Showing posts with label haulage emissions. Show all posts
Showing posts with label haulage emissions. Show all posts

Thursday, 25 January 2024

HVO – where on earth will all the used cooking oil come from?

Aggregate Industries’ magical solution to its unsustainable 2.5 million mile haulage scheme for Straitgate Farm – a result of processing the as-dug sand and gravel 23 miles away at Hillhead near Uffculme – is to rely on hydrotreated vegetable oil, HVO, despite, as of early 2024, HVO being around 40 pence per litre more expensive than normal diesel. 

Condition 22 of the planning permission to quarry the farm says: 
Prior to the export of any sand or gravel from the site, a scheme which ensures that all heavy goods vehicles entering and leaving the site, together with all plant and equipment located within the site, use hydrotreated vegetable oil fuel shall be submitted to and approved in writing by the Mineral Planning Authority. The scheme shall include details of how the use of hydrotreated vegetable oil fuel will be monitored to secure compliance with this condition. All heavy goods vehicles and plant shall be used in accordance with the approved scheme. 
In 2022, we posted HVO – AI’s answer to the Straitgate sustainability issue – gets bad press and questioned how the company's HVO scheme would work in practice: 
How this would be done is anybody’s guess, since the company does not own its own fleet of trucks and HVO is not available on garage forecourts – as Devon County Council pointed out. How this would be monitored and policed is another issue – as the Council also acknowledged. 
We also posted that HVO is blamed for indirectly "encouraging more deforestation in Southeast Asia" with some research claiming it’s "three times worse for the climate than regular diesel when indirect emissions from changes in the use of land are accounted for". How so? HVO is primarily made from used cooking oils, UCO, which is used in the production of animal feed. Increased demand for UCO will lead to increasing use of palm oil as a replacement, therefore increasing deforestation. Across Europe, imports account for more than half of the UCO that's made into fuel. According to this study, there's no way to prove these imports are sustainable: 
China supplies over a third (34%) of Europe’s UCO imports while almost a fifth (19%) comes from major palm oil producers Malaysia and Indonesia combined. Within a decade the volume Europe needs could double to 6 million tonnes as EU countries strive to meet targets for renewable fuels in transport, the study finds. This in turn could trigger palm oil being used to replace cooking oil in exporting countries while also incentivising fraud (mixing virgin oil).
HVO is fully compatible with petroleum diesel and can also be upgraded for use as ‘Sustainable Aviation Fuel’ (SAF). 
According to Ryanair’s Michael O’Leary, sustainable aviation fuels are a con.

They’re a wheeze. Unless governments get in behind the production and sourcing of sustainable aviation fuels – and they’re only going to come from, ultimately, the oil majors, the only ones who are going to make them – I don’t see where we will get the supply in the volumes we need. You want everybody running around collecting fucking cooking oil? There isn’t enough cooking oil in the world to power more than one day’s aviation. 
Whilst Ryanair has deals with oil majors for up to 9.5% of its fuel needs in SAF by 2030, O’Leary said: 
But we have no idea that they’ll be able to make those kinds of volumes. 
Whilst capacity for HVO is forecast to double by 2028, demand is set to outstrip supply. 

Aggregate Industries is new to the HVO scene. In June last year, the company made a big song and dance about a single HVO-fuelled cement tanker being a "UK biofuel first". For Straitgate, it is conditioned, as pointed out above, that all the trucks, and all the plant and equipment located within the site, will need to use HVO.
 

At our Bardon Hill Quarry we are replacing diesel with HVO on equipment such as generators, compressors and crushing and screening plant. All of our HVO is traceable to source under the International Sustainability & Carbon Certification Scheme, does not result in any deforestation and will save an estimated 3,301 tonnes of CO2e at Bardon Hill. The savings from this, together with our suspended conveyor system saves enough carbon annually equivalent to driving a car 26,000 miles. 
Which is all very commendable – albeit the 26k miles is insignificant compared with the company’s HGV haulage plan for Straitgate. But whilst it may be possible to claim that the HVO used by AI does not directly cause deforestation, proving it does not indirectly cause it, proving that the UCO used in making its HVO is not causing more palm oil to be grown elsewhere as a replacement, is another matter. 

The concern must be that if every corporate is now going to be greenwashing their pollution away with the delights of HVO, where on earth will all the used cooking oil come from? And how many millions more acres of rainforest will have to be cleared to replace it? 

Almuth Ernsting of NGO Biofuelwatch warns: 
We are deeply concerned that HVO is being used and promoted in ever more sectors, from aviation fuels to cars and now as a heating fuel, too. While a limited amount of HVO can be made from genuine waste products such as used cooking oil, such waste products are in very short supply and come nowhere near meeting current HVO demand... EU and UK biofuel sustainability and greenhouse gas standards still permit biofuels from palm oil and soy to count towards renewable energy targets, and they are based on a flawed greenhouse gas methodology which ignores the greatest source of emissions – indirect land use change.
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Friday, 3 November 2023

‘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.

