Dust impact on observatory stops quarry extension

Mhardcastle

Dust and noise - two of the main impacts people think of in relation to quarrying. And while noise is a nuisance, dust can be a killer.

Small particles are a particular problem. They can travel large distances and can be damaging to human health even in low concentrations over prolonged periods of time. Terms PM10 and PM2.5 are used to describe particulate matter of 10μm and 2.5μm in size respectively (a human hair is about 50μm in diameter). A quarry can generate significant amounts of this harmful dust over its lifetime, particularly during dry conditions. We’ve written about this dust - Respirable Crystalline Silica - before. HSE advice is that "all RCS is hazardous", and that workers should be told that "very fine quarry dust can cause silicosis, which leads to disablement and early death". The US Health Department warns "Residents near quarries and sand and gravel operations potentially are exposed to respirable crystalline silica". One study concludes "there seems to be a risk also in groups exposed to lower levels [of respirable quartz]. There is no consensus how low an acceptable risk level ought to be".

Keeping these facts in mind, it’s interesting to note that plans for a sand and gravel quarry extension in Hertfordshire were recently refused on appeal - because of this PM2.5-PM10 dust. Perversely, and despite objectors' fears, not because the planning inspector was concerned about the impact of prolonged exposure to this airborne carcinogenic dust on people living as close as 75m away, but because he was concerned about the impact the dust might have on an observatory - 550m away.

The quarry company had put forward a Dust and Air Quality Management Plan (DMP) which claimed to “proactively” manage the dust. Objectors, however, had little confidence in these measures, and nor did the University of Hertfordshire’s Bayfordbury Observatory, who were "...concerned about the potential for a significant loading in PM dust in the air for significant periods of time".

The Inspector was also unconvinced the DMP would work:

I am also concerned about its effectiveness in limiting harmful concentrations of PM2.5-PM10 dust, given their long suspension in the air and ensuing unpredictability and that monitoring and any preventative action would need to be the subject of constant surveillance... Responding to visible signs of dust emissions in dry, windy conditions would plainly not be effective as a preventative measure… For all that the DMP would provide for an enhanced level of control over dust emissions, given the risks and uncertainties that I have outlined above, I cannot be confident that it would prove to be fully effective... I conclude that the proposal would give rise to an unacceptable risk of harm to the operation of research equipment at the observatory, having regard to dust.

But when the planning inspector recognised the "long suspension in the air and ensuing unpredictability” of PM2.5-PM10 dust, and the harm such dust might cause an observatory 550m away, why did he not think that over prolonged periods it might be harmful to people too, living just 75m away? Were his hands tied by planning guidance? Did he put too much faith in consultants' reports? The observatory may have been particularly sensitive to dust, but so too are children, asthmatics, allergy sufferers and the elderly.

Whatever his reason, he refused the appeal anyway, and people nearby were spared prolonged and elevated dust emissions; others across the country continue to suffer. 

Since PM2.5-PM10 dust can travel long distances, planning authorities should be pushing quarry companies to act in a more precautionary manner, pushing for greater stand-offs from nearby communities, pushing for more rigorous dust mitigation. As DCC's Sustainability Appraisal warns, "due to a changing climate there is the potential for the impact of noise and dust on sensitive receptors to become more intense. Hotter summers will provide conditions that will produce additional dust, and people will spend more time outdoors and leave the windows of dwellings and workplaces open for longer". Planners' attitude to dust and the harm it can cause has to change.

PS. On the subject of consultants' reports, prepared for and paid for by quarry companies, and how much trust can be placed upon them, it may come as no surprise that the Dust Impact Assessment for the above quarry extension claimed "any impact associated with dust generation upon the observatory is considered to be low". The Planning Inspector, on the other hand, said "given the apparent importance attached to the observatory’s research activities, any harm arising from operations, notably in relation to PM10 dust, must, I conclude, have the potential to be severe". Low or severe? They can't both be right.

Update

Archaeological work at Straitgate Farm is ongoing. Further investigation in the areas showing evidence of Iron Age huts has however been on hold - the trenches are full of water. There appears to be a tail-off in archaeological evidence moving further away from the Iron Age settlement, but a few new prehistoric features are being uncovered that had not shown up in the geophysical survey. No evidence has so far been found of the prehistoric boundary running through the site, but this would have to be explored further should planning permission eventually be granted.

Consultants AMEC have just uploaded another round of groundwater measurements from the 11 boreholes around the site, and now have a full 12 months of data from all of the boreholes. AMEC will continue to monitor groundwater levels, and will be producing a report for AI in the new year. They have also sampled water from three boreholes and three springs to test water quality, and continue to take regular stream flow measurements.

Miscellaneous

1. "We did not give up and now this battle has been won.”

Plans for an Aggregate Industries' concrete plant 'directly opposite' The O2 in London have finally been rejected after a three year campaign.

