Straitgate has already been a disaster for AI

When Straitgate Farm was bought in 1965 the 'available resource' was estimated to be 20 million tonnes. It has been falling ever since.

By the time planning permission was refused at the 1968 Public Inquiry, this amount was down to 17.15Mt, after "taking into account losses due to landscaping and to modifications to conserve water resources". By 1990, following extensive borehole surveys and losing part of the site to the new A30, it was down to 8.1Mt. By the time of DCC’s public consultation in 2012, the eastern half of the site had been 'abandoned' leaving 3.6Mt. Now, Aggregate Industries has revised that figure to 2.8Mt, and, determined to retrieve something, anything, after spending a fortune over the years on not only the site but on consultants, surveys, borehole drilling, monitoring, testing etc, the company is putting in a scoping request for just the 1.2Mt above the water table. It’s been a terrible investment by any metric.

Of course, the cynically minded might think AI has just split the resource into the two smaller amounts, above and below the water table, in an underhand ploy to increase its chance of winning further extensions at Blackhill, the thinking being that two consecutive 4-5 year extensions might stand more chance of succeeding than one of 10 years. However, what realistic prospect does AI have of extracting the material below the water table, when groundwater from Straitgate plays such a critical role to private water supplies and wetland habitats in ancient woodland, as indeed the Environment Agency recognises? AI's 1.6Mt below the water table is a stranded-asset and needs to be written off. Twenty million tonnes to 1.2Mt - only 6% of the figure first estimated in the 1960s.

Back in 1968, the planning inspector concluded:

… it may be that the review of the development plan will contain proposals for other land with less disadvantages, and it is not possible to say now that the need for the Straitgate site is in any way overriding. For this reason any approval would be premature, and my recommendation not to allow that application is also on that basis, apart from the water supply considerations. (408.p)

He recognised the disadvantages and the water problems with Straitgate, but could rule the site out on prematurity considerations alone. The site may no longer be as premature, but with birdstrike, dormice and archaeological assets there’s now an even longer list of disadvantages.

In 1968, before any talk of supporting "the move to a low carbon future", initial processing was to be at nearby Rockbeare; now the best that AI can come up with is trucking 1.2Mt of sand and gravel 8 miles away to Woodbury Common. That’s not a plan or a quantity that’s worth destroying a farm for, that’s worth causing so much environmental damage for.

Has AI fallen into the sunk cost fallacy? Is it making irrational decisions in an effort to recover anything from its investment in Straitgate? AI proudly claims "We are pioneers of best practice in sustainability" but then admits that "transport CO2 emissions have gradually increased since we started to monitor them in 2007". Is it any wonder, with plans like Straitgate? It’s time for Holcim's bean-counters to tell AI to stop throwing good money after bad and leave the farmers to get on with farming the land, as they have done for hundreds, even thousands of years.

Never underestimate the impact of a European Protected Species

Persistent newts put the brake on a Transport Secretary's rail showpiece

It is a story of David vs Goliath if ever there was one: an 18-month battle between the newt and the minister. And – so far – the newt is winning.

Fishponds

And talking of heritage assets and settings of listed buildings, this is the setting of Grade I listed Cadhay, resplendent with mediaeval fishponds in the foreground, themselves Grade II listed. What we said in our last blog would apply equally here too. A reliable supply of spring water from Straitgate, particularly during drier periods, is critical to the functioning of these ponds.

This is what was said at the Public Inquiry in 1968:

396. Cadhay is a historic house, listed as being of historic and architectual importance, and is open to the public. One of the features is the fish ponds immediately to the south of it. They are fed by the reservoir [in Cadhay Wood] and [Cadhay Wood] stream. They are not lined and water seepage takes the whole outflow. 397. It is contended that if the present water supply to the ponds were no longer sufficient to supply them they would be lost to posterity in the way in which they have existed for centuries, which would be a wanton destruction of a valuable historic monument.

The position of the spring is indicated by our arrow on ECC’s 1967 working plans below. No doubt it was in an effort to protect this water source [53] that ECC intended to leave the surrounding area unquarried.

Aggregate Industries has made no allowance yet for this spring on any plans we have seen.

Yet more for AI to subtract from its ever decreasing resource?

In 1968, the planning inspector concluded that any loss of flow to springs and streams at Cadhay "could be made good from the Straitgate lake...". [408] Without a lake, it's not exactly clear how AI could achieve that now.

