AI's trade body complains again

There's really no pleasing some people. Whilst the NPPF has moved the odds firmly in favour of development, that's still not enough for the Mineral Products Association. The trade body that represents companies controlling 90% of UK aggregate production and "helps secure greater weight for minerals in planning" - as if Holcim et al. can't stand up for themselves - now complains that the NPPF is not delivering for them, and says the situation is becoming "critical". Specifically, with local authorities failing to produce up-to-date plans, "great uncertainty has been created for mineral developers, which is undermining investment for the medium and long term". Apparently "MPA members are saying that the last thing that they want to do at the moment is engage with the planning system and submit applications" - "too expensive and too risky".

Which sounds tragic, but in the real world, Aggregate Industries hasn't been put off its stride in carrying out preliminary work towards an application to quarry Straitgate Farm.

The MPA calls to "re-establish the primacy of the planning system over the environmental permitting system which should enable and support democratically determined land use decisions", predictably confirming that, to the MPA and its members, the environment - where people, amongst others, inconveniently live - is of secondary concern.

It grumbles that LAAs are "inconsistent" and "the thrust is erring towards provision of less sites for future mineral extraction", which does show that some authorities are seeing sense and recognising the long-term decline of primary aggregate consumption.

The MPA bemoans that "replenishment rates for aggregates [are] continuing to languish at around 60%" of production, but BDS who monitor these things estimates that nationally 70% of sand and gravel was replaced - continuing a "trend which has occurred over many years". And has there been any shortage of gravel? Any resultant increases in prices? No - replenishment rates are low because demand has been falling for years, and operators haven't needed any more reserves.

And the MPA does admit that current reserves are adequate, but, not surprisingly, talks up the future supply its members will need for "the planned upturn in demand in 2014 and beyond". Of course, when the MPA says "planned" it really means "forecast", or "hoped for", or "failing that year, the year after". Because, in truth, no-one knows. Some construction forecasters are showing a decline for 2014, some say that construction has "10 more years of pain".

Trade associations say what suit them. The British Aggregates Association, "the recognised voice of independent quarry operators", in its recent plea to George Osborne to scrap the Aggregates Levy, lamented that the sector "has operated at 40% below the pre-recession output levels for over 5 years with little or no indication of any improvement in the foreseeable future" - in direct contrast with the MPA's "planned upturn".

Plainly the MPA's duty is to its members who fund its overheads - no-one else, and what it says should be interpreted with this in mind. As Norman Baker MP said last week, "It's no great surprise that the asphalt industry thinks we need to spend more money on asphalt".

Two quarrying proposals without any objections at all

Minerals can only be quarried where they are found. But, unlike Straitgate Farm, some locations are obviously more acceptable than others, and some raise no objection at all.

Tynes Quarry on the North Cornwall coast is such an example. Cornish Stone Products has a "long-term plan of development on a small scale". Set to be reopened, the operation will support about six people, involves no blasting and "the stone extracted would be mainly for hedging and facing". In recommending approval, the planning officer reported that "the previous history of the site as an active quarry is a material planning consideration". "A wetland area would be created at the western end of the site as ecological mitigation" and "the nearest homes are some distance from the site and there have been no objections from them".

Another example, "Duntilland Quarry is one of the largest mainland hard rock quarries in Scotland" and in 2010 Aggregate Industries applied for, and in 2011 secured, "a 43Mt consent on a 165ha site extending the life of the quarry until 2049". Not one objection was received. AI's Estates Manager for Scotland, wrote in Mineral Planning "Aggregate Industries found that the key to manoeuvring a major minerals application smoothly through the planning process was a great deal of public consultation and sensitivity to the environment".

Duntilland Quarry

Which is how it should be. He added "the consultation addressed many issues either through events or one-to-one meetings and no objections or negative representations were made to the application". It all sounds great. But why did it go so well? And were there really no "negative representations"?

It helped that the application was for an extension to an existing quarry, directly adjacent to and north of the M8 motorway, with the nearest communities to the south of the M8. It helped that AI visited "neighbouring residents and businesses to discuss the proposed extension ensuring all parties were aware of and able to participate in the planning process." But the main reason for the lack of objections was probably because, as AI's planning documentation makes clear, "the proposed quarry extension is in an isolated location, several kilometres from the nearest settlement or village".

Regarding the claim of no "negative representations", Salsburgh Community Council did in fact make nine pages of "observations" on dust, PM10s, HGVs, visual impact, ancient monuments and more, but submitted no formal objection. 

