Hillhead sand and gravel quarry, which on current production rates has permitted reserves until c. 2028/9. We are starting the planning process for our Hillhead extension now in order to allow sufficient time to enable an orderly and planned transition of mineral working to the new extension area to take place in c.2028/9. 

Clearly any material won from Straitgate in the intervening period – which is only permitted to be processed at Hillhead – does not figure in those timescales. Earlier this year, the company won permission for another 460,000 tonnes of sand and gravel at Hillhead, which will see it through until this new application is decided. 

Ever since Aggregate Industries moved its sand and gravel processing operation to Hillhead back in 2018 – after it was forced to move its operations away from Blackhill on Woodbury Common, part of the East Devon Pebblebed Heaths in the East Devon AONB – it has made economic and environmental sense to source raw material closer to the processing plant. It made no sense to source material from Straitgate, 23 miles away. Given we have a new application for Penslade, alongside the as yet unimplemented permission for Straitgate, perhaps the penny has finally dropped. 

At the Public Inquiry deciding the fate of Straitgate – with its barely 1 million tonnes – the Planning Inspectors chose to ignore the 23 million tonnes of sand and gravel sitting at Penslade, arguing there was "a shortage of sand and gravel in Devon", and writing: 

82. Although development of the allocated site west of Penslade Cross would contribute significantly to supply, there is no immediate prospect of this coming forward, and our decision must be based on the current situation with respect to sand and gravel supply.  

137. We have already noted that there is little prospect of the allocated site at west of Penslade Cross coming forward in the near future. Therefore, any advantage that that site would have over the appeal site in terms of its proximity to Hillhead Quarry is not material to our decision.

Even Aggregate Industries chose to forget there was any gravel in the fields around Hillhead, when it was trying to win permission for Straitgate. At the time, we posted AI’s greenwash document assumes no gravel at Hillhead, not 25%, not 5%, not any!

And yet, just two years on, a planning application for Penslade has indeed come forward – as we all knew it would – which is expected to provide enough material for years to come. 

So, clearly, there is no shortage of sand and gravel in Devon, and – as we have argued for the last two decades – zero need for mineral from Straitgate Farm.

Aggregate Industries had extra 460k tonnes of sand & gravel up its sleeve all along

At the Public Inquiry in October 2022, Aggregate Industries pointed to the less-than-7-year landbank for sand and gravel in Devon, and claimed there was therefore an "urgent" need for a quarry at Straitgate Farm. As a result, in weighing up the planning balance, the Planning Inspectors concluded there were: 

154. ... significant material considerations which weigh in favour of the proposal. These include its contribution to sand and gravel supply in Devon in circumstances where there is not currently a 7-year landbank as required by the Framework. 

Ten months before, in December 2021, at the time Aggregate Industries’ application to quarry the farm was refused by Devon County Council, the landbank was actually above 7 years, according to a subsequent revision by the Council. However, by the time of the Public Inquiry, the landbank had indeed dropped to 6.4 years, based on permitted reserves of sand and gravel in the County at the end of 2021 of 3.317 million tonnes, divided by the 10-year sales average of 0.514 million tonnes per annum. 

But, surprise, surprise. It now turns out that, at the time of the appeal, and unbeknown to the Planning Inspectors, Aggregate Industries had another 460,000 tonnes of sand and gravel up its sleeve, which, once permitted, would have pushed the landbank to over 7 years. 

Aggregate Industries has recently lodged a planning application with Devon County Council for Hillhead Quarry near Uffculme – DCC/4399/2024 "Variation of conditions 2, 4, 6, 7, 12, 19, 22 and 25 of ROMP permission DCC/3655/2014... to vary the phasing; landform; drainage; and restoration of the site." 

This application is concerned with modifications to the Houndaller part of the site – a site with the same sort of material that underlies Straitgate Farm – that has suffered from ponding problems, as we have posted about here, here and here.

The Planning Statement for the application reads: 

3.4.1 Houndaller Extension Area is currently facing surface water ponding issues in Phase 6 which is preventing completion of restoration of this section of the quarry. It is considered that a similar situation will occur once extraction operations cease in Phase 7. During 2023 and to date in 2024, in excess of 1m dept [sic] of water has collected over much of the Phase 6 area. The consented final restoration landform does not allow for effective drainage. Therefore, Aggregate Industries are proposing a long-term solution for surface water ponding issues on site. 

Clearly, the concern must be that if the company hasn’t been able to adequately manage surface water at Houndaller, it doesn’t stand much chance of complying with the no water bodies condition at Straitgate: 

25. No water body shall be created within the site other than the approved weigh bridge lagoon.   

However, the company’s application for Houndaller is not just concerned with surface water management. The application’s Non-Technical Summary says: 

1.1.6 The proposed modifications to mineral operations at Houndaller include removal of two unsafe historic faces which will provide an estimated 460,000 tonnes of permitted reserves to Devon’s sand and gravel landbank. 