Harm to setting of listed farmhouse already means presumption in favour of refusal

There can be no argument - quarrying Straitgate Farm would substantially harm the setting of its Grade II listed farmhouse, for ever more; surrounding fields would be removed, different levels would be introduced, screening would be ineffective, farming may no longer be viable. In 1967, Aggregate Industries (then English China Clays) wanted to bulldoze the farmhouse; today it is protected in law.

Straitgate has been farmed for more than 400 years, as copies of legal papers we have confirm. The farmhouse is thought to date back to around 1580. Part of the surrounding land is also listed, and the rest is fundamental to the setting of the farmhouse and its continuation as a working Devon farm.

In the 2012 S1-S10 site appraisals, DCC wanted us to think that "there is a medium risk of harm to the listed building which sits within an historic landscape of Barton Fields, which may require the retention of a buffer area to preserve its setting", and that nothing could be a ‘showstopper’ for S7/Straitgate. Only later, when the Sustainability Appraisal looked at the matter, did it consider that "the setting of the Grade II listed Straitgate Farm would experience a significant negative impact".

Now, in 2015, Aggregate Industries proposes that:

An impact assessment will identify the significance and sensitivity of all heritage assets affected by the proposals, and includes an impact assessment to evaluate the magnitude of change and thus direct and indirect impact on heritage assets. In particular the potential impact on the setting of designated heritage assets within 2km will be considered in relation to the Landscape and Visual Impact Assessment. If mitigation can be designed to reduce the effects of potential impacts on the settings of the statutorily protected heritage assets, then a strategy will be written and (assuming its implementation as part of the permitted scheme) the reduced residual effect will be assessed in light of the mitigation.

The issue of 'heritage assets' could be very important - not just a material planning consideration.

We mentioned the Barnwell Manor Appeal Court decision last year, but we have been reminded again by CPRE of its potential implications for Straitgate Farm. This Court of Appeal judgement upheld an earlier decision overturning permission for wind turbines in the setting of various heritage assets. CPRE, who have made representations to DCC regarding Straitgate in the past, wrote:

It is being treated as a landmark decision and is frequently referred to in subsequent planning decisions/appeals.

The importance is that it highlights the significance of the setting of a heritage asset, i.e. a listed building such as Straitgate Farmhouse. The setting includes not only views from the heritage asset, but views of the asset and its surroundings - anywhere that you get a view of the heritage asset.

The emphasis is on S66 Listed Buildings Act (1990) and the "special regard to the desirability of preserving the building or its setting". This statutory duty outweighs any policies (such as the NPPF), and as the Listed Buildings Act is worded more strongly than subsequent policies, it is helpful.

Harm to the listed farmhouse's setting would be substantial; yet, even if it were not, the judgement says:

It does not follow that if the harm to such heritage assets is found to be less than substantial, the balancing exercise referred to in policies HE9.4 and HE10.1 should ignore the overarching statutory duty imposed by section 66(1), which properly understood (see Bath, South Somerset and Heatherington) requires considerable weight to be given by decision-makers to the desirability of preserving the setting of all listed buildings, including Grade II listed buildings.

That consideration "can outweigh even considerable planning benefits such as, in this case, temporary (25 year) generation of zero carbon renewable energy". As the Planning Resource article, Pickles prioritises heritage in wind turbine decisions, puts it:

Judges ruled that once the decision-maker finds some harm to a heritage asset, that harm should be given "considerable weight", creating a "strong presumption" against the grant of planning permission.

In other words, there is a presumption in favour of refusal if harm is present.

The onus will be on AI to demonstrate that sufficiently powerful material considerations exist to justify such harm. For the decision-maker, this is not just "a simple balancing exercise but whether there is justification for overriding the presumption in favour of preservation"; preserving the setting is not a "mere material consideration to which (he) can simply attach the weight (he) sees fit in (his) judgement".

AI will also have to demonstrate that "there is no clear alternative which would generate equally powerful public benefits". If you think of AI’s extensive mineral rights in the region, covering thousands of acres, that might not be so easy; because of course there are sand and gravel deposits in other locations that wouldn’t cause as much harm, that would generate 'equally powerful benefits'.

WHRA's response to AI's scoping request

"This response has been prepared by West Hill Residents’ Association..."

Cllr Wright's response to AI’s scoping request

Response to scoping exercise for controversial plans to quarry at Straitgate Farm, Ottery St Mary

Why should local people believe AI this time?

Aggregate Industries has said lots of things over the years. It nows tells us, in its Scoping Request, that:

Subject to planning consent, it is therefore proposed that mineral processing from Straitgate Farm would take place initially at Blackhill Quarry for a period of approximately 4-5 years until the end of 2021. Sand and gravel which may then be potentially worked from the “wet working option” would be processed at Rockbeare.