In fact, for an application proposing 39 more years of hard rock quarrying, 24 hours a day, 7 days a week, only six people attended "a well-advertised consultation event", two of which were from North Lanarkshire Council. If DCC's West Hill drop-in event last year is anything to go by, any event AI organises, in connection with quarrying at Straitgate Farm, could expect hundreds. For the multitude of reasons raised by the Environment Agency, Natural England, Exeter Airport and local people, Straitgate Farm is plainly not the right location.

‘Two fingers’ to the generosity of the community

A reader has highlighted yet another case where restoration plans for an Aggregate Industries' quarry have gone awry - this time in Uttoxeter. It's not landfill that has been proposed, but a wind turbine 78m tall and 350m from the nearest home.

According to Uttoxeter Wind Turbine Action Group, "the land was promised as a nature reserve, sports pitches and a waterside haven". AI wanted a turbine instead because, as its director of sustainable construction said, "Ultimately we all have the same goal – preservation of the countryside". (Yes, you read that correctly.)

The area's MP accused AI of "clearly putting profit ahead of the local community":

This company has expected local residents in Uttoxeter to put up with the disturbance of quarrying, such as noise, dust and traffic that comes with it for many years in the understanding that they would return the land as a community facility that was restored to its former beauty. The fact they now want to erect an industrial scale wind turbine that will blight the landscape for years to come sticks two fingers up to the good will and the generosity of the community.

I would issue a warning to any residents in Staffordshire, or elsewhere in the country that if they have a quarry run by Aggregate Industries, there is a chance that any time now they will be faced with an application for a wind turbine. I don’t think Aggregate Industries should underestimate the damage it is doing to its reputation and the relationship it has with the communities around its sites.

The application was turned down last month by Staffordshire County Council. AI said “We think the grounds for an appeal are compelling – and this is something that we’re now reviewing.”

Whilst local people pay the price for quarrying, some people really do benefit

Figures released for the construction industry on Monday showed output falling at its fastest rate in more than three years. Prospects for the industry looked no brighter the next day when the FT reported that infrastructure projects had stalled, and government plans to sell off trunk roads on motorways on long leases to attract billions of pounds in private money - an idea viewed by many as "fatally flawed" - were in "disarray". On the same day, Jersey-registered Breedon Aggregates, "the largest independent aggregates business in the UK after the five global majors", released its financial results in what Peter Tom CBE, its Executive Chairman, called "the worst trading conditions I can remember in my 50 years in this industry".

But Peter Tom himself can cope with the downturn. Whilst local people pay the price for quarrying in their community, and Breedon itself admits that "its activities and operations have a significant impact on the wider social, environmental and economic well-being of the areas in which we operate", some people make a good living from quarries - Peter Tom more than most. Peter Tom oversaw the formation of Aggregate Industries, and was its Chief Executive until Holcim bought it in 2005 for £1.8 billion, valuing the Tom family stake at £29m.

He had "joined what was then his grandfather's quarrying business in Leicestershire. His grandfather had started quarrying in Cornwall but when he sold the Cornish operation..., he moved to Leicestershire to buy Bardon Hill quarry in 1948. [Peter] Tom assumed the reins of the firm from his father in 1985." Now at Breedon Aggregates, where he has a 5% stake worth close to £8m, the strategy "is to grow via consolidation of the heavyside building materials sector". Quarrying has been good for Peter Tom and family, worth an estimated £40m. "I've been in the industry since the age of 16 and enjoy what I do". But then Peter Tom doesn't live next door to any of Breedon's "27 quarries, 18 asphalt plants and 40 ready-mixed concrete and mortar plants"; he lives in Guernsey.

And he's unlikely to be the only aggregates boss missing out on the 'health benefits' of next-to-a-quarry-living. In the case of AI, if its bosses are so keen for a quarry at Straitgate Farm, then let them move here; there's no shortage of houses for sale. It's a great place to live - at least, it was until…

Straitgate groundwater measurements

Initial groundwater measurements taken on 25 January for AI's six piezometers have been supplied and range from 0.17m to 7.65m of water. Although the piezometers are in different positions to the 1990 drillings, the measurements approximate to earlier readings and confirm the same underlying groundwater flow from west to east, as expected. Further readings will be downloaded in due course. 

AMEC survey Straitgate watercourses

An AMEC consultant today walked the Straitgate area assessing where best to position gauges for long-term monitoring of stream flows. Such gauges would not only inform any planning application, but also, if quarrying were to take place, highlight any changes to stream flows or response times to rainfall events as a result. During and after any potential quarrying, streams from Straitgate would legally need to maintain the same flow characteristics, so that wetland habitats in Ancient Woodland and downstream communities prone to flooding would be unaffected. It remains to be seen how this could ever be achieved.

ePSV - for anybody with a penchant for such matters

DCC has clarified with its Materials Laboratory why the Pebble Beds (PBs) have apparently become more durable (LAA, 5.18). PSV is a measure of how quickly a sample of aggregate will become polished, i.e. on a road surface how quickly it will lose its resistance to skidding. Aggregates specified for roads on approaches to pedestrian crossings and traffic lights may require a PSV of 68 or more, whereas for an infrequently used minor road a PSV of 50 would be acceptable.