Part of AI's undoing, according to The Secretary of State, was:

There is little evidence that thought has gone into alternative layouts and arrangements of structures to take account of the site’s environmental constraints or wider context. Indeed, there is little identification of these, or opportunities, unlike the analysis carried out for the Objectors... [12.36]

A warning that environmental constraints for any application must be properly addressed, even by AI.

2. Gravel switch: crushed rock is the preferred tonnage as sourcing changes

In an article in Mineral Planning, on the effects of the NPPF, the director of planning for the Mineral Products Association admits:

Operators have been eking out reserves they already have. The last thing they have wanted is to go anywhere near a planning authority... [as a result] MPA survey figures suggest both producers and consumers have adapted by switching from sand and gravel to crushed rock.

On the subject of planning, he bemoans that:

Concern over vulnerability to legal challenge is leading to an ever more precautionary approach by regulators. This results in delay and unnecessary costs in providing superfluous information to support plan allocations and planning applications.

Superfluous information? Is that really the industry's thinking when responding to its impact on people, groundwater, ecology, history, endangered species, dust, noise, traffic, etc?

3. Silica Particles from Frac Sand Mining Put Tens of Thousands at Risk

An article by Environmental Working Group claims that thousands in the US are exposed to potential health risks from silica sand mining:

Research has shown that these particles can degrade air quality as far as 750 meters away, leading to a variety of serious health problems, particularly in children and other vulnerable populations.

Dust, and its effects upon health, is a continuing concern around quarry sites in the UK; we have written a number of times in the past about Respirable Crystalline Silica.

4. Business and society: defining the 'social licence'

An article by John Morrison in The Guardian argues that:

Social licence can never be self-awarded, it requires that an activity enjoys sufficient trust and legitimacy, and has the consent of those affected. Business cannot determine how much prevention or mitigation it should engage in to meet environmental or social risk – stakeholders and rights-holders have to be involved for thresholds of due diligence to be legitimate (sometimes even if these are clearly determined in law).

5. The resource curse of corporate social responsibility

A blog on the impacts of mining across the world, by a PhD candidate at the University of Bristol, tackles the subject of corporate social responsibility or CSR:

Often, CSR in the mining industry is little more than a public relations exercise, with no tangible reality to support its elaborate rhetoric.

6. Prehistoric boundary

For anybody interested in learning about Prehistoric Boundaries - like the one thought to run through Straitgate Farm - this English Heritage document explains more.

The cumulative effect

Let’s summarise what’s happened since 2012, when DCC decided that Straitgate was the best of 10 sites in East Devon to put forward as a Preferred Site for sand and gravel in its new Minerals Plan.

In 2011/12, DCC performed a "detailed appraisal" of each of the 10 sites to find those with "the least constraints and most likelihood of potential delivery". It found issues with all of them - but apparently Straitgate (S7) was the only site without a ‘showstopper’; of course, it was also the only site owned by Aggregate Industries. DCC's belated Sustainability Appraisal - a process which did not inform the rejection of the alternative sites as it should have - found even more constraints. In fact, Straitgate had more "significant negative impacts” than almost any other site; the Environment Agency remarked "It is apparent from the SA that some of the excluded sites may [be] preferable in environmental terms".

Since DCC’s original appraisals, Straitgate’s list of issues has only grown. We now know that:

Natural England, the Environment Agency and Exeter Airport all have unresolved concerns;

Part of Straitgate has now been designated by the Environment Agency as an SPZ - Source Protection Zone - indicating its importance to the drinking water supplies at Cadhay. The EA had made it clear before the new SPZ that "if [Straitgate] is shown to be a significant part of the catchment for the water features near Cadhay, its deliverability as a viable site would seem unlikely”;

Cadhay Bog, with its ancient woodland and wetland habitats, is now recognised in all likelihood to have been wooded for up to 10,000 years, being a remnant of the 'wildwood' that colonised Britain after the last Ice Age. According to SLR, AI’s consultants, Cadhay Bog is “in very good condition” with "significant biodiversity interest” and "the ecological site most at risk from the proposals”;

Straitgate has a population of dormice - a European Protected Species; AI will need to convince Natural England that a quarry and the removal of almost 2 miles of ancient hedgerow dormouse habitat is "preserving public health or public safety or other imperative reasons of overriding public interest including those of a social or economic nature and beneficial consequences of primary importance for the environment”, has “no satisfactory alternative” and “will not be detrimental to the maintenance of the population of the species concerned at a favourable conservation status in their natural range”;

And now, the fields at Straitgate are also revealing signs of Iron Age settlement that will probably require a very full archaeological excavation before any quarry could ever take place.