Blackhill, of course, was meant to be restored years ago. It’s now an isolated sand and gravel processing factory sitting in an AONB, adjacent to areas of European importance to nature, 8 miles from Straitgate. AI’s unsustainable plans would generate a million HGV miles on Devon’s roads over 5 years.

Can we take AI’s new plans at face value, or should we instead read:

We have no intention of processing at Rockbeare. Holcim, our Swiss paymasters, won’t expense the move. If we did ever win permission for “wet working” at Straitgate, we would apply to extend permission for Blackhill again. DCC has given permission before, and before, and before, and we expect them to do so indefinitely.

Are we being disingenuous? Let’s see what Aggregate Industries has told people in the past:

2001, Blackhill site visit, considering planning permission for working Thorn Tree Plantation:

…[Blackhill Quarry] would close completely after the application area was excavated, because the quarry site is limited by the Special Protection Area, candidate Special Area of Conservation and other landscape designations.

2008, Supporting Statement, Blackhill Quarry, Importation of material from Marshbroadmoor:

It is estimated that winning and working of mineral within the Thorntree area will be completed in late 2009. At this point, the processing plant will be dismantled and removed from site, leaving only the weighbridge and stock piles operation whilst stock is depleted.

2010, Planning Application, Blackhill Quarry, Importation of material from Venn Ottery:

3.6.1 It is anticipated that importation and processing operations will take place over a period of approximately 5-6 years based upon predicted sales… Upon cessation of processing operations it is anticipated that final restoration would be completed within 12 to 18 months.

Whilst it was making claims about Blackhill, AI was also making claims about Rockbeare. It may not want to use Rockbeare for processing Straitgate material now, but in 2003 it was a different story:

It is this Company’s view that there is an inextricable link between Straitgate Farm and the Rockbeare Minerals Working Area... It is the Company’s intention to transfer [Blackhill] plant to Rockbeare as soon as working is completed at Blackhill... Working the reserve at Straitgate Farm initially and possibly wholly through our existing mineral site at Rockbeare we believe is both efficient and has environmental benefits.

AI is in the business of winning permissions. It will say whatever it thinks it needs to, as demonstrated above, and local people will rightly assign little weight to any claims it makes about the future.

The truth is, if AI had moved to Rockbeare when quarrying at Thorn Tree Plantation had finished, and had not been so profit-hungry, so short-sighted, it could have used the site to process both Venn Ottery and Marshbroadmoor material, covering moving costs, saving hundreds of thousands of polluting miles on Devon roads, and now be in the right place should it win Straitgate. That it didn’t is the company’s problem, and not one for which local people or Woodbury Common should now pay the price.

Surely the NPPF must have something to say on unsustainable proposals like AI's?

As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport.

As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport.

As a company we are committed to sustainable construction and reducing the carbon footprint of the products we produce and transport.

It's a claim Aggregate Industries keeps wheeling out. Perhaps if it says it enough it might act like it too...

And not push million-mile HGV proposals onto local communities and European-protected sites. It's one thing ruining a perfectly viable farm and risking water supplies for 100 people, but it’s another thing continuing to blight the East Devon Pebblebed Heaths.

It is staggering that AI is still kicking around this ridiculous, unsustainable and polluting plan - to transport Straitgate material all the way to Woodbury Common for processing - when it owns an alternative site just 1/4 of the distance away at Rockbeare; an industrial site already sitting empty; a site that would save more than 750,000 HGV miles on Devon roads over 5 years; a site 0.5 miles from the strategic road network, for sales distribution, not 6 miles as at Blackhill; a site that’s apparently good enough for AI's improbable 'Stage 2' plans for Straitgate, and that therefore must be good enough for 'Stage 1' too.

How many other sand and gravel operations can there be in the UK, where 8 miles separate quarry and processing plant? We haven’t come across one yet. The reason being that transport costs normally limit the economic supply radius of low margin aggregate to 30 miles or so; AI's plans reduce that by 16 miles.

If AI can't do the right thing, what does the NPPF say on the subject - could anyone pretend that digging out Straitgate and transporting the spoil 1,000,000 miles for processing is sustainable development? Yes, if they could demonstrate that the economic benefits outweigh the social and environmental harm - but the issues page clearly shows that won't be easy. But what exactly is sustainable development? We have written about this before, but it comes back to what’s written on page 2 of the NPPF:

Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs. The UK Sustainable Development Strategy Securing the Future set out five ‘guiding principles’ of sustainable development: living within the planet’s environmental limits; ensuring a strong, healthy and just society; achieving a sustainable economy; promoting good governance; and using sound science responsibly.