Only a limited number of quarries produce high PSV material in the UK. The PBs have previously tested in the mid 50s and Straitgate at 53. The 'Mat Lab' has however recently measured the effective PSV or ePSV of the PBs at 60-64 using "a mix of particle sizes from 3mm to 8mm, which provides greater friction levels than a single sized particle due to the greater surface area (with the smaller particles filling the gaps between the larger ones), and is also more durable and resistant to wear from turning vehicles". DCC confirmed that any extra demand for the PBs created by this re-rating would be relatively minor. Most higher risk locations require PSVs of more than 65.

Councillors reject plans for two sand and gravel quarries against officer advice

Councillors have unanimously refused permission for a two million tonne sand and gravel quarry in Fife, despite officers recommending approval. NHS Fife objected, outlining concerns about "noise, dust, the quarry’s proximity to houses and the psychological effects of living next to a quarry" and saying that "residents living nearby, particularly children, could be harmed by dust emissions...".

Questioning whether assurance could be given that dust from the quarry would not cause a single case of lung disease, [a councillor] compared the health risk to that of coal dust and asbestos. She said: “Even with the mitigation measures, there is still going to be a degree of dust. When the wind blows in a certain direction there will be dust on people’s properties and if there is dust on your windows there is dust in your lungs.”

Her concerns echo those of an earlier post here on respirable crystalline silica.

Reasons given for refusal were "cumulative impact with neighbouring quarries, visual impact, proximity to houses, impact on residential amenity from noise and dust, road safety, loss of trees, flood risk, water table issues and lack of proven need". All bar one could of course apply to Straitgate.

Another application, this time to extract 1.4Mt of sand and gravel near Great Yarmouth, was also refused. The planning officer had recommended approval "to address the current shortfall in the sand and gravel landbank" which, at 5.3 years, was less than the 7 years the NPPF requires. No objections were raised by the Environment Agency, Natural England and Broads Authority, but councillors considered the proposal would harm the setting of a listed church and the amenity of nearby residents due to increased noise, dust and traffic. Substitute church for Devon longhouse or Tudor manor house and again all could apply to Straitgate.

Of course for Straitgate, in a county where there are 15 years supply of sand and gravel, not 5.3, there has already been concern shown by the Environment Agency, Natural England, Exeter Airport and hundreds of others before an application has even been raised. For reasons of its own, Aggregate Industries plainly believes these concerns present no barrier to its plans. Time will tell.

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.

What makes building fixed plant at Rockbeare economic now?

In Aggregate Industries' 2010 planning application to process sand and gravel from Venn Ottery and Marshbroadmoor at Blackhill, it claimed that to provide fixed plant at Rockbeare for the combined 1.8 million tonnes "would be uneconomical in terms of the investment required".

It now seems unlikely that AI would be able to use Blackhill to process material from any future quarry at Straitgate. And since fixed plant cannot be sited at Straitgate, this now only leaves Rockbeare. But with the recoverable resource no greater than 2.3Mt, and much less allowing for realistic constraints, how can it be economic for AI to build plant at Rockbeare now, when it wasn't in 2010 for 1.8Mt?

Is it because Ottery St Mary is to have the privilege of becoming AI's centre for sand and gravel production for decades to come? Or is it that AI was not being entirely straight with DCC in 2010, when it obviously suited them to haul material across Woodbury Common? If the former, then local people deserve to be informed by AI of its long-term ambitions for their environment. If the latter, then how can people be expected to trust what AI says next time in any application to quarry Straitgate Farm?

What if aggregate could be manufactured instead - using 98% waste?

Now it can. Novagg, "hailed as the world’s greenest lightweight aggregate", is made using unsorted mixed coloured waste glass combined with other industrial waste. Developed in collaboration with Imperial College, "work is now under way with several multi-national companies to put Novagg on the commercial stage in a bid to become the global ‘green’ construction material of choice".

This is just the sort of advance that makes forecasting aggregate shortfalls over the next 20 years so uncertain, and will in time reduce the need for the sort of quarry AI is planning at Straitgate Farm.