1.4.10 In addition, at present the approved plans under the extant consent contradict each other, with the approved restoration plan (ref. 2285/ROMP/4C) not showing the ridge along the northern boundary of phase 8, but it is in-situ on the working plans (ref. 2285/ROMP/3C & 2285/ROMP/73D) thereby creating an anomaly. Therefore, at present the approved restoration scheme cannot be delivered as currently consented. 

A spare 460k tonnes? Unsafe quarry faces? Approved plans that contradict each other? How has Aggregate Industries allowed all this to happen? 

But could it be that these perilous quarry faces were not known about at the time of the 2022 appeal? Not unless Aggregate Industries has been asleep for 20 years. The application’s Planning Statement points to The Quarries Regulations of 1999 and says: 

3.2.6 It is proposed to remove the ridge escarpment which lies adjacent to the eastern edge of Houndaller Plantation Pond which is in the northern part of Houndaller Extension Area and former Phase 1 area. 

3.2.7 The former Houndaller Phase 1 extraction area, north of the current Phase 8, had been worked pre-Quarry Regulations 1999 when long-term geotechnical stability of the final quarry faces when excavating sand and gravel material was not given the consideration which is now required for quarry legislative purposes. Whilst this area is now restored, the historical faces are currently up to 20m high and 65˚ to near-vertical therefore presenting both a stability, and health and safety issue. 

3.2.8 Hillhead Quarry is now subject to a Regulation 33 geotechnical assessment every two years. Within this assessment, there are various design criteria that the quarry must use to ensure geotechnical stability for both active and inactive faces. These design criteria’s are derived from the specific geotechnical properties of the geology onsite and from various stability analyses undertaken alongside the assessment. 

3.2.9 Based on the current design criteria for restoration slopes, the historic faces adjacent to the eastern edge of Houndaller Plantation Pond and along the northern boundary of the current approved Phase 8 extraction area have been assessed and are considered to be excessively steep and too high for long- term stability. They therefore currently present a significant geo-technical risk, and health and safety hazard. The current Regulation 33 Geotechnical Assessment for the site states that "Aggregate Industries must develop a plan to include remedial actions on these historic quarry faces". Further detail on the stability issues are presented within the Stability Assessment accompanying this planning application at Appendix 6.2.

The company would therefore have known for years that these hazardous quarry faces did not comply with the 1999 regulations, and that removing them would likely yield extra material. 

But perhaps it forgot all about them at the time of the Straitgate appeal in October 2022? This isn’t likely either. The Stability Assessment referenced in Appendix 6.2 says: 

1.3 ...It was identified in 2022 that the restoration plan needed to be updated to include improved drainage and to update the final profiles in relation to the materials available for backfilling the extraction area. At this point it was a natural way to deal with this legacy face to ensure the whole Houndaller excavation area is left in an adequate way that it supports long term stability and no hazards remain when Aggregate Industries complete this area.

So, how very clever of Aggregate Industries to keep all this material – about half the quantity available at Straitgate – up its sleeve. 

Prior to the determination of its Straitgate Farm application, Aggregate Industries had been in the habit of losing material – including at Houndaller – which had the inevitable effect of reducing the landbank and creating the impression of need for Straitgate. Miraculously, after Straitgate is determined, we now discover the company has found material again. How convenient. How cunning. 

What does this application for Hillhead mean for the County’s sand and gravel supplies: 

3.2.16 The current estimate completion date for extraction [at Houndaller] is end of 2029 with completion of restoration and landscaping by 2031, this is based on an average production rate of 350,000 tonnes per annum. 

Assuming production for the years 2024,25,26,27,28,29 this implies that some 2.1 million tonnes remain, or 1.64 million tonnes excluding the newly found 460,000 tonnes. Aggregate Industries helpfully confirmed in 2019: 

The company's reserves schedule for Houndaller was subsequently revised to 2.9 million tonnes as at 1st January 2019.

Subtracting those two figures implies that over the 5 years 2019,20,21,22,23, some 1.26 million tonnes of sand and gravel has been produced, at a rate of 250,000 tonnes per annum. 

At this rate, Houndaller would in fact last another 8 years. 

Of course, this is why Aggregate Industries – knowing all along it had extra material at Hillhead – has been in no rush to advance its plans for Penslade, despite starting groundwater monitoring in 2021. 