The NPPF states that "to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system" [8], but of course the NPPF is open to interpretation, particularly because "the policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development in England means in practice", which is why many argue that it has done nothing to protect us from unsustainable development. But election time is coming, and different noises are coming out of the Government:

the Government are committed to doing far more to publicise those recent cases widely, to provide reassurance that unsustainable development should be resisted

And the Communities and Local Government Select Committee has now recommended:

that the Government remove from the NPPF the statement that the policies in paragraphs 18 to 219, taken as a whole, constitute the Government’s view of what sustainable development means in practice. The definition on page 2 of the NPPF needs to stand on its own. [13]

In the meantime, let's highlight two very salient parts of the NPPF that are relevant here:

Firstly, on the issue of Meeting the challenge of climate change, flooding and coastal change, the NPPF says: "Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions... This is central to the economic, social and environmental dimensions of sustainable development [93]. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change... in line with the objectives and provisions of the Climate Change Act 2008" [94].

In other words, planning must be in accordance with the Climate Change Act, whereby "it is the duty of the Secretary of State to ensure that the net UK carbon account for the year 2050 is at least 80% lower than the 1990 baseline", and that’s not going to happen by allowing proposals like AI’s.

The Committee on Climate Change was tasked by the Government to provide advice on How local authorities can reduce emissions and manage climate risk. One of the key messages is: "It is particularly important that local authorities use their plan making and development management control functions to... reduce transport emissions...".

Secondly, on the issue of Promoting sustainable transport, the NPPF says: "Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion [30]. Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised..." [34]. The NPPF has more on this, but the Campaign for Better Transport has scrutinised the document far better than we ever could, and produced the very relevant Sustainable transport and the NPPF - a guide for local councils and communities.

Looking beyond the NPPF, there’s also the moral issue in all this, because continued processing on Woodbury Common is so demonstrably wrong, on so many fronts. If AI can’t be trusted to do the right thing now - to minimise the impact on local people, the East Devon Pebblebed Heaths, or the planet - how could it be trusted to do the right things if it were to actually win permission for Straitgate?

How far??

Forty times around the Earth - that’s how far Aggregate Industries plans to transport the sand and gravel it digs out of Straitgate Farm - and that's just to process it.

When the world is shouting for polluters to reduce greenhouse gases, AI's track record on CO2 reduction - or lack of it, and its latest million-mile proposal for Devon, suggests it carries on regardless; regardless of warnings from eminent scientists that "climate change is a moral issue on a par with slavery":

The situation we're creating for young people and future generations is that we're handing them a climate system which is potentially out of their control.

Are we surprised? After all, CEOs don’t take climate change seriously:

Only 6% of respondents listed reducing the risk of climate change as a priority, putting it at the bottom of the list… [but] unless we see a sea change in the global business community’s involvement in fighting climate change, corporations will continue to be seen as part of the problem rather than the solution – and consumers’ trust that companies will do the right thing will fade even further.

However, when it comes to planning applications, it’s not up to CEOs, it’s up to councils and councillors, working within the guidance of the NPPF. And on this point, the NPPF is clear:

To support the move to a low carbon future, local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions

In locations and ways which reduce greenhouse gas emissions - a point we made in one of our earliest submissions. AI's proposal to process Straitgate material at Blackhill is not sustainable development. Every one of the 1.2 million tonnes at Straitgate would incur a 16 mile round trip - just to be processed into something saleable; curtailing the material’s viable supply radius, damaging roads, polluting the air we breathe with NOX and other diesel emission carcinogens, all because a multinational won’t expense processing in an appropriate location, a location that's not in the middle of a site of "national importance for its heathland, grasslands, mires and fens, breeding birds, and dragonflies and damselflies".

In Lancashire, Cuadrilla is going to have to fork out a few more million pounds, to address planning officer concerns over noise and the “severe” impact of 50 daily lorry movements for two of their fracking sites. At the end of the day, AI would also have to spend some money and move plant closer to the point of extraction - to a nearby industrial estate for example, not Woodbury Common - if it wants any chance of winning permission to quarry Straitgate Farm.

And on the subject of fracking... and groundwater

Fracking may be geologically improbable in East Devon - Cllr Claire Wright’s blog gives more details - but this helpful map from Friends of the Earth shows the areas being offered up for licensing, including parts of Devon. What it also shows are the groundwater Source Protection Zones imposed by the Environment Agency - including those to protect private water supplies around Straitgate.

