Wednesday, 10 July 2019

AI launches another retrospective planning application



Aggregate Industries has launched a planning application, DCC/4132/2019, "to continue importation of inert soils and subsoil to allow for revised restoration contours at Marshbroadmoor including a revised restoration scheme at Rockbeare Quarry."

Mineral extraction at Marshbroadmoor ceased in 2014. Importation of material has since continued despite "3.3 Condition B1 of Schedule B of planning permission Ref. 7/11/98/P0050 required the cessation of operations at Marshbroadmoor by 25th of April 2015."

Over the years we’ve posted about nearby Marshbroadmoor and Rockbeare – the latter being the area that had previously been earmarked, by both AI and DCC, for processing material from Straitgate Farm. We’ve posted things like: AI says it's done this sort of thing before - if so, it was breaching planning conditions, and how AI's asphalt plant at Rockbeare continues to operate without permission.

Incidentally, for anyone banking on Straitgate delivering the goods, Marshbroadmoor was one of the quarries mentioned in AI’s last two quarries in East Devon produced significantly less than expected - and there's every chance Straitgate would too:
The original planning application gave a figure of 1.1 million tonnes, but, due to geological faulting, nothing like that amount ever came out. After an 'incidental' amount was transported to Hillhead for processing, an application was made in 2010 for the bulk of the reserve, some 176,000 tonnes, to be processed at Blackhill.
This new planning application "includes an overall restoration masterplan for both Marshbroadmoor and Rockbeare Quarry which will provide for a more comprehensive, coherent scheme." The volume of material required to complete restoration is "estimated to be approximately 118,000m3", which at 15 tonnes per load equates to another 30,000 truck movements "likely to average 40 (20 in, 20 out) per day."

One aim of the restoration will be to "to ensure the stability of RB2":
3.19 The large waterbody known as RB2 is a former silt pond. It was originally intended to infill the pond under the previously approved restoration scheme. The pond is currently (and will continue to be) used to accept surface water drainage that is pumped from a sump near the Waycon Precast Concrete site. Given the need to retain the pond and potential ecological value, it is no longer intended to infill completely.
3.20 The restoration of RB2 will be reliant on the stability of the surrounding slopes and silt content. A survey of the slopes is required and the applicant is willing to accept a condition requiring one to be undertaken within a specified timeframe alongside a restoration scheme solely for RB2…
3.22 The reduction in the size of RB2 and the proposed planting will make the waterbody less attractive to birds which may present a bird strike risk given the site’s proximity to Exeter Airport.
Three other water bodies, that were originally proposed to be infilled will now also be retained – directly below the landing path to Exeter Airport – apparently in agreement with DCC.

Mineral extraction at Rockbeare dates from 1947 and at Marshbroadmoor from 1997. The retrospective application seeks to amend the restoration scheme such that the "final restoration of Marshbroadmoor will be completed by April 2022" and "the timeframe for restoration of Rockbeare… remains up to 21st of February 2042."

AI’s consultants say – without any trace of irony – that over that 95-year interval:
5.1 The effects associated with the operational development will generally be considered to be temporary in nature, mineral development and restoration representing a temporary use of the land. Long term effects arising from the finalisation of the operations and final restoration will generally be considered permanent and beneficial in nature.
On the latter issue – how restoration will benefit nature – here’s the document spelling out how AI will deal with the removal of habitat at Marshbroadmoor for nesting sand martins.
It is not considered safe or feasible to maintain or create a face suitable for nesting Sand Martins as part of the final restoration scheme.
Is this another example of Aggregate Industries making space for nature?

Consultation for the above application remains open to the public until 1/8/2019.

Photo: Sand martins at Tarmac’s Arcow Quarry, in North Yorkshire, by Michael Cardus

Quarry firms criticise council for allowing “unregulated mineral extraction”

What hope is there of Devon County Council and the Environment Agency being able to police Aggregate Industries’ complicated working scheme at Straitgate Farm – "untried anywhere else in the country"? What hope of stopping water supplies from being harmed when excavators are let loose? What hope of knowing what goes on, or what depths would be reached, behind closed bunding.