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.
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.
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Monday, 21 November 2022

HVO – AI’s answer to the Straitgate sustainability issue – gets bad press

Aggregate Industries’ answer to the 2.5 million mile haulage scheme for its Straitgate Farm planning application is to claim that the HGVs hauling as-dug sand and gravel to Uffculme for processing would run on chip fat biofuel, or HVO as it's commonly known – hydrotreated vegetable oil. 

How this would be done is anybody’s guess, since the company does not own its own fleet of trucks and HVO is not available on garage forecourts – as Devon County Council pointed out. How this would be monitored and policed is another issue – as the Council also acknowledged. HVO was part of the S106 heads of terms when the application was originally determined, part of the legally enforceable planning obligations; now the HVO proposal finds itself as another planning condition – and we know the problems with enforcing those. 

Devon County Council’s barrister said in his closing submission: 
206. The Appellant’s proffered obligation/suggested condition (it is difficult to keep track – it was in the draft s.106 but seemingly no longer) that the vehicles use HVO goes nowhere. Mr Gould gave up that he can point to no example of the use of HVO in the aggregates setting. This is, as was put to him, innovative technology (he denied that, before being taken to his Proof as “innovative” is his own word). There can be no reliance placed upon it. Nor has there been any evidence from the Appellant as to how the MPA might hope to monitor so as to ensure HVO is being used. The Appellant’s suggested condition does not begin to answer matters: it simply seeks to kick the can down the road and require the question of whether monitoring is possible to be addressed later. Not good enough. To be addressed now. 
Mr Gould, who represented Aggregate Industries, preposterously claimed "the proposal minimises transport of minerals with innovative solutions to help achieve this". 

Apart from all that, uptake of HVO is being rejected by a number of organisations, including the Environment Agency and others: 


Even before determination last year, we pointed to the fact that rising imports of used cooking oil into the UK for biodiesel is indirectly "encouraging more deforestation in Southeast Asia" with some research claiming it’s "three times worse for the climate than regular diesel when indirect emissions from changes in the use of land are accounted for". 

Others have problems with it too. HVO is primarily made from used cooking oils or UCO:
According to Jo Gilroy, Balfour Beatty’s group sustainability director, it is simply a matter of due diligence. “We’re very good at jumping on solutions and thinking they’re the answer to our problems, aren’t we?” she says. “We look for easy wins, and HVO looked like that. 
“But any one-hit wonder solution needs to be examined carefully; you always have to do your due diligence.” 
As momentum built in favour of HVO, Balfour Beatty decided it had to delve deeper into the sustainability claims being made for the fuel before approving its use. And what it has found so far has only raised doubts. 
The chemistry of HVO is well understood but less clear is the sustainability of its supply chain. “What does the supply chain look like?” demands Gilroy, “Nobody knows - it’s very complex and there’s very little transparency.” 
One of the big attractions of HVO is that it purports to transform a troublesome waste material into a valuable commodity. But Gilroy says this is misleading: “UCO has always been used in the production of animal feed – it’s not a waste product,” she says. 
This might appear to be a mere technicality, but if one industry’s feedstock is diverted to supply another industry’s needs, alternative sources must be found. If producers of animal feed cannot obtain enough raw material in the form of UCO, they will turn to primary sources, namely commercially-grown vegetable oils such as palm oil. 
Mention palm oil and you open a whole new environmental can of worms...
Balfour Beatty’s Position paper on HVO can be found here: 
There is a high risk that the resulting increase in demand for used cooking oil is causing deforestation and the draining of peatland and marshland in countries such as Malaysia and Indonesia where farmers are having to grow palm oil to produce animal feedstock. Such displacement activity has an extremely damaging impact on the environment: these areas store large amounts of carbon, so clearing them would lead to a significant increase in carbon emissions in those countries. EU research indicates that once the effects of land use change and draining of peatland are accounted for, the GHG impact of palm-oil derived HVO could be up to 3 times greater than standard fossil fuel diesel.
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Wednesday, 30 June 2021

AI ‘welcomes new net zero rules for major UK government contracts’

Aggregate Industries has apparently "welcomed the news that firms looking to bid for UK government contracts worth more than £5 million will need to prioritize sustainable building materials as a new rule requires them to commit to achieving net-zero carbon emissions by 2050." The company's press machine has been mobilised: 
Kirstin McCarthy, sustainability director at Aggregate Industries, commented: ‘Given the billions of pounds the government spends on construction schemes each year, these new rules are a major leap forward for sustainability – positioning the UK as a world leader. 

‘However, it also means that companies hoping to win these lucrative government contracts must demonstrate a credible, robust and ambitious plan for achieving net-zero carbon emissions. 

‘The good news is that Aggregate Industries have invested heavily to innovate and develop low-carbon materials in recent years, including concrete, concrete blocks and asphalt. The speedy adoption of these will be fundamental to any successful tender, hence, we’d urge those that haven’t done so already to prioritize the use of sustainable building materials now.’ 