AI’s Scoping Request now has SLR claiming that because "...the intention is only to extract mineral from a “dry working option” (above the water table) at Straitgate Farm. It is considered, therefore, that the proposed development would not result in any significant effects on the water environment".

It’s a big claim, and it will be interesting to see if the Environment Agency agrees. Because removing soil, overburden and 1.2 million tonnes of unsaturated sand and gravel above the saturated zone would certainly appear to have the capacity to change the hydrological regime in some way - be it recharge characteristics, surface run-off, or response to pollution events.

Of course, the corollary of SLR's claim is that the future “wet working option”, the improbable 'Stage 2' of AI's plans, would result in significant effects on the water environment.

Straitgate’s dormice

For people who haven’t read Aggregate Industries' recent Request for a Scoping Opinion, this is what it has to say about Straitgate’s population of dormice - a European Protected Species:

Some 200 dormouse ‘nest tubes’ were deployed at 10-20m intervals across many hedgerows on the site and in further suitable habitat to the east of the application boundary in order to sample potential dormouse habitat. Nest tubes were installed in May and June and two interim checks were made during July and early September 2013. The final check and retrieval of tubes was made in October and November 2013. On 3rd July 2013 the survey found no evidence of dormouse. On 5th September 2013 five dormouse nests were found, one of which contained an adult dormouse. On 1 October and 4th November 25 dormouse nests were found, two of which contained an adult dormouse, and three nests which contained two dormice: one adult and one sub-adult. This evidence indicates that dormice are highly likely to be present in all suitable habitat within the site and local area. Therefore all shrub habitat (including hedgerows and woodland) within the site has been classified as dormouse habitat for the purposes of the European Protected Species Licence application.

One of the UK’s most endangered mammals, dormice are now protected by law. Continuing destruction and fragmentation of hedgerow and woodland habitats have taken dormice numbers down to around 45,000 across the UK. Aggregate Industries would have to apply to Natural England for a licence in order to proceed, and demonstrate that it can meet three statutory tests:

the project is for the purpose of preserving public health or public safety or other reasons of overriding public interest, and there is no satisfactory alternative, and the action will not be detrimental to the population of the species

Natural England "applies the tests on a proportionate basis; thus the justification required increases with the severity of the impact on the species or population concerned".

DCC would also need to address these three tests when deciding whether to grant planning permission, and "if it is clear or perhaps very likely that the requirements of the Directive cannot be met… then the authority should act upon that, and refuse permission".

Looking at the three tests more closely: Firstly, mineral extraction can count as an ‘imperative reason of overriding public interest’, but let’s remember that a) this is commonly available sand and gravel we are talking about, not some nationally or internationally important mineral that occurs only in limited areas of the UK, and b) the amount of resource available (to justify the harm) is now much reduced. Secondly, on the question of no satisfactory alternative, plainly there are alternative sites, and also alternative materials. Again, "the greater the impact of the proposal on the species, the more evidence Natural England would expect to see from the applicant in order to be able to satisfy itself that there is no satisfactory alternative to the one being proposed". On the third test, it’s difficult to see how ripping out so much hedgerow, some up to 4m wide, could be anything but detrimental to the population of the species, whatever number of saplings are planted in mitigation. We’re not talking about the loss of a few metres for a gateway… we are talking about the loss of almost two miles of ancient hedgerow.

Have dormice and protected species made any difference to planning decisions in the past? Absolutely. Here are just a few - here, here, here, here and here.

Ref: PRE/0953/2015 Proposal to extract sand and gravel at Straitgate Farm, West Hill, Ottery St Mary, Devon - and transport it over 1,000,000 miles

Aggregate Industries' outrageously unsustainable and polluting quarrying proposal for Straitgate Farm - processing as-dug material over 8 miles away in the middle of "one of the most important conservation sites in Europe", 100 or more trips a day for up to five years - will now attract even more opposition. AI claims that "reducing our carbon footprint is an important part of our commitment towards sustainable construction" - a claim that rings very hollow.

In the meantime, our response to AI's Scoping Request has been sent to DCC.

It’s good news and bad news (and the bad news could be good news)

The folly of Aggregate Industries' plans to quarry Straitgate Farm has finally been laid bare, following its formal request to DCC for an Environmental Impact Assessment "Scoping Opinion" - to identify the information needed for the Environmental Statement accompanying the company's planning application.

[AI] hereby gives the Council notice in writing that it intends to make a planning application, and to accompany such applications with an ES.

The scoping request "sets out the principal issues upon which SLR [AI’s consultants] considers that the EIA should specifically focus on", and is subject to consultation with statutory consultees and anybody else who wishes to comment on what AI's Environmental Statement should contain - not on the merits or impacts of the proposed development itself.