Of course, AI will know all about these advances. It will know that this is the way its industry has to move. It will know that consuming farmland on this ever more populated island is not sustainable. And, as if to prove as much, in 2010 AI bought a majority stake in a company using fly ash to make lightweight aggregate. Lytag "provides an excellent alternative to natural, quarried aggregate, being strong, light and consistent". AI's then CEO (now Chairman) said "as modern construction continues to evolve, fly-ash and Lytag are increasingly being used and specified for a range of products and projects". A new "state of the art facility" next to Drax Power Station will be finished this summer and will "displace the need for 400,000 tonnes a year of newly quarried aggregates".

So, DCC's Minerals Plan to 2031 should acknowledge the advances being made in construction materials and the long term decline of sand and gravel, not allocate more and more land for quarrying. Products such as Novagg and Lytag reduce the need for aggregate extraction, divert material from landfill and preserve the natural landscape - to not use them more widely would appear a no-brainer.

Starlings - 1000s of them

Jeff Bevan

Starling numbers have declined, so much so that the RSPB has put the species on their "red list". But a new habitat has come to the rescue. The RSPB claims "quarries really are providing a refuge and important over-wintering habitats for this familiar yet struggling bird, up and down the country". "Always looking to exploit new areas, starlings, along with other wildlife, are wising-up to the benefits that both active and restored quarries can provide".

It is reported that starlings frequent Gill Mill Quarry in Oxfordshire in their thousands. There are 20,000 at another quarry in Nottinghamshire, 10,000 at a quarry in Yorkshire, and 10,000 at Aggregate Industries’ Warmwell quarry in Dorset. But also "quarries continue to be a 'home of choice' for birds of prey", and nearer to home it is established that gulls love to visit Blackhill Quarry.

Which is all good news for starlings and other birds, and plays to the nature loving facade that quarry companies like to hide behind. It is not good news if you have to convince an airport that the threat of siting a quarry directly under its landing approach is benign.

The Head of Flight Safety at the British Airline Pilots Association explains that "the problem is when a plane strikes a very large bird, or if they are flocking, and there are multiple strikes". Therefore, in terms of birdstrike risk, along with gulls, starlings are one of the more hazardous species, and the worst birdstrike accident in history was caused when an aircraft flew through a flock of them.

So that's another job for AI's consultants: A Bird Hazard Management Plan, not only for a quarry's lifetime, but also for ever after - because, in digging out Straitgate, AI would leave a body of water and increase the risk of birds. If AI can't convince Exeter Airport and the CAA that this water would pose no additional threat of birdstrike to overflying aircraft then it's game over and it will have to look for a new site: "The aviation industry, be it the airport itself, the MOD or CAA, has never lost a public enquiry regarding an objection if an unacceptable birdstrike risk has been predicted from a development."

Does AI want to play God?

The planning shake-up means different things to different people. To Aggregate Industries, or at least its Head of Planning and Estates, "Reform of the planning system is an opportunity to harness the full potential of quarrying and other development to create a more diverse landscape".

Has AI assumed the role of the Creator? Isn't quarrying about supplying the construction industry and making money? In the same vein he adds:

Policy recognition that the landscape and its habitats are not natural but have evolved from land management practices would take the emphasis away from preservation and allow the full potential of government, developers, landowners and conservation bodies to be properly harnessed for the creation of a more diverse and resilient landscape.

It is the same view he puts forward in another article:

The ‘natural’ environment we enjoy in the UK is anything but natural. It is the result of largely unregulated development and land management over thousands of years.

Landscapes not natural? They are a good deal more natural than a quarry with excavators ripping out the life and guts of the land, or the industrial development that inevitably seems to follow. Landscapes may have been influenced by land management, but has he forgotten his school lessons on weathering and tectonic plates? It is alarming that a cement giant wants to be at the right hand of landscape creation; all too predictable that it wants attitudes to shift from preservation. There's more:

Diverting resources from ever more onerous investigation, recording and mitigation into the creation of new landforms and habitats would be far more productive. 

Forget those "onerous" checks then - just start digging to create new landforms and habitats. And as if that's not enough, AI has something to say on interaction with local people too:

Those who have engaged with local communities know that genuine and open consultation can lead to positive outcomes for both community and applicant... In return for more control over the planning process, local communities will need to assume the responsibility to guide and approve rather than just oppose. Applicants need to invest more time in helping communities to do just that.

That's alright then. With AI helping us to approve its plans and with "positive outcomes" for the community, we should obviously welcome it to Ottery St Mary to remodel our landscape and our habitats. In a different article, complaining about the "mind boggling amount of bureaucracy" involved in running a quarry, the same spokesman is quoted as saying:

We need a flexible, light touch system as these separate regulations lead to uncertainty for owners and investors who back the sector.