The advice comes as, for the first time, the UK Government will require companies to report some scope-three emissions – including transportation… 
Oh dear, surely that’s a problem for Aggregate Industries, who clearly doesn’t think twice about plotting multi-million mile haulage plans across Devon – with all the resulting CO2 and other nasty emissions that would result? But Ms McCarthy clearly believes otherwise: 
‘While reaching Net Zero remains a big challenge for the construction sector, we’re seeing tangible progress. For instance, at Aggregate Industries, not only are we committed to removing as much transport from roads as possible through the use of rail and water transport… etc etc 
Perhaps Ms McCarthy hasn’t come across the company's plans for Straitgate Farm yet – given that she only joined the company this month.


Commenting on the appointment, Dragan Maksimovic, Chief Executive Officer at Aggregate Industries, who has only been in post for a matter of weeks himself, said:
As part of our strategic commitment to reduce the carbon footprint across our business we have appointed a new Sustainability Director who joins our Executive Committee. I’m delighted to welcome Kirstin to the team and I look forward to her playing an integral part in achieving our ambitions.” 

“This appointment is placing us in a unique position at the forefront of our industry and we must continue challenging ourselves to continuously reduce our carbon footprint through innovation, commitment and personal accountability.”  etc etc 
Ms McCarthy looks forward to "contributing to building a greener, smarter world for all":
Bringing more than 20 years’ experience in environmental management to the role, Kirstin will be responsible for accelerating the company’s journey to net-zero and for driving improvements across all aspects of sustainability. Prior to joining the business, Kirstin was Head of Sustainability at Birmingham Airport... etc etc 
And we all look forward to seeing how that translates... in the real world.
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Thursday, 6 May 2021

AI’s greenwash document assumes no gravel at Hillhead, not 25%, not 5%, not any!

Oh dear. Aggregate Industries and Devon County Council must have been hoping for great things from the report "Greenhouse Gas Assessment of the Proposed Quarry at Straitgate Farm" by Dr Daniel Lash from The Centre for Energy and the Environment at the University of Exeter.

But it really is a pile of worthless drivel. 

In October 2020, we posted ‘Ask Exeter University to help with your CO2 problem’ – suggested DCC to AI, and indeed Aggregate Industries did just that. A report was produced. It should have been titled "How to Greenwash the Proposed Quarry at Straitgate Farm". It concludes: 
The calculations show that the proposal for extraction at Straitgate Farm with onward processing at Hillhead Quarry will result in 11% lower GHG emissions than meeting the demand for sand and gravel in proposed markets from existing quarries.
It’s a fantastical illusion, because Hillhead is 23 miles away from Straitgate. 

You might have expected more from a company loudly proclaiming it is "committed to tackling climate change", from a parent company apparently "making climate action part of everything we do."  

But greenwash is what we've got, with some whitewash thrown in too.

Whitewash? Aggregate Industries had previously told Devon County Council that:
Processing at Hillhead may be feasible, but would generate a massively greater quantity of CO2 emissions from the additional mileage required to be travelled. 8.48
Now, of course, that the company is wanting to process at Hillhead, it's a different story.

Dr Lash's report has glaring omissions and errors too. Although no credentials are provided, Dr Lash is an academic, who has advised the Devon Climate Emergency Response Group, and should know better. An academic would normally cross-check their facts, make sure they’re robust, take a look, ask around, try Google at least, not just take the word of a profit-hungry aggregates business. 

Dr Lash has not checked his facts. The giveaway is on the front page of the report: 
Any information provided by third parties and referred to herein has not been checked or verified by the Centre for Energy and the Environment, unless otherwise expressly stated in the document. 
So, not rigorous at all then. 

And it shows. Dr Lash has assessed the "Do Nothing" scenario, i.e:
The GHG emissions that would arise without the proposed quarry at Straitgate Farm, namely that the demand for sand and aggregate at the target markets would need to be met from other quarries
These calculations assume that in the absence of a quarry at Straitgate, Hillhead would NOT produce any gravel. None at all. Zero. Nada. Not for asphalt plants. Not for the Exeter/M5 market. Not now. Not in the future. Not from the 8 million tonne sand and gravel resource at neighbouring Penslade, a Preferred Area in the Devon Minerals Plan. It’s a revelation. It makes you wonder what this is doing at Hillhead:

Hillhead Quarry is an important source of sand and gravel. The site produces high quality sand and gravel and coarse aggregates for the general construction industry, concrete aggregates, building sand, asphalt and coated materials for road-making.
Devon County Council also assumes there is gravel at Hillhead at the Houndaller site: 
2.5.4 Information provided by Aggregate Industries UK Ltd [SLR (2015)] in support of their planning application for Straitgate Farm near Ottery St Mary indicates a ratio of 54% gravel to 46% sand at that site, while their reserves at Houndaller near Uffculme have a ratio of 25% gravel to 75% sand.
Photos in the Council's monitoring reports for Hillhead – above and below – give the game away too, as do the piles of unprocessed pebbles previously photographed at the site.