What hope? None at all.

Two of the country’s leading building materials firms have accused local authority planners of allowing a large mineral extraction operation to continue unregulated.
It's not surprising. Planning conditions are broken all the time.


If AI can't be bothered to fulfil its Blackhill obligations, what hope is there for Straitgate? What hope for people who lose their drinking water supplies? What hope for people whose supplies become contaminated? What hope for timely action, when the last three hydrological monitoring reports for Blackhill have either been submitted late or not at all, when surface flows haven't been measured since 2011?

Friday, 5 July 2019

Cyclist in her twenties crushed by Aggregate Industries cement lorry in Battersea


London Concrete – part of Aggregate Industries – was quoted in the Evening Standard as saying:
It is with deep regret that we can confirm a vehicle owned and driven by a self-employed franchise haulier was involved in a fatal collision with a cyclist. Our sincerest sympathies go out to the family of the deceased. London Concrete are currently working closely with the authorities to fully investigate the incident.





We have only recently posted about AI’s HGVs in the real world.

Crikey, yet another change at the top of Aggregate Industries’ aggregates division

Barely 12 months into his role, Pablo Libreros – appointed as "new managing director to lead aggregates business into the future" – is off already. Mr Libreros has moved to LafargeHolcim France. No news of any replacement yet.

Another case of musical chairs, or rats deserting a sinking ship??

It was only last year that we posted AI appoints new head of Aggregates division, again:
Readers may remember that in July [2017] AI appointed Mike Pearce as managing director of its Aggregates division, only to see him move on to Breedon two months later. 
And of course, it was only in December that AI lost another CEO:
During the time that AI has been trying to get its act together in East Devon – to gain permission to butcher a successful farm and risk water supplies for more than 100 people for the sake of a relatively small amount of sand and gravel that could only be processed off-site 23 miles away – the company has gone through three CEOs, and will now be looking for its fourth.
We asked:
Is this simply an indication of how long the Straitgate Farm fiasco has been staggering on, or an indication of deeper problems?
Certainly there seems to have been an attrition of directors recently. In the last few months two other directors have gone: Duncan Reaney, Growth and Innovation Director – who only joined in May 2018, with "a portfolio covering Marketing, Sales Excellence, Internal sales and Pricing" – and James Atherton-Ham, General Counsel – who amongst other duties, "was responsible for the planning and estates and geological services teams".

Closer to home – as we have previously posted – people behind the Straitgate Farm proposal have been leaving too. In fact, the regional director who had been driving the Straitgate project for so many years, before moving elsewhere in the company, can now be found working for a competitor – part of the same company that purchased AI’s bagging operation at Uffculme. Small world.

Thursday, 4 July 2019

‘Proposed quarry could affect safety of flights at Airport’

RAF Boeing C-17 Globemaster flying low over Straitgate Farm

In its submission, CIAL says the proposed quarry "is likely to have more than a minor adverse effect on the safe, efficient and unrestricted operation" of the airport. Ponds for quarry wash and sediment treatment, along with puddles after heavy rain, could attract seagulls and other scavenging birds, "increasing the risk of bird strike". The proposed quarry was also in line with the centre of the main northeast-southwest runway and as a result directly beneath the flight path for arriving and departing planes.
Air New Zealand says it opposes the quarry development for the same reasons. "The risk of bird strike occurring is increased by factors such as bird concentrations as a result of storage of water on sites near to flight paths. Bird strike has the potential to cause serious damage to aircraft and consequently impact the safety of passengers and crew."
Exeter Airport has not objected to quarry proposals at nearby Straitgate Farm, directly below its landing approach –


– but then again they were spun a story from Aggregate Industries that no bodies of water would be created by its quarry proposals; Aggregate Industries being the same people who plan to dig down to the maximum water table at the site, but have not yet been able to work out exactly how high the groundwater rises, the same people whose infiltration ponds can't work in the areas proposed because the groundwater is so close to the surface, the same people whose restoration plans propose "Ephemeral water bodies and species-rich wet grassland to be encouraged in low-lying infiltration areas", the same people who made similar assurances about dry-working elsewhere in the area.