Any of these new developments might have been considered ‘showstoppers' in their own right, but when you combine them all, and then add them to the ones we knew about before - 100 people and 3 farms relying on the site for drinking water, increased birdstrike risk to aircraft from ponding, visual impact on AONB, flooding, effect on Grade I & II listed buildings, off-site processing using public not internal haul roads - then the cumulative effect of any quarrying makes Straitgate look a non-starter. Sometimes you wonder whether DCC couldn't have picked a more constrained site if it had tried.

Of course, if DCC does go forward with Straitgate as its preferred choice, it will somehow have to persuade a public inspector of the soundness of relying on a site with potentially as little as 6 years, or less, of sand and gravel... and a list of issues as long as your arm.

Settlement of Iron Age roundhouses at Straitgate?

Evidence of a prehistoric settlement of Iron Age roundhouses from over 2000 years ago was one of the last things Aggregate Industries would have wanted to find from its archaeological surveys at Straitgate.

Michael Murray

The Devon Historic Environment Records for the area, kindly sent to us back in 2012, had suggested there might be - based on an excavation in 1996-7 next to Straitgate Farm, referred to as the 'Long Range excavation'. This archaeological dig was one of the eight site excavations undertaken in advance of the new A30 between Honiton and Exeter, and revealed the presence of Iron Age roundhouses and pottery from around 400-100 BC, as well as finds from the early Neolithic period. Two of the roundhouses were indicated by evidence of complete penannular gullies - circular-shaped gullies formed either by rainwater dripping off the end of the eaves and eroding a small trench or where a drainage trench has been cut to carry rainwater away from the walls. These are documented fully in Prehistoric & Roman Sites in East Devon: The A30 Honiton to Exeter Improvement DBFO, 1996-9 (Wessex archaeology report).

Many more of these structures are thought to lie in the fields at Straitgate, after the geophysical survey last year revealed 10 or more circular or part-circular anomalies. Investigations at Straitgate will add to the 'Long Range' data, and will give a fuller picture of what life was like for our predecessors - in a hill-top settlement overlooking where Ottery St Mary stands today.

Archaeology is rarely a ‘showstopper’ - many think Straitgate already has plenty of those. But as part of Devon’s history, Straitgate's past will have to be fully explored and documented before any of it is lost to a Swiss multinational cement conglomerate.

For maps of the historic finds in the area, contact Devon County Council Historic Environment Team.

Archaeology at Straitgate

A group of local people met with archaeological contractors and DCC archaeologists on the fields at Straitgate Farm yesterday. AI and its consultants, SLR, were also present.

The archaeologists from DCC and the archaeological contractors spoke enthusiastically about a landscape that has been extensively occupied and farmed on and off over thousands of years. Signs from a number of prehistoric dwellings have been revealed, from the Iron Age to as far back, possibly, as the Neolithic period. Finds so far include pottery, post holes, drip gullies and enclosure boundaries. There is more archaeology than many had expected, and AI could eventually be called upon to excavate, survey and record much larger areas - if it were to ever secure planning permission.

Such evaluations would further add to AI’s running bill of costs. With so many constraints already identified, sand and gravel from Straitgate is unlikely ever to be won cheaply.

Archaeology and openness

Even after 55 trenches have been dug, up to 98% of Straitgate's "rich historic landscape" stands to be lost without any further archaeological investigation.

It remains to be seen how much is disclosed at a meeting on site this week, but, to date, the details of the archaeological survey have been more closely guarded by Aggregate Industries than any other part of the pre-planning investigation work. No plans, no method statements, not even - until recently - the number of trenches. Why? Is AI worried that any publicity could turn the dig into something bigger? Worried that more of the site could need to be surveyed?

Local people will have seen the news last week about the hoard of 22,000 Roman coins unearthed by a metal detectorist near Seaton. Local people may also remember the news a few years ago - England's western-most Roman town uncovered. The person leading that investigation is quoted as saying:

I'm hoping that we can turn this into a community excavation for everyone to be involved in, including the metal detectorists

Because archaeology should be open. History belongs to us all.

Dormice and hedgerows

Dormice are a species on the edge of extinction and are heavily protected - there is a known population at Straitgate. For those concerned that archaeological trenching will destroy any of their hedgerow habitat, the method statement agreed between SLR and DCC will have made clear that the contractors cannot remove any length of hedge without prior checks for dormice or their nests by a licensed ecologist. Obviously, any hedgerows that are removed must be rapidly restored to ensure habitat connectivity is maintained; planning permission is not a done deal - these are pre-planning investigations.

Aggregate Industries plans to grub up almost 2 miles of these ancient Devon hedgerows - some 4 metres wide or more. There are strict rules in providing compensatory habitat for dormice, and earlier this year AI planted trees around the site. Since the company has now revised its extraction area, a long length of 'hedgerow' is now in the wrong field; referred to previously in - Aggregate Industries' answer for the dormice - an 'escape route'. This entire length will now need to be replanted in the right place; one year of growing time has been lost.