Aggregate Industries' very own Supporting Statement for the application to import Straitgate material into Hillhead also admits: 
2.2.1. Sand and gravel extraction has taken place on the site for some time. The 1890/91 OS map marks an ‘old gravel pit’ to the north of the site... 
3.2.3. ...the sand and gravel deposit indigenous to Hillhead Quarry is red in colour and is sand rich, containing circa 20% gravel. 
And the area next to Hillhead at Penslade? The Devon Minerals Plan tells us that:
9.3.5 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. 
In other words, in the past, the present, and the future, there's not zero gravel at Hillhead. This table from Devon County Council's Local Aggregates Assessment gives more detail:
What size is the existing reserve at Hillhead? In 2019, Aggregate Industries helpfully confirmed: 
The company's reserves schedule for Houndaller was subsequently revised to 2.9 million tonnes as at 1st January 2019.
So – bearing in mind Hillhead is 23 miles away from Straitgate – what fanciful figures has Aggregate Industries been able to come up with? Dr Lash has calculated that to quarry Straitgate Farm and haul material to Hillhead for processing for onward supply to markets would result in a total of 3.96 million miles. But to not quarry Straitgate, to forget all the gravel at Hillhead, and to source much of the gravel from Cornwall would result in 4.38 million miles. It’s brilliant, but complete and utter nonsense. 

If we instead remember that Houndaller next door to Hillhead has 25% gravel, then not quarrying Straitgate would save 1.3 million miles. If we remember the other 8 million tonnes of sand and gravel allocated in the Minerals Plan at Penslade next door to Hillhead, then not quarrying Straitgate would save 2.1 million miles. We’ve calculated three other scenarios too. All five scenarios result in less mileage than the smoke and mirrors from Aggregate Industries. Calculations can be found here.

But forgetting the gravel at Hillhead is just one of many problems with this report. Claiming "17,200m2 of restored orchard" at Straitgate would be planted "at a density of 2,250 trees/Ha" leading to annual sequestration of "9.3 tCO2e" is another problem. Because if 3,870 trees were ever planted in this small orchard there would be no orchard, particularly when Aggregate Industries has previously claimed "cuttings will be taken from 10 trees". 

Can Aggregate Industries not offer up a single report without something being seriously amiss?
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Thursday, 8 April 2021

Quarry operator granted permission to move processing on-site – from 3 miles away

Virtually all sand and gravel quarry operators process on-site – not 23 miles away as Aggregate Industries has proposed for Straitgate Farm. It makes economic sense. It makes environmental sense.

This week, Warwickshire County Council approved planning application RBC/20CM010 from Smiths Concrete to process sand and gravel at Wolston Fields Quarry rather than hauling material to a processing plant 3 miles away. Only two public objections were received. One councillor remarked: 
By making sure it is going to work for the local community as well as being the known operator in the area is shown by the relatively low number of objections. With something like this you can sometimes have pages and pages and we’re just not seeing that this time which shows that this has been well thought through, well worked through with the proper consultation and everything has been considered.
The applicant claims that the proposals would reduce vehicle mileage by 50,000 kms and this would lead to a reduction in fuel consumption and carbon emissions over the short life of the scheme. The bulk of the figure arises from no longer hauling silt from Wolston to Bubbenhall for processing and the remainder from shorter trips to the company’s markets in Rugby and Coventry east areas. The claim appears reasonable and would demonstrate the reductions policies DM 5 and DM11 are seeking to achieve and a commitment to adapting to climate change.
Those policies are from Warwickshire’s emerging Minerals Plan. DM5 Sustainable Transportation: 
Developers must demonstrate that a proposal facilitates sustainable transportation by: a. considering alternatives to road transport; b. minimising transportation distances; c. minimising the production of carbon emissions; and d. Where road is the only viable method of transportation, demonstrating that there is no unacceptable adverse impact on the safety, capacity and use of the highway network. 
DM11 Carbon Emissions and Resource Efficiency: 
Mineral development that reduces overall carbon emissions and improves resource efficiency during construction, operation and restoration will be supported subject to compliance with other policies in the development plan. 
One day, Devon County Council might have to determine Aggregate Industries' proposal for Straitgate Farm. It would be an indication of how seriously the Council takes its declaration of a climate emergency, because rather than reducing haulage distances by 50,000 kms, Aggregate Industries' application is all about increasing haulage distances by 4,000,000 kms.
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Wednesday, 24 March 2021

DCC's Chief Executive warns us not to go back to our old unsustainable ways

A "message of thanks and hope" was sent out by Devon County Council this week reminding us to reflect on the past year, including on Devon’s carbon emissions: 
Over the last year real progress has been made to create a roadmap to show the way to a net-zero Devon by 2050 at the latest.  
The Devon Climate Emergency Response Group (DCERG) and its appointed group of experts, headed by Professor Devine Wright, have created an interim draft carbon plan. That plan will become the blue-print to show what we must all do - residents, councils, businesses alike - to ensure that Devon reaches its net-zero ambitions.  
Since the first lockdown we have been encouraging more walking, cycling, and advising people on how to get around safely while social distancing. Pavements have been widened, new paths created, and roads have narrowed to accommodate greener travel options.  
Research last summer showed that Devon's carbon emissions reduced by almost a quarter during the first lockdown.  
"We have an opportunity to introduce transformative change, and not just tinker around the edges," said Professor Devine Wright.  
Chairman of the DCERG, Dr Phil Norrey said: 
"The lockdowns have given a glimpse of how a more sustainable Devon might look, feel and sound. 
"There is a huge opportunity to improve our public health, our resilience and our wellbeing, as well as address the climate and ecological emergencies.  
"We must be careful not to fall back into the same old routines. We all must think differently about the way we work and the way we travel."