But what the scoping request also sets out is how AI intends to proceed. And this is the good news, because after eleven boreholes, two years of groundwater measurements, regular stream-flow monitoring and prolonged pre-application discussions - between AI, its consultants, DCC, the Environment Agency and Natural England - the scoping request, and therefore AI's future application, is only for a "dry working option", only for the resource lying above the water-table, only for 1.2 million tonnes of sand and gravel, only for one third of the amount DCC originally consulted upon, only for 4-5 years of working, and only for the amount that we have been saying is available all along. AI talks about a "wet working option" (extracting below the water-table) at a later stage, but plainly if that were possible the data and statutory consultees would have indicated as much by now, and the scoping request would have been for the whole resource.

That’s the good news. The bad news is that, with the diminished quantity and to save plant relocation costs, AI wants to process this as-dug material at Blackhill Quarry, 8.2 miles away along the B3180 on Woodbury Common AONB, SPA, SAC, SSSI. AI’s permission to run a sand and gravel processing factory in the middle of an internationally important conservation site runs out in 2016. AI will be seeking, in a separate application, to extend this to 2021.

Why could this bad news be good news? Because the chance of AI securing a Blackhill extension must surely be heavily weighted against it. Because it's inconceivable that DCC officers and councillors would permit this, when as far back as 1999 AI was told to get off the Common and was given millions of pounds in compensation. Because it's inconceivable that yet a further extension would be granted, after AI has already won various extensions in 2002, 2008, 2010 - continually delaying restoration of the East Devon Pebblebed Heaths. Because it's inconceivable that such an unsustainable proposal could ever be allowed - 16 mile round trips, over 100 HGV movements a day, over a million HGV CO2 polluting miles, over a 5 year period. Because it's inconceivable that such a proposal would be permitted, when similar planning applications for sites elsewhere with the same designations have been rejected.

And what if AI's application for a Blackhill extension were rejected, and there was not enough 'dry material' at Straitgate to justify moving plant to Rockbeare - what then? If AI can’t get planning permission for Straitgate and Blackhill, then all the 'southern' sites could be off the table.

What of the Scoping Request itself? What else does it tell us? Well, the report may have been "prepared by SLR Consulting Limited with all reasonable skill, care and diligence", but the three references to "Birdcage Walk" won’t impress the Queen. There are major fails too.

The omission of any reference to increased bird activity from standing water and changes in tree cover a few hundred feet beneath an international flight path won't impress Exeter Airport or the CAA.

The omission of any reference to the environmental impact of processing at Blackhill, for example importing nitrate-rich sand and gravel to an SPA, SAC, SSSI, won't impress Natural England either:

Natural England has serious concerns regarding potential continued processing at Blackhill Quarry due to its sensitive location within the SAC. Although we have some concern regarding later restoration we are particularly concerned about the importation of waste material (including wet silts and water used to clean waste) with a higher nitrate content than that appropriate for restoration in a heathland area which requires negligible or preferably no nutrients. As Straitgate is intensively dairy-farmed, it would be impossible to prevent nitrates from entering lagoons at Blackhill if material were brought to Blackhill as dug. We advise that off-site processing at Blackhill is therefore an unacceptable high negative impact...

People can comment on AI’s scoping request until 6 February, as detailed below.

Seriously, what were Aggregate Industries and its consultants SLR thinking?

When, as a way of dealing with the water problems that would be created by quarrying Straitgate Farm, they proposed this?

The provision of water storage along the [eastern] boundaries of the site, to mitigate flooding and maintain groundwater flow, also offers the opportunity to create a priority wetland habitat and therefore enhance the ecology of the area.

Obviously they weren't thinking anything about Exeter Airport, anything about planes and people flying a few hundred feet overhead about to land on Runway 26, or anything about birdstrike.

Quarries restored to wetlands provide crucial habitat for many species, including starlings http://t.co/eGBehRA7mI pic.twitter.com/RPfwv89x3w
— NatureAfterMinerals (@NatureAM) January 12, 2015

Aggregate Industries on climate change

We have long recognised the consequences of CO2 emissions and how both the manufacture of our products and their use in the built environment contribute to climate change... there is a real focus and drive to minimise the environmental impact of all we do.

In 2012 our total process carbon emissions were 236,800.24 tCO2e 

In 2013 our total process emissions increased to 254,495.44 tCO2e

If AI has long recognised the consequences, why are CO2 emissions still rising? People across the world look to carbon polluters like AI and Swiss-parent Holcim to actually do something about the climate-changing emissions from cement and concrete, not just to talk about it.