By our reckoning, AI's newly planted area of saplings barely matches the area of ancient hedgerow at risk; saplings that will, by the way, take many years to provide any sort of dormice habitat. This is what Natural England and an ecological consultant say on the subject of compensation, respectively:

Area provided should exceed losses in potentially high impact cases as the acceptability of new habitat to dormouse is not predictable… Planting of replacement habitat should begin as early as is practical in the works programme as it will take several years before areas become utilisable by dormouse both in terms of structure and food supply.

In fact, where significant impacts are predicted there will be an expectation that compensation will provide an enhanced habitat (in terms of quality or area) compared with that to be lost. Compensation should also remedy any loss of connectivity brought about through the development.

Digging a quarry can’t be anything other than high impact to dormice. So where's the enhanced habitat?

RT @Greebobek Baby #dormouse samples blackberries in Gloucester http://t.co/9vRPhX4nbv pic.twitter.com/1vizXtPe3r
— Straitgate Action Gp (@straitgateactgp) September 21, 2014

Archaeology contractors leave a message for local people on the farm gate

Volte-face

Following our earlier suggestion, Aggregate Industries has now invited a small group of local people with a keen interest in local history to meet with archaeological contractors next week to discuss investigations and progress to date.

An air of secrecy surrounds Straitgate this morning

An archaeological contractor couldn’t remember how many trenches were dug yesterday or how many had been dug this morning. It turns out they have been expressly told not to tell local people anything about how work is progressing.

The reason given for all the secrecy? Contractors don’t want members of the public turning up with metal detectors - which is ironic, after they had no intention of doing so themselves yesterday. Are they or Aggregate Industries concerned local people might find important artefacts where they have found none? 

These are the signs that greeted us this morning. Time Team this is not.

Aggregate Industries respectfully requests

Following the missing metal detector debacle yesterday, Aggregate Industries has respectfully requested that we and other local people do not enter any land at Straitgate Farm where archaeological investigations are taking place - even when machines are idle and contractors off-site - on the grounds that the 30-40 cm deep trenches, as in the photograph below, present a health and safety hazard. AI intends to put warning signs around the site in due course.

AI advised us that to enter the dig site without company permission would be trespassing. However, only the tenant - who has to date kindly granted us access - can bring a claim for trespass, not the landlord.

Nevertheless, AI assures us it has nothing to hide and does not need the help of the public to audit its investigations. Unfortunately, events yesterday - when neither SLR, AI nor DCC were present at the start of archaeological investigations - would seem to indicate otherwise.

Archaeological evaluation begins... without a metal detector

Digging of the 55 trenches to evaluate archaeology at Straitgate Farm started today. A detailed method statement had previously been agreed between SLR Consulting - who are overseeing the project - and DCC, stating exactly how these trenches should be dug, evaluated and recorded. It clearly states that "trench spoil will be scanned with a metal detector" - as any member of the general public would expect for a site "within a rich historic landscape" - and yet, unbelievably, the archaeological contractors employed by SLR had not intended to do so.

We hope that this has now been remedied; however, it does not inspire confidence. How many other procedures are not being followed correctly? Why does it take members of the public to monitor and correct shortcomings in Aggregate Industries' pre-planning investigations?

Update

An Aggregate Industries’ spokesman has confirmed that digging of the 55 trenches referred to earlier will now start next week. The 1.8m wide trenches will be in the range of 50-100m (not 30-50m as we had been told by a DCC archaeologist) and will total just under 3500m in length. They will comprise 2% of the revised site, giving the new area now being proposed at approximately 31.5 hectares, including haul roads, tree planting, overburden storage etc.

This now confirms that AI is only intending - and only ever intending - to quarry to the west of the geological fault line that runs through Straitgate Farm. Taking standoffs into account, this now gives a quarryable area of no more than 25 hectares. The mean thickness of the pebble bed deposit in this area above the water table is 5.2m giving a net recoverable resource of less than 2 million tonnes.

Even this figure excludes resource lost for face angles, and extra standoff from properties on the west of the site that may need to be made following noise assessments. Restricting excavation to "1 metre above the maximum level of the water table", as AI was forced to do at Thorn Tree Plantation at Blackhill Quarry, would reduce that figure by a further 0.4 million tonnes. 

Two million tonnes is little more than a quarter of the figure put forward in AI’s September 2011 geological statement of 3.5Mt in phase 1 and 3.8Mt in phase 2. It was a point we made at the start of 2013 in DCC is overstating the 'recoverable' resource at Straitgate by more than 50%.

Of course, AI is still hoping to quarry below the water table and is “confident that the proposed design won’t have an impact on groundwater”. However, it will be the Environment Agency that will be the arbiter of that call - for the 3 working farms and 100 people around the site who rely on the area for their drinking water, and for the wetland habitats in the ancient woodlands. And it will be Exeter Airport that decides whether ponding and wet grasslands that attract birds is something it wants just beneath aircraft landing at Exeter Airport.