So if Devon County Council’s Chief Executive Dr Norrey, Chairman of the Devon Climate Emergency Response Group, warns us not to go back to our old polluting ways, what must be done? 

DCERG's draft interim Devon Carbon Plan says transport accounts for 31% of Devon’s greenhouse gas emissions, so "reducing emissions from transport is key to successfully reaching net-zero." How is this to be done? Follow a "hierarchy of action". What's top of the list? "Reduce the need to travel". 

Obvious really. Not embarking on needless multi-million mile haulage schemes for new sand and gravel quarries should also be obvious.

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Sunday, 21 March 2021

Has AI thought through all of the alternatives?

A description of the reasonable alternatives (for example in terms of development design, technology, location, size and scale) studied by the developer, which are relevant to the proposed project and its specific characteristics, and an indication of the main reasons for selecting the chosen option, including a comparison of the environmental effects. 
It’s something to look out for when Aggregate Industries finally gets around to submitting revised and long-awaited documents to support its application to quarry Straitgate Farm, to check that all reasonable alternatives have been addressed – including but not limited to the do-nothing option, site access, phasing, processing location, mode of transport.
 


Well ok, no one is suggesting Aggregate Industries employ Straitgate's cows to haul sand. 

Aggregate Industries did look at alternatives for its first application in 2015. When previously arguing the case for processing Straitgate's material on Woodbury Common in the East Devon AONB, the company claimed: 
Processing at Hillhead may be feasible, but would generate a massively greater quantity of CO2 from the additional mileage required to be travelled. 8.48
What is now proposed? Processing at Hillhead. The cost: a haulage scheme of 2.5 million miles. 

According to the above regulations, Environmental Statements should include:
A description of the likely significant effects of the development on the environment resulting from, inter alia:... (f) the impact of the project on climate (for example the nature and magnitude of greenhouse gas emissions)
In 2019, Devon County Council, which has declared its own climate emergency, advised Aggregate Industries – "in the spirit of helping to address issues" – to contact experts at Exeter University to help it explain away, to greenwash?, the "massively greater quantity of CO2 from the additional mileage". What a sympathetic council.
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Monday, 14 December 2020

‘Every aggregate freight train takes 70-75 lorries off the road’

Aggregate Industries’ CEO Guy Edwards was recently asked his views on his company’s application to quarry Straitgate Farm. Despite claiming that his company took its responsibility to the environment "very seriously", Mr Edwards failed to explain why the underlying material at Straitgate is worth the environmental cost of 2.5 million HGV miles, and the thousands of tonnes of CO2 that such a scheme would produce.

CEMEX and others have in the meantime been publicising their push to use more sustainable transport:

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Wednesday, 2 December 2020

Aggregate Industries’ CEO Guy Edwards in reply to Straitgate sustainability issue

At a time of climate crisis – when public concern about the environment and climate change has never been higher – we thought we’d write to Aggregate Industries’ CEO Guy Edwards to ask him about the company’s proposal for Straitgate Farm.

It was an ideal opportunity for Mr Edwards to explain why Straitgate is so important to the company that it justifies a 23 mile haulage route between quarry face and processing plant, an ideal opportunity to explain why the underlying material at Straitgate is worth the environmental cost of 2.5 million HGV miles. 

This is what we wrote: 
Dear Mr Edwards, 
You will be aware of the intense and growing focus on ESG issues, not only by the public and media, but also by the investment world; LafargeHolcim tapped the latter only last week with an €850 million sustainability-linked bond. 
Given that Aggregate Industries claims “sustainability is at the heart of our business, and is incorporated in all of our operations”, we would be interested in any comments you may have about the company’s planning application in Devon for a new sand and gravel quarry at Straitgate Farm. 
You may already know of this application. Over the last decade, your company has struggled to address the many constraints linked with this site, not least on groundwater. The irreversible damage to the many surrounding private water supplies and Grade I listed Cadhay from your company’s proposal has been unequivocally set out in a damning report by leading authority Professor Brassington. 
Your company’s application is for "up to 1.5 million tonnes of as raised sand and gravel". However, significantly less than a million tonnes of saleable material would be recovered, given that waste accounts for 20% of that figure, and elevated groundwater levels have yet to be factored in. This ignores the fact that similar local sites, Marshbroadmoor and Venn Ottery, respectively yielded 80% and 50% less than forecast due to geological constraints. 
However, what sets the Straitgate application apart – at a time that councils and the UK government have declared a climate emergency – is the issue of sustainability. 
Your company is proposing a 46 mile round trip to process every as-dug load; a staggering 2.5 million miles in total – before any onward delivery of finished product. 
No other UK aggregates operator has 23 miles separating quarry face and processing plant. Clearly this – together with Aggregate Industries’ lamentable progress reducing carbon emissions – sends the unequivocal message to the wider world that sustainability is neither at the heart of your business nor incorporated into all of your operations. 
You can google Straitgate for further information. 
We look forward to hearing from you. 
Mr Edwards – as we posted in Aggregate Industries' CEO talks net zero – has previously claimed: 
With the government committing to producing ‘net zero’ greenhouse gases by 2050, the construction industry’s role in safeguarding the future of our planet has never been more prevalent.
While the magnitude of the task facing us in achieving ‘net zero’ is clear, we’re confident that a forward-thinking, progressive industry like ours will take up the mantel and lead the way in demonstrating the lengths we can go to reduce our environmental impact, which will positively impact us all.
So, naturally, we were interested to hear how Mr Edwards squared such fine words with his company's plan for Straitgate. This is what he wrote: 
Thank you for your letter dated 23rd November. 
At Aggregates Industries we take our responsibility to the environment and communities in which we operate very seriously, which is why it is one of our company's strategic pillars. 
In response to your letter, I would like to make you aware that shortly, we will be formally submitting additional information for our 2017 planning application to Devon County Council, which will include transport sustainability data. 
This will then be published on the County Council's website and subject to formal planning consultation. 
Is anyone surprised by the brevity of Mr Edwards' reply, or the lack of meaningful response to the central issue raised? 