This may be, but in digging test pits at Straitgate Farm for example, AI had to be reminded to follow the regulations. And how thorough are the stretched authorities in enforcing the rules anyway? If there's to be any "light touch" then let it be upon the planet.

It is disturbing for mere mortals to hear such views on landscape reorganisation and light touch regulation being touted by Aggregate Industries. Disturbing, but hardly surprising.

Straitgate Farm, Straight-gate Farm, Great Street Gate Farm... Straitgate Quarry?

There's an 1801 map of the area that we were kindly pointed towards at the British Library's Online Gallery. It's a surveyor's draft for the Ordnance Survey map of 1807. Although the field boundaries are not accurate (there was no intention to publish them on the final map), it is still interesting to see it overlaid on today's Google Earth. The field boundaries are recorded on the tithe map of 1843.

It is also interesting to see field names, listed here on a Schedule for Great Street Gate Farm in 1870.

These emotive maps of the past, giving a flavour of what the area looked like up to 200 years ago, won't mean anything to a hungry Swiss Aggregates Giant - it doesn't care about our local history. But Holcim and Aggregate Industries ought to move with the times and progress to a more sustainable and environmentally acceptable business model, using increased proportions of recycled and secondary aggregates for example, before gouging out and scarring our beautiful and historic land.

Anyone who bought a house near Straitgate Farm "have only themselves to blame"

An Ottery St Mary Town Councillor has repeatedly claimed that residents around Straitgate "must have known all about [the threat of quarrying] when they purchased their properties". Would they really "have known full well that [AI] owned the land and one day would extract minerals from it"?

It may have been common knowledge to some local people, particularly farmers, that Straitgate Farm was owned by AI, but to others and those moving into the area from further afield it was not.

A prospective house purchaser would normally instruct a solicitor to ensure good title and to uncover any issues that might affect the enjoyment of their property. A conveyancing solicitor is expected to advise their client that the Local Authority Search is performed only against the property they are purchasing, not against adjoining land or the wider area, and that they should therefore contact or visit the local authority to ascertain what plans there might be for the locality. Indeed, a solicitor who does not advise a client of the limitations of the local search can be held liable for negligence.

A solicitor would not necessarily be expected to make enquiries, or advise the purchaser to make enquiries, of the Mineral Planning Authority, unless forewarned in pre-contract documentation, even for a property next to open farmland.

If a buyer had received such advice from their solicitor and visited EDDC, would they then have found out about Straitgate Farm from the Local Plan? Not necessarily. Since 2004 Straitgate has not been in DCC's Minerals Local Plan. Before that it was highlighted as a Mineral Consultation Area. Prior to 1979 the area again had no designation.

Could a buyer have made their own enquiries? Of course, but with all manner of things on their mind when moving house and with a solicitor to ensure the property is unencumbered, they might be forgiven for not suspecting that a nearby dairy farm could be harbouring a future sand and gravel quarry, or that English China Clays had bought the below surface rights of the surrounding land.

Generally, a prospective buyer cannot hope to know the owner, the intentions of that owner, or the permissibility of those intentions, for every piece of nearby land before they buy a house. The number of house purchasers in the area in recent years unaware of the quarry threat have demonstrated as much. Just as people living along the HS2 route have found out, home ownership can be a 'can of worms'. In their case they can at least attempt to claim compensation if their property is blighted; people living next to a sand and gravel quarry foisted upon them by Aggregate Industries cannot.

A good news story from DCC

Following our earlier post, DCC's Minerals Officer has notified us of a press release closer to home from Devon Wildlife Trust, showing that, despite the National Trust's unsuccessful proposals for quarries in Shropshire, restoration of a former quarry can indeed be successful. So, for balance:

Devon Wildlife Trust have acquired the recently-restored Meeth Quarry near Hatherleigh for management as a nature reserve. The mineral operator, Imerys, had restored the site in accordance with their planning permission prior to putting it on the market, with the restoration having biodiversity as its main aim as illustrated by the approved plans.

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.

Would a 4000 signature petition help?

The National Trust had wanted to buy Lea Quarry North at Wenlock Edge, a SSSI in Shropshire, from Aggregate Industries to "provide diverse opportunities for people, heritage, biodiversity, tourism and the economy". It was sold instead to Edge Renewables, who "chip wood from sustainably managed forests for renewable energy biomass incinerators". The National Trust opposed the retrospective planning application from Edge Renewables, as did Natural England, Shropshire Hills AONB and over 4000 others by way of petition. However, planning officers recommended approval and yesterday councillors voted to grant permission to the renewable energy business. The petition made no difference at all.