Holidaymakers returning to Exeter Airport, flying low over Straitgate Farm


Canada geese flying over AI’s nearby Blackhill Quarry:

UK construction sector suffers worst output in 10 years

If Aggregate Industries is waiting for the economic headwinds to improve – before progressing its application to quarry Straitgate Farm after continued delays – they may be in for a long wait:
Activity in the UK construction sector "dropped like a stone" last month as it suffered its steepest fall in output since the height of the financial crisis, according to a closely followed industry index.
The headline seasonally adjusted IHS Markit/CIPS UK Construction Total Activity Index posted 43.1 in June, down sharply from 48.6 in May and below the 50.0 no-change mark for the fourth time in the past five months. The latest reading signalled the steepest reduction in overall construction output since April 2009.
Not only that. Construction firms are going under at the highest rate for four years; after the failures at Carillion and Interserve, witness the recent problems at Keir and Costain:
There are now signs that the sector may be facing some serious issues once again as output declines and employment numbers fall.
Last year we pointed to another aggregates company, posting that whilst AI’s profits were down 56% in 2017, Breedon’s profits were up 52%. Now even Breedon is finding the going tough:
On a like-for-like basis, underlying EBIT declined by six per cent... reflecting the slow start to the year due to severe weather, challenging markets, rising input costs and the general uncertainty around Brexit.
Of course, a no-deal Brexit is looking more and more likely as the pantomime in the Tory party plays out – "as though facts are meaningless":
If a no-deal Brexit is as catastrophic as predicted, this could create a perfect storm of job losses, citizens unable to pay off their debts and the economy tanking. This in turn, could lead to a run on the pound and interest rates rising – which is bad news for those with large debt.
Moody's, the international credit rating agency, predicts that the UK is likely to fall into recession after a no-deal Brexit.

So, if Aggregate Industries – and parent company LafargeHolcim, holder of the purse strings – are waiting for things to improve, it may be some time.

‘Time is running out for sand’

Across the world, sand and gravel are being extracted faster than they can be replaced, according to a new report published in the journal Nature:
Most of the trade in sand is undocumented.... Illegal sand mining is rife in around 70 countries, and hundreds of people have reportedly been killed in battles over sand in the past decade in countries including India and Kenya, among them local citizens, police officers and government officials.
A group of scientists has now called for a global monitoring programme for sand resources – "A Global Agenda For Sand":
In order to move towards globally sustainable sand extraction, we need to fully understand the occurrence of sustainable sources, and reduce current extraction rates and sand needs, by recycling concrete and developing alternative to sand (such as crushed rocks or plastic waste materials). This will rely on a knowledge of the location and extent of sand mining, as well as the natural variations in sand flux in the world’s rivers. A global sand monitoring program is thus imperative.
The researchers say there are seven components essential for sustainable sand extraction: Source. Replace. Reuse. Reduce. Govern. Educate. Monitor.

At least three of those components are as applicable in the UK as they are elsewhere:
Replace. Local and national governments and planning authorities should encourage greater use of alternatives to sand, such as crushed rock, industrial slag and waste (including copper, fly ash and foundry sand) and recycled plastic. For example, roads, car parks and driveways made from plastic waste embedded in asphalt can lessen demand for bitumen and aggregate.
Reuse. Sand-based materials should be reused when possible. For example, demolition waste and concrete can be crushed and mixed into cement. Rubble can be used as a base aggregate for building foundations and roads, for filling holes and as gravel for walkways, gardens, noise barriers and embankments. Legislation and controls on the disposal of concrete, and financial incentives to reuse old concrete, will be needed.
Reduce. Cutting the amount of concrete required in new structures would also lessen the demand for sand. This could be achieved by using more efficient materials (such as concrete blocks and printed construction panels with hollow cores). Industry standards for material qualities will be needed and should be backed up by regulations to enforce usage.