Of course, Aggregates Industries has been promising to furnish additional information shortly for more than 3 years now; determination of its application has been extended 11 times as a result. Perhaps this time will be different. 

And we’ve already posted about the "transport sustainability data" issue, how Devon County Council suggested to Aggregate Industries that they should ask Exeter University to help with (greenwash away?) the emissions related to Straitgate.

Presumably Mr Edwards' lack of concern about the 2.5 million mile haulage scheme is an indication of "the lengths we [Aggregate Industries] can go to reduce our environmental impact"? 

Clearly, if Aggregates Industries took its responsibility to the environment "very seriously" we would not have posted Climate emergency? Not at Aggregate Industries. CO2 emissions increase again. 

If Aggregates Industries took its responsibility to the environment "very seriously" we would not have posted about how the company has seemingly given up publicly reporting its own CO2 emissions. 

If Aggregates Industries took its responsibility to the environment "very seriously", the company’s application for Straitgate Farm would have been scrapped years ago.
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Wednesday, 4 November 2020

DCC says local plan policy tackling climate crisis should be ‘implemented robustly’

Since Aggregate Industries applied for planning permission to quarry Straitgate Farm – and haul material a staggering 2.5 million miles in total to be processed – Devon County Council has declared a Climate Emergency. We have posted about it. Devon County Council’s Chief Executive Phil Norrey said:

This is not about gestures, this is about action
And it must be about action. The UN warned we have 12 years to limit the climate change catastrophe. That was 2 years ago. Every day, more signs of our global heating calamity are emerging; recently we learnt about the release of Arctic methane deposits adding to the domino effect.


Local plans set out policies used by county councils to determine planning applications. They are not prepared for decoration, for fancy bookends, for pressing flowers, but to inform future development. There is no point going to the lengths and expense of preparing local plans if the policies contained within are to be cast aside whenever they get in the way. 

Local plans are periodically reviewed. The Devon Waste Plan, for example, adopted in December 2014, was reviewed this year, taking into consideration amongst other things the Devon Climate Emergency. A Review of Climate Emergency Declaration implications for Devon Waste Plan was published in August 2020:
The Devon Climate Emergency is considered to be a significant change in local circumstance since the adoption of the Waste Plan which requires consideration. 1.1.5
The review presented within this report has identified that tackling climate change features strongly as a key theme within the current Waste Plan. It is central to its vision, objectives and policies. The Devon Waste Plan policies contain a number of measures which seek to reduce and adapt to the impacts of climate change. 1.6.1
The review concluded that:
...at this stage, the existing measures in the Waste Plan are sufficient in the context of the declaration, providing they are implemented robustly. 1.6.2
Providing they are implemented robustly. 

Waste planning and mineral planning often go hand in hand. In fact, the Devon Waste Plan was authored by the same person that compiled the Devon Minerals Plan. Like the Waste Plan, the Minerals Plan also contains policies to tackle climate change. The Devon Climate Emergency would again be a significant change in local circumstance since the adoption of the Minerals Plan. According to the Minerals Plan:
One of the biggest challenges facing Devon’s communities and environment, together with the wider world, is climate change driven by global warming. 3.4.1
Mitigation of and adaptation to climate change is a key consideration and statutory duty for the Devon Minerals Plan, and will be a cross-cutting theme for the Strategy. 2.2.4
Rather than being considered as a discrete issue, climate change is treated as a thread running through the Minerals Plan that influences a range of Policies. In particular: (a) the Spatial Strategy (Policy M1) ensures that the distances that minerals are transported by road are minimised... 3.4.7
Distances that minerals are transported by road are minimised.

Clearly, given Devon County Council’s Climate Emergency Declaration, Minerals Plan policies relating to mitigating climate change should also be implemented robustly. What is the point in declaring a Climate Emergency otherwise?