2012 - "the lowest year for aggregates and concrete sales since 1965"

That's according to the Mineral Products Association, the trade association representing 90% of aggregates production in the UK. The MPA sales survey results showed a fall of 9% in aggregates, cement and ready mixed concrete markets in 2012. Road construction fell by 44% in the first nine months of 2012 compared with the same period of 2011. How foolhardy then, following the lowest aggregates sales since 1965 - ironically the year that all our problems started when English China Clays bought Straitgate Farm, that AI is still pushing ahead for a brand new sand and gravel quarry.

Grading analysis results from Straitgate

Grading analysis results have been supplied by Aggregate Industries following its recent activity at Straitgate Farm. The test pits had an average of 9.3% silt, 28.0% sand and 62.7% gravel. The six boreholes across the site had an average of 14.6% silt, 32.5% sand and 52.9% gravel.

Any questions relating to the grading results can be directed to AI's Head of Geological Services. Contact us for his details.

Secondary vs. Primary

The left pile: secondary aggregate - a by-product from china clay (kaolin) operations dumped for over 250 years as waste in huge amounts across Cornwall and Devon; the right pile: primary aggregate - a finite virgin resource sitting under Straitgate Farm. Two different materials we are told; different properties - physically, chemically, economically.

Whilst DCC in its Local Aggregate Assessment said "Devon has the capacity to support increased production of secondary... aggregates", it also said that "limited spatial occurrence" and "technical requirements" may constrain their use.

In evidence to the Competition Commission, however, Aggregate Industries said that whilst "in Cornwall and Devon alone there was about 600 million tonnes of secondary aggregates already available with about 40 million tonnes more being generated a year", its customers were "increasingly able, willing and prepared to use secondary and recycled aggregates". AI added "secondary and recycled aggregates now accounted for between 25 and 30 per cent of the current market and were a substitute for primary aggregates in the vast majority of cases. AI used secondary aggregates in its own production of [ready mix concrete] and other products."

The aggregates levy, currently £2 per tonne, was introduced by the government in 2002 not only to "address the environmental costs associated with quarrying" but also to support "the use of alternative materials such as recycled materials and certain waste products". Encouraging local use of secondary aggregate would have the advantage of extending reserves of sand and gravel whilst also reducing the 'mountains' of tipped waste across Cornwall and Devon. Is Devon's Mineral Planning Authority doing enough to achieve this?

Admittedly, not all china clay waste is suitable - nine tonnes of waste are generated for every tonne of china clay produced - but for the right quality of granite fraction (stent) there has been a "long history of satisfactory use in ready mixed concrete over much of Cornwall and Devon". In addition "An assessment of the specifications and standards available demonstrates that there are a significant number of applications available for the use of China Clay waste derived aggregates. While many secondary materials are used in low value applications such as fill, China Clay waste derived aggregates are suitable for a number of higher value applications including use in concrete and bitumen bound products."

Furthermore, it's now finding applications elsewhere. In 2006 the construction of One Coleman Street, a prestigious commercial building in London, was "the first major use of china clay stent coarse aggregate outside the locality of its production in the South-West" and "demonstrated the feasibility of using 100% secondary coarse aggregates in a large scale project remote from the source of aggregate". The stent aggregate concrete "cost a little more" due to the "transportation and testing costs" but this was partially offset by the stent being "exempt from the UK aggregates levy" and "if used more often for future projects there would be less need for extensive testing". The project won the 2007 Concrete Centre Award for Sustainability. AI will know about it since it supplied the aggregate. It will also know about the construction of the Olympic Park, where it supplied "secondary aggregates arising from the production of China Clay".

So, if the economics can work supplying London, why not Devon?

With existing supply agreements coming to an end, "IMERYS Minerals Ltd are actively developing the growth of their secondary aggregates (china clay waste) products from Cornwall and are currently seeking partners to realise the full potential of the materials in the markets they serve". With its new Minerals Plan, maybe DCC should work with Cornwall to facilitate and encourage this. And how about Devon's own levy too, on primary aggregate extracted from the Budleigh Salterton Pebble Beds?!

Construction industry ‘faces 10 more years of pain’

Construction output in the three months to November was "down 9.8%" on the same period in 2011. Furthermore the BBC reports on an industry lobby group that "doesn't anticipate the industry returning to its former levels until at least 2022". Something DCC should bear in mind when forecasting aggregate shortfalls for the years ahead.

Can Straitgate produce a ROI of 8% for Holcim?

Naturally, the question of financial return is central to whether Aggregate Industries and parent Holcim ultimately take Straitgate forward to a planning application. We have argued before that the commercial viability of a quarry here can only be marginal at best, and is a factor not yet assessed by DCC despite the NPPF saying "Pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. Plans should be deliverable." Holcim is now however working to a new financial benchmark.