Many people will understandably wonder why profit-hungry Swiss-parent Holcim - a company currently focusing on improving its return on invested capital to above 8% - would be driven to sanction the cost of consultants, surveys, investigations, reports, planning applications, appeals, etc, etc - and the cost of moving processing plant - all for the chance of winning less than 6 years' supply of low-margin aggregate.

© Aggregate Industries UK Limited

freemaptools.com

55 trenches

Doesn't 55 trenches - to assess ‘anomalies’ thrown up after the geophysical archaeological survey last December - sound a lot to you? It adds up to about 1.4 acres and 3,500 tonnes of soil to excavate. Remember the test pits that Aggregate Industries dug in November 2012? That was for 400 tonnes.

But it is important to assess any archaeology before ripping the farm apart with bulldozers and quarrying equipment. A pre-historic track is thought to run through Straitgate, and a number of archaeological finds were made in the area during the construction of the A30. The site's prominent position was also an important junction, where a Roman road (the Fosse Way - old A30) crossed a Saxon road (B3180) running from the Blackdown Hills to Exmouth.

Would significant archaeology stop a quarry? Well, only this week in South Oxfordshire “a rural site is being assessed for heritage status, which could affect plans for a large quarry”.

DCC's map of historical and archaeological features at Straitgate Farm

Even very small amounts of silica dust are harmful

We've written about the dangers of silica dust or respirable crystalline silica before. It is an invisibly fine dust generated when quarrying and processing sand and gravel.

You only need to be exposed to a very small amount of silica dust daily for it to be harmful http://t.co/RTbeZQt8Pi pic.twitter.com/b0dK1BfTCI
— Arco (@ArcoSafety) September 18, 2014

Update

Following a geophysical survey of Straitgate Farm last December, to assess areas that might require further archaeological investigation, an extensive plan was agreed with DCC in March to dig 55 trenches across the site - each trench 30-50 metres in length, 2 metres wide, up to 40 cm deep. It is understood that these trenches may be started in October. The exact number will depend on the area Aggregate Industries intends to quarry. The trenches will be dug by archaeology contractors, overseen by archaeologists from the Council. Reports with analysis of findings will follow.

Regarding DCC's new Minerals Plan, presubmission consultation has been pencilled in for next spring, with the Council holding local meetings beforehand. AI has still not submitted anything to DCC to demonstrate that Straitgate Farm is feasible for the Plan. Our understanding is that, following further groundwater and stream flow measurements, any such evidence will not be produced until the new year.

It is now almost two and a half years since DCC’s consultation on Quarrying in East and Mid Devon. The Minerals Plan has been beset by delays as AI has been trying to prove that Straitgate Farm is workable without negative impacts to groundwater. Further delays to the Plan should not be unexpected.

Aggregate Industries' trees around the site, planted earlier in the year

Emergency landing after Swiss A330 suffers birdstrike

Birdstrike is a big deal. It has to be taken seriously. Developments - especially involving water - that have the potential to raise the number of birds directly under the take-off and landing approaches to a busy international airport should not be permitted. At Zurich last week, a plane bound for the US suffered a birdstrike. It had to make an emergency landing after circling for more than an hour to burn off fuel. One hundred and eighty concerned people were on board. The engine was repairable. The red kite - similar in size to a buzzard - was not. The incident was costly in both economic and environmental terms.

Number of cyclists killed or seriously injured in Devon rose by 27% in 2013

Finds a report commissioned by Devon County Council:

... a cyclist who was knocked down by a lorry, said road users must learn to share the road  

Devon County Council will be looking carefully at what it can do to support and protect cyclists and pedestrians, including influencing the skills, knowledge and behaviour of motorists

Planning decisions that help keep HGVs from using the more minor roads in Devon would surely help.

Community engagement is not about being nice; it’s the fourth pillar of CSR

Reads the title of an interesting article from Guardian Sustainable Business. CSR? Corporate social responsibility. The article makes the point that:

...community engagement is a way to understand, engage in and act upon critical workplace, marketplace and environmental issues. It is not additional; it is central. It is not about being nice; it is about addressing business objectives. And it is definitely not about ‘giving back’; it is about companies being part of, not apart from, society.

We touched on the subject a couple of weeks ago in Doesn't AI do hearts and minds any more? and gave an example of just such a company trying to connect with the local community - trying to be part of society - in an open day at its cement plant in Derbyshire. How successful was that open day? More than 2000 people attended, which indicates that local people do want to engage with what's going on in their community. The article finishes by saying:

If sustainability is about benefiting all stakeholders in the long-term, then community engagement can play a central role, helping companies and their people to understand and embrace issues, ensuring a positive impact on all stakeholders.

It's all common sense really; which makes it all the more surprising that community engagement is so low down on the list of priorities for certain quarry companies - companies that cause so much negative impact on local people and the surrounding environment.