But the Minerals Plan doesn’t only cover general policies; it contains specific policies on specific sites, including for Straitgate Farm. For this site, the Minerals Plan does not say it’s OK to transport 53,000 28-tonne loads of as-dug material 23 miles from quarry face to processing plant – a total of 46 miles for each load – as Aggregate Industries has proposed. The Minerals Plan for Straitgate says:


Minimal transportation by road.

Clearly we can’t rely on Aggregate Industries to employ a moral backbone and do the right thing; as we posted, Climate emergency? Not at Aggregate Industries. CO2 emissions increase again.

So, if Devon County Council is serious about "one of the biggest challenges facing Devon’s communities and environment", if declaring a Climate Emergency is to mean anything at all, it must indeed ensure that policies that seek to reduce carbon emissions do just that, and are implemented robustly. It’s not rocket science. 

 

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Monday, 5 October 2020

‘Ask Exeter University to help with your CO2 problem’ – suggested DCC to AI

We all know by now that rather than letting Aggregate Industries – subsidiary of cement giant LafargeHolcim – stand on its own two feet, ‘Devon County Council’s job is to deliver Straitgate’, providing any assistance it can.

But did the Council really suggest – in a time of climate crisis – that Aggregate Industries should greenwash away the carbon emissions connected with its application to quarry Straitgate Farm?

Surely not. But in October last year, in an email about the outstanding matter of "the Sustainability appraisal" uncovered by a FOI request, Devon County Council sent this message of help and advice to its friends at Aggregate Industries:
As I previously mentioned on a number of occasions, I can’t stress enough how important that will be and you might want to consider using a known expert in the field such as Exeter University to check it over, if not to produce it.
I can foresee that the road mileage (amongst other issues) will be a main point of debate so the report should also consider more up to date solutions such as an electric fleet before I am asked to go back to you to assess it?
This is only an observation, but is given in the spirit of helping to address issues that I am almost certain will be raised in the consideration of this proposal by the County Council’s development Management Committee. Any report to them currently needs be extremely clear on the carbon/sustainability issue following the declaration of a Climate Emergency.
In December, in a later email, Aggregate Industries confirmed:
I am in the process of arranging a meeting [with a] Senior Research Fellow from Exeter University to address climate change and sustainability issues.
Perhaps Devon County Council thought Aggregate Industries hadn't quite grasped the severity of our climate emergency – the record temperatures, the wildfires, the melting ice caps. Perhaps they hadn't – if Aggregate Industries’ track record on CO2 emissions is anything to go by.

But people might wonder why, if Devon County Council has declared a climate emergency, its planners – "in the spirit of helping to address issues" – are still suggesting ways to ease the passage for Aggregate Industries’ nonsensical plan. People will rightly wonder how hauling as-dug aggregate 2.5 million miles – to a processing site that already has more than 10 millions tonnes of the same material – contributes to Devon’s net-zero ambitions.

And Devon is not alone with net-zero ambitions. Even cement giants are now jumping on the bandwagon, pushing out press releases, proclaiming they've changed:


So, if LafargeHolcim really has changed its spots, how does the carbon-intensive plan for Straitgate – the one that would be operative until the mid 2030s – sit in a #netzero world?

How does it square with what Guy Edwards, CEO at Aggregate Industries, claimed only last month?
We’re proud to be part of the LafargeHolcim Group as it makes the bold and ambitious pledge to go Net Zero by 2050. By being the first building materials supplier in the world to sign up to the SBTi’s ‘Business Ambition for 1.5°C’ demonstrates our genuine desire to achieve real and lasting change in protecting the environment.
In our capacity as one of the UK’s leading construction materials suppliers, we fully support LafargeHolcim’s pledge and accelerating the use of low-carbon and carbon-neutral products is just one of the initiatives we’re currently working on to help create a greener construction industry.’
Or this statement, from Guy Edwards talking about lowering CO2:
Sustainability remains at the heart of what we do, and our aim is to make a positive contribution to the built environment now and for future generations.
You see, words are easy. Words are cheap. The question is, will any of those words herald anything new? Or is it more greenwash? Will carbon-intensive plans be junked in favour of more sustainable ones? Or will it be more of the same-as-usual?

Because as things stand, such grandes déclarations ring hollow – when Aggregate Industries is prepared to put a ridiculous 23 miles between quarry face and processing plant for bog-standard sand and gravel.

In fact, you wonder if this company has any idea what sustainability looks like. If the company really wanted to "address climate change and sustainability issues", if "sustainability remains at the heart of what we do", if there were any genuine desire, Aggregate Industries would have scrapped its plans for Straitgate years ago.

But as extreme weather grips our planet, Aggregate Industries clearly has no qualms about calling upon Exeter University to "address" the CO2 emissions connected with the Straitgate project, no doubt putting it through some greenwashing cycle to help councillors look more favourably upon its gas-guzzling scheme.

We don’t know what came of any meeting at Exeter University. The Senior Research Fellow in question, with "a background in architecture and building physics", is often called upon by local authorities. In fact, somewhat ironically, he has been called upon to help move Devon to net-zero carbon emissions.