A summary of the initial hearing held with AI on 16 May 2012 for the Competition Commission makes clear that "Holcim had recently publicly announced a new cost-cutting plan in order to improve the group’s profitability. Holcim needed to achieve an overall return on investment (after tax) of 8 per cent, while AI’s operations were only currently achieving a 2.7 per cent return (before tax)."

Yet "there had also been significant increases in the production costs, particularly for fuel and energy, for these products. Increased taxation such as the aggregates levy and carbon taxes had also raised costs." In December Holcim announced it was "to accelerate a restructuring program and write off 410 million Swiss francs of fixed assets in Europe". 

Investigations by AI and its consultants will uncover more about Straitgate's commercial potential, but here's a list of some of the other costs that AI will need to consider, over and above operating costs, before breaking the ground at Straitgate Farm once again:

Cost of preliminary work: surveys, consultants, boreholes, test pits, material testing

Cost of planning permissions and appeals; legal costs; professional fees

Cost of public relations: exhibitions, local liaison

Cost of site infrastructure: weighbridge, offices, etc.

Cost of access modifications: road modifications, land purchase required for access

Cost of a 15 mile round trip for each load of as-dug material transported to Blackhill, if permitted. If not

Cost of moving and constructing new plant at Rockbeare if permitted

Cost of acceptable standoffs from homes thereby reducing the recoverable resource

Cost of protecting the setting of the listed Straitgate Farmhouse thereby reducing the resource

Cost of restricting excavation to 1m above highest water table as enforced elsewhere

Cost of downstream flooding mitigation - in perpetuity

Cost of preserving stream flows to wetland habitats in Ancient Woodland - in perpetuity

Cost of protecting private water supplies

Cost of restoration (if it were to ever get that far)

Cost of a community fund for local projects in compensation to local people

Less of course what AI can sell the site for afterwards, which could be significant if industrial development were to be permitted, or not, as in the case of Foxenhole where 38 acres sold for £300k last year - no more than the going rate for farmland.

Would Holcim accept a lower return in order to maintain local sales control? Would a Swiss-based multinational care? In the end the limited resource and the cost burdens may well undermine the commercial rationale for proceeding, particularly if Holcim's 8% target is to be met. 

DCC is overstating the 'recoverable' resource at Straitgate by more than 50%

We have long argued that the resource figure for Straitgate with which DCC went out to Public Consultation, up to 3.6 million tonnes (Mt) giving an expected lifetime for the site of about 10 years, was inaccurate and misleading. English China Clays' "Report on the reserves of Pebble Beds at Straitgate Farm", December 1990, and appendix, substantiates this claim.

DCC would have long had a copy of this report. We however have only just seen it, kindly supplied by Aggregate Industries (see note below). The report analyses results from 24 boreholes drilled across the site in 1990. Only limited geological information existed beforehand, and subsequent resource calculations are based upon this data. 

From the report it is clear that 2.311Mt is the maximum resource figure at Straitgate that DCC should have consulted upon, as this is the net tonnage recoverable above the water table from "sub area A" (section 5.3). There was no reason for DCC to ever think Straitgate could be quarried below the water table, particularly considering airport safeguarding, and in fact at Blackhill "to protect the hydrology of the area it [was] proposed to cease excavation at 1 metre above the maximum level of the water table". Would the hydrology and the receptors around Straitgate Farm deserve any less protection?

And even 2.3Mt is based on a number of assumptions, some of which are now unrealistic:

A "working margin of 5 metres behind the tree screen and 15 metres around Straitgate Farmhouse and access" [BGS recommends 250m stand-offs]; A "working margin of 15 metres" from the A30 [unrealistic]; "Water levels are based on July readings" [the water table is up to 1.4m higher in winter]; "No allowances have been made for face angles or haul roads".

Reducing the depth of deposit by say 1m for the seasonal movement in the water table could cut the resource by c.0.4Mt. Restricting excavation to "1 metre above the maximum level of the water table" as at Blackhill loses another c.0.4Mt. Sensible stand-offs from properties, another c.0.2Mt. So even 2.3Mt can quickly become c.1.3Mt. Of that, gravel (the component of value) makes up about 70%.

And remember, DCC was originally talking about 8Mt at Straitgate, even though it had been known for many years that the eastern half of the site was "geologically more complex". Here, the Pebble Beds are not only covered with a deep outcrop of sandstone, but a large portion of them is also underwater.