Deep sea mining: Have we lost our minds?

On practically every mission down to the deep, scientists discover new species. We know more about the surface of Mars and the moon than about the bottom of the ocean. Mining the deep sea sounds just as ludicrous as mining the moon.
We’ve already seen the huge destruction ravaged upon our planet by corporations mining on land. Are we really prepared to give the go-ahead to the mining industry expanding into a new frontier, where it will be even harder for us to scrutinise the damage caused?

Friday, 28 June 2019

EA’s model of Otter Valley groundwater levels “as much as 15m adrift”

The Environment Agency plainly thinks that Aggregate Industries’ consultants can accurately predict the maximum winter water table and base of any quarry at Straitgate Farm to cm precision – across some 55 sloping and geologically faulted acres – with just six data points.

It is of course nonsense. Professor Brassington is clear:
...the MWWT is not a representation of the maximum water table readings for the proposed quarry site 4.16
Dr Rutter was also concerned about AI’s groundwater predictions at Straitgate:
This surface is only a model of reality, and may not represent actual groundwater levels across the site…
There are many private water supplies reliant on the aquifer underlying Straitgate Farm. The EA has a statutory duty to protect and improve the water environment through effective management of water resources and by reductions in pollution. The EA obviously has a short memory about the difficulties of modelling groundwater levels in the Otter Valley:
The Permian and Triassic sandstone aquifer in the Otter Valley is one of Devon's largest groundwater sources, supplying drinking water to 200,000 people.




The National Rivers Authority, the EA’s predecessor, produced a four volume Environmental Study of the River Otter in 1994, based on their network of observation boreholes.

Volume 4 of the report accepts that:
The Otter Valley Triassic aquifer is complex. As a result there is considerable spatial variation in groundwater level response to natural recharge.
Water level responses are influenced by many factors. Those of greatest significance include: * proximity to areas of groundwater discharge; * proximity to the river, where changes in stage are reflected as groundwater level fluctuations; * proximity to the coast, where tidal responses are similarly reflected; * proximity to abstraction points; * thickness of the unsaturated zone, and the presence of low permeability material in the sequence...
But the bombshell is in Volume 2:
A substantial amount of work in this area has already been done by MRM Consultants (1989), who developed a ground water model of the sherwood sandstone aquifer in the Otter Valley. The model was used to assess the likely impact of certain abstraction policies on ground water levels in the aquifer, and resultant changes in the flow regime of the Otter between Fenny Bridges and Dotton. Calibration of the model was difficult to achieve, and modelled ground water levels were sometimes as much as 15m adrift from estimated ground water level after calibration. These discrepancies probably arise from the adopted assumption that the aquifer permeability is constant across the whole catchment (ie that the aquifer is homogeneous and isotropic). In practice, permeability can be highly variable, substantially affecting local transmissivities and rates of water table recession and drawdown. 3.1.6
So, the best that these consultants could produce for the EA – using records collected over almost two decades – was a model of groundwater levels "as much as 15m adrift."

It’s perhaps not surprising. After all, as this EA technical report makes clear:
A model is a tool, not a substitute for reality.
So, why then has the EA so much faith in AI’s model of maximum groundwater levels at Straitgate Farm – given that it was produced by consultants Amec Foster Wheeler (now Wood Group) who were looking to accommodate their client’s desire to maximise the recoverable resource, given that it was produced from groundwater levels recorded from just six boreholes only 12 months after they were drilled?

Why too – in an effort to support AI’s assertions that those groundwater levels at Straitgate can be relied on to be the highest ever – does the EA rely on groundwater levels from an assortment of boreholes on Woodbury Common and elsewhere, an assortment of boreholes up to 93m deep (at Straitgate they're 6-12m deep), including ones in different geology, and one going no further back than 2008? Why does the EA choose to ignore actual evidence from the site? Why does the EA choose to ignore higher baseflows in previous years from one of the streams emanating from Straitgate? Why does the EA choose to ignore groundwater levels from June 1990 in one borehole that shows water levels almost 3m higher than AI’s best guess close to where 'Drillers were surprised they struck water so quickly' in June 2017?