.@HopeConstMats welcomes more than 2000 people to #cement plant open day http://t.co/Sjjt5tqEH8 pic.twitter.com/i8DjpHjyGF
— World Cement (@World_Cement) September 9, 2014

Government invites public's views for Autumn Statement 2014

The Government is seeking the public's views on what they would like to see in the Autumn Statement 2014, and is looking for "original and innovative ideas".

So let's remind the Government to promote the use of secondary aggregates - through both an escalation of the Aggregates Levy on virgin or primary materials and the resumption of the Aggregates Levy exemption on waste or secondary materials, such as the hundreds of millions of tonnes of china clay waste aggregate heaped up in Devon and Cornwall.

Mineral industry casts itself as saviour of the natural environment

At the Conference for Nature at Westminster yesterday, the Chief Executive of the Mineral Products Association made some bold statements; they bear repeating here:

MPA totally supports the aim of protecting and enhancing the state of nature and biodiversity delivery across the UK and EU and we will play our part where we can. Our industry is uniquely placed to make a difference, more than any other. Our industry operators are practitioners working in the environment, with the environment, and mainly for the environment.

Powerful words: "with the environment"? "mainly for the environment”? The MPA is a UK trade body representing the interests of international cement conglomerates, so let's not forget that the cement industry pumps out 5-7% of global man-made CO2 emissions - as well as a variety of heavy metals, particularly mercury. Never mind the impact that quarrying itself has on the environment.

Furthermore, and how's this for business babble:

Supporting biodiversity is a key aim for us: it is a key part of our license to operate. It also makes good business sense to restore sites to high quality and help deliver national and local environmental priorities and biodiversity targets. We can demonstrate the overall gains in environmental quality as result of our operations, and community support of, and use of, our sites.

Restoring sites? There are people, both in Devon and elsewhere, who will question those words - with a historical and seemingly never-ending legacy of quarry sites used for brownfield development.

"Where next?" he says:

We will build and validate the database, we will evaluate the asset better, we will capitalise on offsetting and ecosystem services, we will write the story better, we will tell the story better. Our aim is to see the industry shake off historic and false perceptions and become recognised as a very significant national biodiversity asset.

"Write the story better"? "Tell the story better"? People next to mineral sites and cement works will just want the industry to "do the story better".

Birdstrike - 'next major challenge in airport wildlife mitigation: addressing threats beyond the airport perimeter'

“Damaging strikes are showing an increase outside [the airport] environment”, reports the September 1 issue of Aviation Week & Space Technology in an article, Airports Reducing Wildlife Strike Risks: As bird-strike data improves, efforts to boost safety go beyond airports:

While strikes above 500 feet [above ground level] account for only 29% of the total number of reports in the FAA database, they make up 43% of the damaging incidents… “Damaging strikes are showing an increase outside [the airport] environment,” FAA’s Weller says. “Now is the time to do something about that. Airports have to put on sales hats and create partnerships with their neighbours.”

Where outside the airport environment? Specifically, says the attached podcast, “in the 5 mile corridor that aircraft approach and depart”. In other words, exactly where Straitgate Farm sits, 3.7 miles from and directly in line of Exeter Airport’s runway.

Airports across the world are increasingly having to work beyond the airport perimeters at controlling the birdstrike threat to aircraft and human life. Birds pay the price - and are culled in their thousands. Land-use proposals that attract birds directly under takeoff and landing approaches - such as Aggregate Industries' quarry plans at Straitgate which would leave a "priority wetland habitat" - would obviously run counter to these aims. Strict regulations for such proposals are set down in the UK by the CAA. Passengers trust that airports - including Exeter - will do everything within their means to keep them safe.

Doesn't AI do hearts and minds any more?

If you wanted to win over a local community with a planning application for a sand and gravel quarry, how would you go about it? If you were Aggregate Industries, wouldn’t you have laid some foundations by now; shown what a positive difference the company could make; shown that ‘there’s nothing to worry about, we’ll be good neighbours, etc’; shown contributions and donations the company has already made to communities to offset some of the impact that operations have made? Other companies have open days - invite the community in, show them how the company works, give them tea and biscuits. Like this:

COME and visit our amazing #Hope #cement works #Derbyshire on Sat 6th Sept for a great family fun day! @HopeValleyForum @vpdd @PeakBreaks
— Hope Cement (@hopecement) August 6, 2014

Open days at AI seem to be a thing of the past. Cash donations are going the wrong way too. Something for AI's new Head of Sustainability to address? Or doesn't AI do hearts and minds anymore?

Miscellaneous

1. Exeter Cathedral

An article from Mineral Planning that local people may find of interest; it's written by Sue Penaluna, principal planning officer at DCC. The Council has issued two separate temporary mineral permissions for working dimension stone at Exeter cathedral.

This is not quarrying on the scale or impact of Straitgate: "Both permissions are personal to the cathedral for ten years and allow up to five cubic metres a year to be extracted using hand tools."