AI's Sustainability Report 2013 mentions "climate change" just once, but the company maintains that: 

By 2016 we will reduce process carbon emissions by 20% on 2012 levels in absolute terms

It has to. Continuation of its carbon-heavy business model depends upon making changes. Not only does the 2008 Climate Change Act commit the UK to cutting greenhouse gas emissions by at least 80% by 2050, but carbon emissions are costing society £4 billion per year. Yet, in 2008, AI said the same:

Carbon remains a key focus for both us and society... We continue to work towards our 2012 target of 20% reduction per tonne of production from the 2008 verified baseline. 

And what happened?

Process emissions (kgCO2/t) 2008: 5.03, 09: 5.56, 10: 4.98, 11: 5.15, 12: 5.12, 13: 5.55

Total emissions (kgCO2/t) 2008: 8.63, 09: 9.25, 10: 9.13, 11: 9.57, 12: 9.74, 13: 8.68

AI claims to be serious about climate change, but its flatlining record would indicate otherwise.

Is corporate sustainability reporting a great waste of time?

Asks an article in The Guardian. It argues that companies need to "zero in on what’s important to the key stakeholders", that "It’s not about your story; it’s about your impact".

Another article asks Sustainable mining: an inherent contradiction in terms? It's about mining across the world, but the message is the same, "Mines generate huge revenues, but communities who live around them are poor and don’t see the benefits. That creates a cycle of conflicts..."

Mining conjures up an ugly environmental image. Companies dig deep into the earth and use large amounts of energy and water to extract, process and transport minerals, leaving behind a devastating impact. That image has come to define the mining industry, and it’s increasingly hurting its ability to make money.

We highlight these articles because Aggregate Industries has recently released its sustainability data for 2013. Part of this data includes information on "Community donations and support". We have written about this before - here, here and here.

Aggregate Industries is in the open-cast mining business. It impacts local communities like very few others. And it should compensate affected local communities like very few others. Yet we find that AI, and its Swiss-parent Holcim, has again given next to nothing back to UK communities. By next to nothing we mean a total of £108,909 in 2013, little more than 0.01% of its sales, or 1p in every £100. Whichever way you look at it, it rounds to nothing.

It's not as if AI can't afford it. Pat Ward, its Chief Executive, recently said: "2014 has been a good year for Aggregate Industries in the UK. We are obviously benefiting from some positive indicators in the market and the economy."

Latest available accounts show it made a turnover of £1.077 billion in 2013, compared to £1.025 billion in 2012. Earnings rose from £40.2 million to £96.4 million over the period.

With the zeroes, that's sales of £1,077,000,000 in 2013; a figure that shames the amount AI gives back to the communities it affects, and undermines the company's claim that "the people who live and work around us influence what we do and how we do it; they are fundamental to the maintenance of our licence to operate". Holcim's hashtag campaign on Twitter is #we_stand_for. In the UK, to the communities AI affects, #we_stand_for means absolutely nothing.

When will AI actually talk to the people of Ottery St Mary?

Last year, Aggregate Industries said it was submitting a planning application to quarry Straitgate "in due course", but, as yet, no views have been canvased by the company from the local community.

AI may not have finalised its plans, but that is exactly the time to seek local input. In Northumberland, for example, Banks Mining are "inviting local people to come to a series of community workshops to meet the Highthorn project team and help shape the plans for the project" in advance of submitting its application. Even for the extension to Bardon Hill Quarry, AI claimed:

At Bardon Hill in Leicestershire we successfully gained planning permission to extend the life of the site in May 2011. The application was submitted some 18 months before – and community consultation began two years before that. We made presentations to different organisations with an interest in or responsibility to the area, took over 70 people on quarry tours, held three series of public exhibitions which were attended by 310 people, sent information and updates on the proposal to over 6,000 homes and met with 42 local residents in their own homes. Feedback from this exercise was sought to influence the details of the proposals and to accommodate expressed views wherever possible. Over 50 direct responses were been [sic] recorded with many of the suggestions being included in the final application. Through local engagement we have committed to a number of projects designed to enhance the lives of the people living within this community.

AI has done nothing so far to seek local views which might influence the details of any Straitgate proposal. Pre-application consultation with local communities is not just best practice, it's common decency. It's also what the NPPF expects:

188. Early engagement has significant potential to improve the efficiency and effectiveness of the planning application system for all parties. Good quality pre-application discussion enables better coordination between public and private resources and improved outcomes for the community. 