It’s a mystery – particularly as AFW has been so evasive over telling us, DCC and the EA the accuracy of the MWWT. No model can be 100% accurate. This paper says:
…it is vital that the uncertainties of the modelled GWLs are quantified so that land managers and scientists interpreting predictions can determine which features reflect statistically significant variation in groundwater processes rather than model errors.
It was back in January 2016 that we first asked DCC:
Since AI now intends to dig right down to the maximum water table, perhaps you could ask Amec to confirm the specific level of accuracy (in +/- m) to which their maximum groundwater contours are mapped?
AFW were asked again in 2017, but still refused to answer – even to the EA.

In February 2018, the EA asked again:
We recommend that a description of tolerance levels is therefore requested again from the applicant to support the planning application and to provide clarity in advance of the Planning Committee.
If any answer has subsequently been provided that adequately deals with tolerance levels, none has yet been made public. Why have AI’s consultants been so reluctant to provide an answer? Is it the risk that their groundwater predictions would look no more reliable than a chocolate teapot?

In any case, AFW’s model of groundwater levels factors nothing in for climate change. BGS – in "Groundwater and climate change" – forecasts that during this century:
annual rainfall will remain about the same but winter rainfall will increase by 10 to 30% over most of the country
Producing:
increases in average winter [groundwater] levels, by the 2050s under a high greenhouse gas emissions scenario...
Perhaps it's for these reasons that Prof Brassington wrote:
If Devon County Council are minded to grant permission for these proposals, despite the evidence given in this report, they are asked to ensure that an unquarried buffer of at least 3 m is left above the maximum water table to minimise the negative impacts. It has already been demonstrated that the MWWT surface cannot be modelled accurately, neither can the MWWT be reliably adhered to during the operational phase. 6.14
It's important to get this right, particularly for those relying on the site for their drinking water.

It's important for AI too. They wouldn't want to be looking at scenes like this in the future:

FM Conway ‘pushes boundaries of asphalt materials recycling in highways industry’

Whilst LafargeHolcim, the parent company of Aggregate Industries, bemoans the lack of demand for greener products – see post below – other companies in the construction industry are challenging working methods and using increasing amounts of recycled material.

For example, FM Conway working with Westminster City Council has recently laid a road surface containing 80% recycled materials:
Traditionally, this has been limited to 50% for the lower layers of roads and just 10% for the surface courses of motorways and ‘A’ roads.
Operations director at FM Conway, said:
With the UK’s materials reserves under pressure, we need to continue to challenge convention and invest in the re-use of highway arisings.

‘Cement Produces More Pollution Than All the Trucks in the World’

... warns an article in Bloomberg. It's a mind-blowing statistic.

There are greener alternatives to cement, but the Head of Sustainability at LafargeHolcim – parent company of Aggregate Industries and the world's biggest cement producer – claims:
There is so far too little demand for sustainable materials. I would love to see more demand from customers for it. There is limited sensitivity for carbon emissions in the construction of a building.
Which sounds like business as usual then, and little sign that LafargeHolcim is fazed by our climate crisis.

Shirley Rodrigues, Deputy Mayor for London, says:
It’s very difficult. What we can do is to start to send a signal. We’ve got a new requirement for developers that they must develop a circular economy statement to show how they will reduce, reuse and recycle materials.

French court of appeal to rule on LafargeHolcim terrorism charges

Executives from the parent company of Aggregate Industries have been accused of financing terrorism in Syria. We have posted on the subject before.

Global Cement now reports:
The Court of Appeal in Paris will decide on 24 October 2019 whether charges of financing terrorism and crimes against humanity will be upheld.

Thursday, 20 June 2019

LafargeHolcim: Acting in a way that would ‘wipe out most life on the planet’

Aggregate Industries is a subsidiary of LafargeHolcim – the world’s largest cement producer.