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Tuesday, 14 January 2020

After DCC’s climate emergency declaration – and “comments in the public domain about how the road trips can be justified” – Council pushes AI for further information

As we watch our planet burn, we know, according to analysis in the Financial Times, that if every company acted like LafargeHolcim – parent company of Aggregate Industries – we would be heading for a +6°C world, enough to "wipe out most life on the planet".



Apparently, the climate emergency is top of the agenda @DevonCC:


Chief Executive Phil Norrey told members of Devon County Council’s ruling Cabinet on 12 June 2019:
This is not about gestures, this is about action
If it’s not about gestures, how has the Council's declaration of a climate emergency affected its actions on planning decisions? One recent decision taken was the approval of planning application DCC/4135/2019. We posted about the application, which proposed:
Change of use from In-Vessel Composting Facility to Incinerator Bottom Ash (IBA) Recycling Facility to import and process up to 90,000 tonnes of IBA per annum, Former TEG In Vessel Composting Site, Stuart Way, Hill Barton Business Park, Exeter
The officer’s report put before the Development Management Committee did indeed look at the impact the proposal would have on climate change, making the case it would lead to reduced CO2 emissions:
Other Environmental Considerations (Including Climate Change)
6.29. Paragraph 148 of the National Planning Policy Framework requires that “the planning system should support the transition to a low carbon future in a changing climate”, while Devon County Council has declared a climate emergency and committed to facilitating the reduction of Devon’s carbon emissions to net-zero by 2050. The scope for individual planning applications to contribute to these initiatives will be dependent on the nature and scale of the development being proposed, and relevant considerations are outlined below.
6.31. Given these requirements, the application would also allow the IBA to be managed and utilised closer to the source of the waste. It is understood that alternative locations closer to the Plymouth energy from waste facility have been considered but have proved undeliverable. Whilst HGVs will still be required to transport material between the facilities, this is a much shorter distance than the current arrangements which see the IBA from Plymouth shipped to the Netherlands. The applicant has provided a comparison of the estimated CO2 emissions generated from the transportation to the Netherlands and Hill Barton and this shows that shipping the material to the Netherlands generates approximately 3.5 times as much CO2 as the road transportation to Hill Barton. This assessment is considered reasonable and would lead to reduction in CO2 emissions.
So, as we watch our planet burn, what additional information – on carbon emissions, alternatives etc – would be made available to the planning committee that decides on Aggregate Industries' proposal to quarry Straitgate Farm and then haul each 29 tonne load of as-dug material a round trip of 46 miles for processing, 2.5 million miles in all, to a location that already has millions of tonnes of sand and gravel reserves and resource?

Documents released under a recent Freedom of Information request show that, on 29 May 2019, Devon County Council wrote to Aggregate Industries:
Following the County Council’s declaration of a climate emergency, we have been asked to do more in our committee reports to consider this issue in finer detail.
This is the current requirement:
“I have been advised by Democratic Services that we need to include ‘Climate Change Impact’ in Cabinet/Committee reports (This was mentioned by Councillor Croad at yesterday’s Council meeting). Democratic Services have issued revised guidance as follows on a required paragraph. Please could you remember this when drafting/approving reports.
Environmental Impact Considerations (Including Climate Change)
Summary of all environment and environmental related issues (including climate change impact) including not only any direct impact on the environment and mitigating activity/work, but the socio-economic impact and sustainability of any proposals ... the likely impact on carbon emissions (or offsetting) ... referring to any formal Environmental Impact Assessment or options appraisal undertaken.
Describe the effects .... are they positive, negative or neutral ... factually! It does not necessarily need to be a balancing exercise between the extremes. Major schemes should detail the economic impact/benefits.”
Clearly this is up to the case officer, but if you are able to provide me with more up to date information about alternatives and with any up to date economic data that would be really helpful. You will understand that this report will be subject to heavy scrutiny and that there are already comments in the public domain about how the road trips can be justified when there are alternative reserves available closer to the process plant.
On 25 September 2019, Devon County Council wrote to Aggregate Industries again:
…I would however welcome a statement of where AI is with the remainder of the requests for additional environmental information, and in particularly the revised sustainability appraisal I recommended you to provide following the DCC declaration of a climate emergency.
On 7 January 2020, in an email to us from Devon County Council’s FOI team:
3. The revised sustainability appraisal has not been received as yet, therefore we do not hold this information. The Planning service recommendation was made following the Council’s declaration of a climate emergency.
No doubt Aggregate Industries will eventually come up with some cock and bull story – as before. But as we posted in AI’s sustainability argument for Straitgate blown away with PSV mileage calculations and AI’s resurrected plant at Hillhead has enough material nearby to take it beyond 2050:
...each 28.5 tonne load of high PSV material from Straitgate would necessitate a staggeringly unsustainable 417 miles of transportation for production, BEFORE any onward delivery. In other words, high PSV material from Straitgate would have to travel over 3x the return-trip distance of material from Greystone, an AI quarry in Cornwall also with high PSV material.
But seemingly, Aggregate Industries doesn't care about CO2 emissions. As we posted last year, Climate emergency? Not at Aggregate Industries. CO2 emissions increase again.




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