So if we are going to talk about destroying a farm and violating the East Devon landscape, creating something like the photograph above, let's consult on the correct figures so that local people know exactly what's involved and are able to make an informed response. We should then consider how little economically recoverable sand and gravel there actually is at Straitgate Farm, and debate whether that's a price worth paying for the loss of so much.

Note: In relation to ECC's report, AI wishes to point out that "it covers the first detailed borehole exploration and resource analysis in 1990 and that the estimates quoted therein do not reflect modern planning conditions or economic expectations - a finite, modern resource calculation will be undertaken following receipt of all expert opinions into hydro-geology, landscape, noise, ecology etc etc probably this time next year (ie as most studies need a full set of seasons to be valid)."

AI's conundrum

Labels have now been assigned to categorise previous posts on this blog, and are sorted in the sidebar by frequency. Unsurprisingly the labels Exeter Airport and birdstrike are near the top.

Aggregate Industries is busily performing tests on its gravel, but what is it doing to reassure Exeter Airport that, if it quarries Straitgate, it isn't going to leave behind a large body of water directly beneath its flight path, attracting birds and increasing the risk of birdstrikes? After the wettest year on record for England, it's hard to imagine how a quarried void at Straitgate could not fill up with water, or how gulls or other birds would not be attracted to such water, as at "Seagull Pond" at Blackhill Quarry.

Gulls at Blackhill Quarry

So it may be that AI cannot provide the airport with that reassurance. After all, in order to replace the groundwater storage being removed at Straitgate, the Environment Agency (EA) would want provision made to store water run-off to prevent flooding downstream. This was the condition made by the Devon River Authority at the time of the 1967 planning application: a 49 acre lake and overflow weirs for "balancing flood flows".

The conundrum for AI is that if it were to dig a hole at Straitgate, the EA would want a body of water, the Airport would not, and the company would have difficulty stopping one forming anyway. Therefore for AI to proceed any further, it needs to know how it would overcome this seemingly insoluble predicament and give the answer to DCC, whose Minerals Plan could be found unsound if it continued to insist on Straitgate Farm being a Preferred Site when there's clearly such a big question mark hanging over its deliverability.

From the Airport's perspective, whilst last year was the safest year on record for air travel, it is understandable that it is protective of its airspace. Birdstrike incidents are recorded for each airport in the UK and the data is publicly available. DCC has been warned that "Under the Air Navigation Law, it is a criminal offence to endanger an aircraft or its occupants by any means". Birdstrike incidents can sometimes have terrible consequences.

Just for fun because it's Xmas...

Merry Christmas and a Happy quarry-free New Year

Update

Aggregate Industries has kept us informed of its investigations at Straitgate Farm. Grading analyses (deriving silt, sand and gravel proportions) have now been performed on the raw material removed from the test pits. Results have been supplied and "continue to confirm the quality". Further physical and chemical tests have been arranged. Piezometers have been installed in the six boreholes, and data-loggers are expected to be fitted early in the new year to start recording groundwater levels. AI has commissioned AMEC to act as its hydrogeological consultants.

Two more quarries that didn't get restored back to farmland

Two more novel uses for old quarries - a 15MW solar energy 'farm' with 62500 panels, and a round-the-clock testing ground for articulated dump trucks. Not perhaps the restoration plans that local people had either hoped for or expected. Not farmland. Not nature trails. But Aggregate Industries is not a charity. If it quarried Straitgate, who could blame it for wanting to persuade DCC in the future that the county no longer needed the woodland clearing with picnic area, or footpaths with education boards, detailed on the imaginative and colourful plans used to win permission way back in 2014. Who could blame it for arguing that what Ottery really needed was, for example, an aggregate recycling centre on the old Straitgate Quarry site? Would the company listen to local people? Did it listen to "Objectors [who] had pleaded to AI to abandon its [78 metre] wind turbine proposals for Hulands Quarry"?

AI calls for more road spending

Just as a turkey might sponsor a campaign calling for a rethink on how we celebrate Christmas, Aggregate Industries is sponsoring a CBI report calling on government to support greater private investment in the road network. Lobbying like this should surprise no-one, but the tab for increased road investment, and the aggregate it requires, would have to be picked up by somebody, and if not directly by the state then in higher charges for road users. The CBI is proposing a similar model to that used in the water and rail industries, but is privatisation, profits and road tolling really the answer? We know where water charges and rail fares have gone.

AI's chief executive officer, Alain Bourguignon, writes in the report's foreword "By transferring the management and maintenance of essential road infrastructure to long-term investment vehicles, we could see far better planning, procurement and design of the assets, leading to far better outcomes for all stakeholders." And far better business for AI of course. It's a "no-brainer" according to AI's blog - just not for the communities next to any one of its asphalt, concrete or quarry operations.