Penslade is owned by Aggregate Industries, and again has the same type of material that underlies Straitgate. Whilst Aggregate Industries claims there is 1.06 million tonnes of saleable aggregate at Straitgate, Penslade is a 23 million tonne sand and gravel resource, 8 million of which is allocated in the Devon Minerals Plan. It sits next to the company's processing plant, not – like Straitgate – 23 miles away. At the appeal, the Council’s Mineral Planning Authority said: 

5.1.13 The Appellant has stated at meetings of the local liaison group for Hillhead Quarry that it is preparing a planning application for their West of Penslade Cross site (to the east of Hillhead Quarry), having undertaken investigative boreholes and intending to seek pre-application advice from the Council before the end of 2022, with a view to submission of an application in 2023. It is also understood that remaining reserves at Hillhead Quarry are sufficient to maintain supply until a new quarry at Penslade has been approved and is capable of being implemented. 

However, to date, no planning application for Penslade has arrived. All Aggregate Industries would say at the appeal was: 

8.4 Aside from the appeal site, the only other allocated site is West Penslade. West Penslade is also AI controlled which [sic] and would be an extension for the Hillhead quarry (planning permission ends in 2028). West Penslade will not come online until then. 

The bottom line is that Straitgate is not quite so urgent after all. 

Furthermore, as we posted last month, Aggregate Industries now says that if current market conditions persist then Straitgate will have to be "mothballed". Local people will wonder what strategic thinking goes on at Aggregate Industries, if any. 

What else does DCC/4399/2024 tell us? In relation to groundwater and nearby water users: 

5.7.3 Throughout the lifetime of the development, some 2 m thickness of unsaturated material will be retained beneath the quarry floor at the western margin of the Houndaller Extension. 

Compare and contrast that with extraction all the way down to the maximum water table at Straitgate, a site with more than 10 times the number of nearby private water supplies at risk than at Houndaller. Even so, Aggregate Industries again recognises that private supplies will be put at risk:

5.7.14 In the unlikely event that a supply is shown to have been impacted by quarry-related drawdown, the following approach is proposed to provide mitigation… The fallback position would be the provision of mains water. AIUK would cover the costs for mains water connection and usage at any property where the water supply is affected by the quarry development. 

What ecological damage will be done in removing those treacherous quarry faces? 

3.5.3 As part of the remedial works for the two unstable ridges within the northern extent of Houndaller, approximately 28,863m2 of lowland mixed deciduous woodland is required to be removed.

 

Which rather undoes this PR piece pushed out by Aggregate Industries last year, congratulating itself for planting saplings at Hillhead. 

Devon County Council is accepting comments on DCC/4399/2024 until 29/06/2024.

AI’s response to the multitude of objections is frankly farcical

What an utter farce.

 

Aggregate Industries has today submitted a response to all the outstanding issues connected with its planning application to quarry Straitgate Farm in the form of a brief letter. 

The letter again contains the word final. On 5 March 2021, Aggregate Industries wrote to Devon County Council saying "Please find attached our final submission of additional information...". On 7 April 2021, "Please find attached our final submission of additional information...". And today, "Further to our March 2021 submission of additional information I am now writing to provide our final response to the queries raised as part of the consultation." Perhaps the company is now as keen as the rest of us to see an end to this ridiculous scheme!

However, the letter – written by the company’s planning manager, not by the relevant experts – utterly fails to address the majority of concerns that have been raised – including from the statutory consultees Natural England and the County Council's Flood Risk Management Team. 

We’ll hold our response for another day, save for one point: the Greenwash Report. On "Why Penslade was not included as an option in the Greenhouse Gas report", Aggregate Industries answered "The gravels that do occur at Penslade do not have the same high psv properties that occur at Straitgate". Clearly – with a resource of 23 million tonnes at Penslade – that must be disappointing for Aggregate Industries. But the statement is at odds with the Council’s Local Aggregates Assessment.

These figures show Straitgate’s 1 million tonnes x 26% = 260k tonnes of crushable gravel, and Penslade’s 23 million tonnes x 13% = 3 million tonnes. In other words, Penslade would have more than ten times the amount available at Straitgate. Not quite so disappointing after all.

Also today, an extra document has been supplied by Wood, Aggregate Industries’ water consultants, following this meeting. However, it's immediately apparent that the document is incorrect. It claims: 

With respect to Professor Brassington’s comments regarding the photographs of trial pits, these trial pits were not 6 -7 m deep as he reports. 

But Wood is wrong. Again. Clearly some of the pits shown in the 2017 Reg22 document (below, on the right) are identical to those we photographed in 2012 (below, on the left). These test pits – which had to be deep enough to yield pebble bed material for analysis – were 6-7m deep, as we posted at the time. Perhaps Wood would like to apologise?

 

AI to drill boreholes at Penslade for ‘monitoring of the watertable’

Last week, Aggregate Industries was granted permission, DCC/4235/2021, to drill nine boreholes at Penslade, a site adjacent to Hillhead near Uffculme, that – like Straitgate Farm – is designated a Preferred Area for sand and gravel extraction in the Devon Minerals Plan, but – unlike Straitgate Farm – has 8 million tonnes and is 23 miles closer to the company's processing plant. 