2. More needs to be done on Health & Safety at mineral sites, an industry conference in June heard:

Andy Price, strategic health and safety manager for Sibelco Europe, gave an update on respirable crystalline silica (RCS) and the mounting problems of inhaling silica, the basic component of soil, sand and other minerals. He told the conference that "more than ever" the aggregates sector was being drawn into the debate on RCS because of diseases such as silicosis.
Evidence suggested people with silicosis could develop lung cancer: 16 deaths were caused by silicosis in 2011, while 40-50 cases were registered every year. But projections from the HSE suggested there could be 800 deaths a year due to past exposure. RCS was number two in the HSE priority list for occupational health behind only asbestos, he said.
Other areas picked up were quarry fencing, traffic management, risk assessments and dust from control of substances hazardous to health...

To hear that the issue of quarry fencing was being discussed at an industry conference, before the school holidays and before a number of tragic drownings, beggars belief.

3. Fracking waste

For those with an interest in the subject, this industry article written by lawyers makes sobering reading:

Here’s just one part:

Fracking involves the injection of large volumes of water. This water is likely to pick up naturally occurring radioactive materials (NORM) from underground strata. This means that, upon returning to the surface, fracking fluid may contain sufficient NORM to be classed as radioactive waste and require an environmental permit for its storage and disposal.
Operators are unlikely to be granted a permit unless they show a clear strategy for disposing of radioactive flowback. This is significant because of the limited number of installations available nationally to treat waste containing NORM. The December 2013 DECC and AMEC Strategic Environmental Assessment report concluded that volumes of flowback waste water could range from 3,000 to 18,750 cubic metres per well.
Under a high-activity scenario, that could mean a potential wastewater treatment and transit requirement of up to 108 million cubic metres, which would place a substantial burden on existing infrastructure.

4. Hanson, a competitor to Aggregate Industries, commented on its 2014 Performance and Sustainability Report:

The eight-megawatt solar farm at Ketton [cement works in Rutland] is part of Hanson’s action plan to increase the use of renewable energy to achieve its 2020 goal of cutting carbon emissions by 10% per tonne of product.

When cement contributes 1 tonne of CO2 for every tonne produced, producers like Hanson and Holcim will need to do much much more in the years and decades ahead - the UK government for one has set targets to reduce greenhouse gas emissions by 80% by 2050.

Planning appeal for quarry working in AONB SPA SAC dismissed

If Aggregate Industries is still clinging to the hope of using Blackhill Quarry beyond 2016 to process any material it might win from Straitgate, then planning appeal decisions are not going its way.

After the one in Staffordshire, mentioned here a couple of weeks ago, here’s another one - this time in Ashdown Forest, which has the same conservation and protection designations as Woodbury Common - AONB, SPA, SAC. In this case the applicant wanted to infill and restore an old quarry with imported inert waste material.

Despite the Inspector agreeing that the "proposal would enhance the character and appearance of the High Weald AONB" and "result in an appropriate measurable improvement to the agricultural use of the land", it would however "jeopardise highway safety along the B2026" and "potentially prejudice any biodiversity interest of the site and harm the nature conservation interest of Ashdown Forest".

Substitute B3180 and Woodbury Common into that last sentence, and you can see why AI is making plans for Rockbeare.

AI's new Head of Sustainability

Aggregate Industries has appointed Shelley Frost as its new Head of Sustainability, a post that's been vacant since February. "Ms Frost joins the company from Lafarge where she held the position of regional director of environment and public affairs in Northern and Central Europe". She said:

Aggregate Industries is passionate about sustainability and committed to performing at the highest standards to minimise our impact on people, the environment and the economy. We are already leading the way in many of these fields and I take pride in working for such a forward thinking company.

This is the same forward thinking company that only now - after almost 50 years of ownership - is working out how to quarry Straitgate Farm.

Locals will of course scrutinise the impact that any quarry at Straitgate will have on people, the environment and local economy if or when a planning application transpires.

‘Airports' global bird slaughter - 100,000s gassed, shot, poisoned’

... writes Rose Bridger, author of Plane Truth: Aviation's Real Impact on People and the Environment, in The Ecologist and the accompanying blog post Airports are waging a war against birdlife. They are important articles, highlighting the cost to birds across the world in the struggle to manage the risk of birdstrike to aircraft. As she says:

Keep airports away from birds! ...the most effective way of minimising bird strikes, aside from constraining aviation growth so that skies are not so crowded, is not to build airports in or near important bird habitats and migratory flightpaths.

The corollary for airports already in place is: don't build developments that attract birdlife - quarries with water being one of them, as proposed here at Straitgate by Aggregate Industries - directly beneath their landing and take-off airspace.