You only have to look at AI’s record on CO2 emissions – or for that matter its proposal for Straitgate Farm to haul material 23 miles for processing, a total of 2.5 million miles in all – to tell that neither of these companies is taking our climate emergency seriously.

And that’s also the conclusion from a new study.

Financial Times analysis of Carbon Delta data shows "only 15 per cent [of the top 500 companies] are in line with the goals of the Paris climate accord, which seeks to limit global warming to well below 2C."
This analysis maps out each company’s current behaviour, and correlates it with the level of global warming it would imply by the end of the century if every company in the world made similar choices.
And LafargeHolcim is the worst of the bunch.

In fact, if other companies acted like LafargeHolcim, we would find ourselves not "well below 2C" but in a +6°C warmer world by the end of the century – within the lifetime of children being born today.



Contrast this finding, with the greenwash pumped out by LafargeHolcim:


Despite the direction of the graph, despite the ambition, despite the greenwash, in reality – as we posted in LafargeHolcim has a way with numbers – CO2 emission numbers – LafargeHolcim’s net CO2 emissions increased in 2018 to 121,000,000 tonnes*, up from 118,000,000 tonnes in 2017, up from 115,000,000 tonnes in 2016:
To put that 121 million tonnes of CO2 into context, it is equivalent to the emissions from 31 coal-fired power stations. To sequester this amount of CO2 would require 142 million acres of forest – an area more than twice the size of the UK.
Welcome to the world of LafargeHolcim – one of the biggest corporate polluters on the planet, increasing its CO2 output each year, acting in a way that would wipe out life on earth.


But what about those working for LafargeHolcim and other such polluting companies? The BBC points to a coal mine reopening in Cumbria, and asks:
The mine will create at least 500 well-paid jobs, but there is a large environmental impact. Would you take a job at the mine?
As one interviewee puts it:
As a human civilisation, we all have to help each other. And we all have to work together. And it’s not just about me getting a good salary, it’s about ensuring that the world stays alive.

* Net CEM CO2 emissions. Total gross direct CO2 emissions 135Mt. Total indirect CO2 emissions 30Mt. Source: LafargeHolcim Sustainability Report 2018

Why is a stream’s baseflow important?

Groundwater sustains the flow of streams and rivers when it's not raining. The groundwater component of a stream's flow is referred to as the baseflow or low flow.

Baseflow is important "for sustaining human centres of population and ecosystems."

It's important at Straitgate too. In one of the streams emanating from Straitgate, such flows sustain Cadhay’s mediaeval fish ponds and stop them from turning into a quagmire. In another stream, such flows sustain wetland habitats in ancient woodland:



The amount of baseflow is determined by groundwater levels. Professor Brassington's report pointed to the baseflows (in 1976/77 and 2000/01) from yet another of Straitgate’s streams – as a reason why Aggregate Industries’ model of the maximum water table at Straitgate Farm (based on the winters of 2013 and 2014) cannot be trusted.


Groundwater is important in sustaining streams and water sources during dry periods. Look at these recent tweets from the UK Groundwater Forum and the Environment Agency's Groundwater & Contaminated Land Team:



AI’s HGVs in the real world

Aggregate Industries has previously pointed to dangerous lorry driving and how safety must come first:
Throughout the duration of 2017 there has been an influx of headlines around poor lorry driving which has led to structural damage of property and infrastructure, accidents and, most tragically of all, fatalities.
As part of an ongoing crackdown on bad driving etiquette by Highways England, last month (November 2017) saw one UK County conduct secret filming which worryingly captured a number of HGV drivers using their mobile phones, watching YouTube videos and even reading books behind the wheel
In 2019, this sort of thing is still going on – including by AI's own drivers.



Since then twitter has been busy exposing further examples of AI's HGVs in the real world:












Wednesday, 19 June 2019

Straitgate determination date extended for 8th time


Last month, we asked Is there any life left in AI’s application to quarry Straitgate, or is it just "resting"? Now, whether there's any life or not, Devon County Council and Aggregate Industries have agreed yet another extension for determining the planning application to quarry Straitgate Farm, this time "from 28th June 2019 to 31st December 2019".