In fact, where Straitgate would yield less than 1 million tonnes of material – if the company ever works out how to design effective infiltration areas – the area around Penslade Farm would give Aggregate Industries access to some 23 million tonnes – more than 70 years' worth based on sales of 300k tonnes per year. The statement below, from the Minerals Plan, hardly needed saying:

Policy M12 proposes two new locations for mineral working... In the event that Straitgate Farm proved to be incapable of being delivered, then the other site, West of Penslade Cross, would have adequate resources to enable sand and gravel supply to be maintained for the Plan period.

Most of this area is owned by Aggregate Industries. In relation to the boreholes, the company says: 

The boreholes will be between 23m and 38m in depth and piezometers will be installed to enable the monitoring of the watertable as required by the Devon Minerals Local Plan.

The Minerals Plan specifies "groundwater monitoring for a minimum 12 month period." 

This has been in the pipeline some time. In 2017, we posted Plans to install piezometers at Penslade: 

at a meeting last week, AI's Head of Geological Services confirmed that budgets are now in place to install piezometers at Penslade… 

You might ask, however, why these plans were only submitted in the middle of a consultation to quarry Straitgate Farm, a proposal that would see minerals worked "over a period of between 10 and 12 years" and would not start until 2023? Was it coincidence, or did Aggregate Industries sense things going pear-shaped with the Straitgate application again? 

In 2017, on being questioned about Penslade by Devon County Council, Aggregate Industries reckoned: 

It is envisaged that groundwater monitoring will be undertaken for a minimum of 3 years prior to submission of a planning application in some 5 years hence.

but went on to say that the site "subject to planning, would come on stream approximately 2030."

Aggregate Industries will obviously be hoping for more success with Penslade than with Straitgate, where boreholes were first drilled in 2013, and where 8 years later, in 2021, the company is still floundering. In its first application for Straitgate back in 2015, Aggregate Industries had been hoping on the site "being available from early 2016". It wasn't to be. The application was pulled following a complete fiasco. In March 2017, another application was submitted with the hope that mineral would start being imported from Straitgate into Hillhead Quarry by "mid 2018". 

The fact that Aggregate Industries has been able to function quite happily for the last 5 years with just the sand and gravel from Houndaller – a reserve of some 2.9 million tonnes at the last count, enough to last for 10 years – clearly means it can survive quite happily without Straitgate.

Plans to install piezometers at Penslade

Last year, an Aggregate Industries spokesman confidently told the Venn Ottery Quarry Liaison Meeting:

Penslade [Uffculme] is 10-12 years away - we're not even thinking about that yet

But, with AI’s revised planning application for Straitgate in a mess, and DCC wanting to know:

Can the applicant inform the MPA regarding the likely timescale for developing the Penslade resource? 8.3

something's obviously changed.

Indeed, at a meeting last week, AI's Head of Geological Services confirmed that budgets are now in place to install piezometers at Penslade - the other Preferred Area for sand and gravel in DCC’s newly adopted Minerals Plan.

At least 12 months of groundwater data would be needed before any planning application. The site is identified as having up to 8 million tonnes of resource, and is 23 miles closer to where AI wants to process Straitgate Farm material.

‘A single woodland nut...’

"...chewed by a dormouse, had a central part to play in a High Court dispute over a controversial housing development in South Devon", ran a story in the Plymouth Herald and PlanningResource this week.

Here are Straitgate's dormice:

It is simply staggering that at the Blackhill / Venn Ottery Quarry Liaison Meeting earlier this week, a representative from Aggregate Industries was merrily talking about wanting to start earthworks at Straitgate Farm in the Spring/Summer of next year - start grubbing up 2km of ancient hedgerows - when virtually no appropriate mitigation planting is in place - for a species protected by European law; for a species on the brink of extinction.

BLACKDOWN HILLS AONB

At the same meeting, another AI representative claimed that applications to work Straitgate Farm and extend Blackhill for another 5 years were still "likely to be resubmitted" - but that was some months away yet; slightly different timing from what the company was previously saying. He also claimed that if Blackhill wasn't permitted, the company would seek to truck Straitgate material 23 miles to Hillhead - not Rockbeare - for processing; some 2.5 million miles in total; something the company had previously said "may be feasible, but would generate a massively greater quantity of CO2 emissions" 8.48; something obviously at odds with how environmentally-friendly the company says it is:

Our transport emissions are at the lowest level since we began reporting in 2008 #sustainability pic.twitter.com/2cKCgQHLD8

— Aggregate Industries (@AggregateUK) July 25, 2016

And what of Penslade near Uffculme? Well, apparently:

Penslade is 10-12 years away - we're not even thinking about that yet

Which is a strange thing for AI to say, because Straitgate has little over 3 years' worth of material - even if the company could win 1.2 million tonnes above the water table. Or is staying above the water table not what AI intends at all?