189. Local planning authorities have a key role to play in encouraging other parties to take maximum advantage of the pre-application stage. They cannot require that a developer engages with them before submitting a planning application, but they should encourage take-up of any pre-application services they do offer. They should also, where they think this would be beneficial, encourage any applicants who are not already required to do so by law to engage with the local community before submitting their applications.

Mineral industry prefers 'simple' sums

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

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

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

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

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

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

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

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

Miscellaneous

1. County Council Leader warns of more cuts

With headlines telling us Fresh cuts 'will push councils to breaking point’, and the Mineral Products Association telling us "the greater proportion of new permissions [for mineral extraction] granted since 2006 were for sites that were not allocated in mineral plans", people will wonder why we bother with the expense of Mineral Plans at all - the expense of flawed site appraisals, the expense of endless consultations that seem to influence nothing but what mineral companies want.

Council Leader John Hart said:

There are certain services we are required to provide by law but I’m afraid we have to ask some very hard questions about everything else we do. We’ve already exhausted the easier savings that we can make by being more efficient.

And the fact is, all Mineral Planning Authorities are required, by law, to develop plans for mineral provision. So whilst DCC cuts services, and charges a charity £45 for hanging some Christmas lights, rest assured that Devon's Mineral Planning function is here to stay.

2. Crackdown on illegal motorcyclists to protect East Devon Pebblebed Heaths

Clinton Devon Estates has complained that ‘illegal off-road motorcyclists risk damaging one of East Devon’s most important conservation sites and ancient monuments’; the same landowner that has, over many years, financially benefited from English China Clays and Aggregate Industries quarrying, processing and driving over the East Devon Pebblebed Heaths - an 'internationally important conservation site, designated a Site of Special Scientific Interest, a Special Area of Conservation and a Special Protection Area'.

A spokesperson for Clinton Devon Estates said: "We have reported the details of the motorcyclists to the police. The Pebblebed Heaths is a sensitive and much-loved conservation site enjoyed by hundreds of thousands of walkers each year. There are no rights of way across the heaths for motorised vehicles..."

A spokesperson for Natural England said: "East Devon Pebblebed Heaths SSSI is of national importance for its heathland, grasslands, mires and fens, breeding birds, and dragonflies and damselflies. Off-roading vehicles have the potential to damage and disturb these sensitive interests. Many of these features are also of international importance..."

A spokesperson for the Police said: "The police take this type of offence very seriously and work closely with Clinton Devon Estates, Natural England and English Heritage to protect the land from damage by motorised vehicles. It is an offence under the Road Traffic Act 1988 for anyone to drive a mechanically propelled vehicle across the Heaths..."

... Aggregate Industries' motorised and mechanically propelled quarry vehicles obviously excepted.

3. Anger over potential delays to restore quarry land in Aldborough Hatch

Another story of delayed restoration. A spokesman for the "Enough is Enough" campaign said:

The residents were told these workings would take six years. They have taken almost 12 – twice as long. And it is laughable to plead lack of infill whilst Crossrail continues at a pace. Councillors must stand firm and they can rest assured that they will be held to account if they do not by the residents of Aldborough Hatch.

A local resident said:

I have had to live with the noise, dust and pollution coming from it for the last 12 years. Redbridge Council needs to now think about the best needs of the residents. We have lived with Lafarge and their desecration of the landscape enough and expect the council to back us in any further attempt by them to spoil the area.

4. Opponents of quarry gain a victory

Plans for a sand and gravel quarry in South Oxfordshire have been thrown in doubt following a decision by English Heritage to recommend protection for a Bronze Age barrow cemetery.

5. Sand and gravel proposal fails to win consent

Gloucestershire County Council has refused permission for sand and gravel extraction at a site near Tewkesbury because of concerns about noise, dust and visual impact.

6. Gillies Hill quarrying plans lodged

Planning applications for quarries tend to evoke similar negative reactions country wide. One community feels so strongly that it is not only raising money for professional help, but has, for more than five years, been producing its own ‘shadow’ environmental impact assessment. Plainly it feels that it cannot trust the environmental impact assessment produced by consultants working on behalf of the minerals company.

7. Asia’s fragile caves face growing development risks

Mineral companies like to greenwash their activities by talking about the work they do for endangered species - the MPA's Christmas card being an example - but scientists have confirmed that Holcim - Aggregate Industries' parent company, a Swiss cement conglomerate that is "striving to achieve better biodiversity conservation" - has, by years of quarrying in "an internationally recognised hotspot of invertebrate biodiversity", not saved, not protected, but "caused the extinction of a number of species".