Exeter Airport, now owned by Rigby Group plc, has seen passenger growth pick-up after a six year hiatus. Sir Peter Rigby said: "We see great opportunities to cement Exeter’s position as the gateway airport to the South West and a real driver for economic growth." Matt Roach, managing director of Exeter Airport, said: “We’ve had a very encouraging start to the year and are well on course to exceed three quarters of a million passengers in 2015."

AI makes plans to process at Rockbeare

Local people may have noticed that Aggregate industries' Charcon blockworks at Rockbeare closed this year, and the site remains unused. The suspicion was obviously that this site was being earmarked to process any material won from Straitgate. Now, someone from within AI has confirmed that this is indeed the case.

Whether the company has given up hope of continuing at Blackhill beyond 2016 or whether this is Plan B, remains to be seen. What it does indicate is that AI is not wholly confident of winning the extension.

And rightly so. It was absurd for AI to ever think it could maintain a processing plant in the middle of Woodbury Common AONB, SPA, SAC without a permitted, working and adjoining quarry. Quarrying there finished long ago, following an EU directive, and while it was granted short term permissions to process material from Venn Ottery and Marshbroadmoor, Straitgate could be for another 10 years.

The situation is not dissimilar from a recent planning appeal in Staffordshire, where an inspector ruled that a workshop - that the appellants wished to retain to process stone from other quarries - should be removed, "since its presence was wholly dependent upon the quarrying use, [and] once that ceased it was necessary for the building to be removed in order to protect the green belt”:

The development was by definition inappropriate, the inspector concluded. It reduced the openness of the area and also detracted from the rural character of the locality. While government policy supported economic development in rural areas, there was no need to process stone brought in from other quarries in the green belt… Alternative premises on an industrial estate could be sourced, he determined.

Of course, AI may find securing planning permission to process at Rockbeare not straightforward either. The Highways Agency may have something to say about 100 or more HGV movements a day travelling to and from Straitgate around possibly both Daisymount A30 roundabouts. And AI would still need to convince Exeter Airport and the CAA that having settlement ponds directly below a flightpath would not increase the risk of birdstrike and compromise airport safeguarding; it was 1947, after all, that permission was last granted to work and process at Rockbeare - air traffic and airport safeguarding regulations have both increased dramatically since then.

And on that point, let’s remind ourselves again what one of the ponds at Blackhill Quarry - nicknamed by AI staff as ‘Seagull Pond’ - looked like a couple of years ago:

#we_stand_for - and other industry news

A range of industry-related stories that have appeared over the last month:

1. So that we all know exactly what to expect if Aggregate Industries quarries Straitgate Farm, Swiss-owners Holcim have launched a #we_stand_for campaign to promote its "values and behaviors". Number one on its list? "Integrity":

Integrity stands for recognizing the right thing to do, admitting mistakes, having the courage to stand firm on compliance, and taking appropriate action. We follow the Holcim Code of Business Conduct and respect local laws in all situations. Integrity stands for Strength. Performance. Passion

2. For those concerned about the possibility of 100 or more HGV movements each day trundling along the B3180 from Straitgate to Blackhill and back, there's now another issue - from early 2015, HGV speed limits will increase on single-carriageway roads - from 40mph to 50mph:

The FTA said the decision supported an improvement in road safety by reducing the 20mph differential between HGVs and other road users, and would allow UK single-carriageway roads to be used more effectively.

Such a move would of course increase the speed differential between HGVs and cyclists/pedestrians.

3. "Closure threat hangs over quarries" shouts the headline in Minerals Planning.

More than 100 pits and quarries could close within the next five years unless new reserves are granted, a leading consultant has warned.

The leading consultant? "BDS Marketing Research Ltd is an independent marketing and market research consultancy specialising in the construction materials and waste sectors... BDS is a member of, and active participant in, the following trade associations - Mineral Products Association and British Aggregates Association". Not quite so independent then.

In any case, a few days later, the Mineral Products Association, when reporting second quarter aggregate sales - with sand and gravel up 4% on 12 months before, claimed "even with 3% growth trends markets would not regain pre-recession levels until after 2020".

Demand is rising in some sectors of the construction industry: Brick shortages 'worst in living memory' and UK concrete shortage threatens major projects. The latter ironically due to the 'dwindling availability of fly ash'.

4. Last month the Mineral Products Association issued a wish list of actions for the Government - here are some of them:

Ensure energy and climate change policies are consistent with the need to sustain a competitive UK mineral products sector, including Energy Intensive Industries (EIIs). Withdraw the carbon price floor. Review and reduce the cumulative cost and volume of environmental legislation. Freeze the Aggregates Levy while there is a comprehensive review of the policy.

Demands that appear inconsistent with any concern for climate change or the environment.

5. Lastly, and closer to home, Minerals Planning reports that DCC "has approved schedule of new conditions for [Aggregate Industries'] quarry near Barnstaple, subject to the operator agreeing to avoid further working in one area of the site and indemnifying the council against compensation claims".