For those who have lost count, it’s the 8th such extension – if we ignore the company's first application for Straitgate back in 2015, that had to be withdrawn in 2016 after AI forgot to ask permission from a landowner whose field was to be used for site access.

Of course, as with the other extensions, there’s been no visible progress from AI since the last extension.

So, what on earth can AI be finding so difficult – that requires so much time, and so many extensions??

Is it the hydrogeology, and the impact AI’s plans would have on private water supplies and Grade I Cadhay? Is it Professor Brassington’s recent report concluding that 'ANY quarrying at Straitgate would cause problems', a report which has prompted new objections, including this one?



Is it proposing what must be the UK’s most ridiculous and unsustainable quarry scheme – to haul as-dug material 23 miles away for processing – at a time of increasing concern and awareness about our climate emergency?

Is it – with a newly rebuilt plant at Hillhead together with 4 million tonnes of permitted sand and gravel reserves next door – the slow realisation that AI doesn’t really need the ever-shrinking resource at Straitgate after all?

Is it that LafargeHolcim bean-counters have finally cottoned on, that – with a working scheme that (according to Prof Brassington) "will not work in practice", with associated infrastructure, extensive archaeological investigations, restoration, legal agreements, and multi-million-mile haulage costs – Straitgate Farm is never going to be worth it?

Or is the company just sitting on its hands, twiddling its thumbs, stringing DCC along, waiting for the Brexit mayhem and associated economic uncertainty to pass? As if that's going to happen anytime soon.

It’s now over 4 years since AI’s application for Straitgate went live, and almost 2 years since any substantive information was supplied by the company.

In 2015, AI was in a rush to quarry Straitgate. In 2017, AI was in a rush to quarry Straitgate. Now, in 2019, having kicked the can down the road for another 6 months, AI is plainly coping quite well without Straitgate's relatively small amount of sand and gravel after all.

Wednesday, 12 June 2019

CEMEX quarry plan in Suffolk – underlines AI’s reckless stance to water at Straitgate


Concerned residents in Suffolk have directed us towards a planning application submitted last month by CEMEX to quarry Lime Kiln Farm, an extension of Wangford Quarry. The site has been proposed by Suffolk County Council as a Preferred Area for gravel extraction in its draft Minerals Local Plan, despite being in the Suffolk Coast and Heaths AONB – where "planning permission should be refused for major development other than in exceptional circumstances" NPPF 172.

Readers will remember Aggregate Industries’ attempts not so long ago to win consent in the East Devon AONB – to process material from Straitgate at their existing plant adjacent to the East Devon Pebblebed Heaths. Approval would have meant a continued blight on Woodbury Common, and would have introduced nitrate-rich agricultural soils into an area sensitive to any nutrient change. After concern from Natural England, AI withdrew its application and has now relocated the plant.

But we’ve digressed. The reason for this post was to contrast the difference between CEMEX and AI in relation to protecting nearby groundwater supplies.

CEMEX has submitted a range of documents in support of its application to extend Wangford Quarry and to quarry up to 1 million tonnes of gravel over some 11 years. The small number of documents submitted by CEMEX contrasts with the huge jumble of fragmented reports AI has been forced to submit in its multi-year quest to win consent to quarry Straitgate Farm – a clear indication of the number of constraints the company faces here in East Devon.

One of the CEMEX documents is a Hydrogeological Assessment – again, a brief affair compared with the tomes supplied by AI’s consultants Amec Foster Wheeler for Straitgate. Interestingly, CEMEX’s consultants rely on "(Brassington, 2007)" – a reference to academic literature by Professor Brassington, a leading authority on groundwater, who recently wrote a damning report concluding that 'ANY quarrying at Straitgate would cause problems'. For the Wangford extension, the salient features are a public water supply 280m away, no private water supplies located within 2km, and a proportion of the site within an Environment Agency Source Protection Zone 2. Groundwater levels have been monitored close to the proposed site since 2002 and show a typical range of 0.6 to 1.4mAOD. In contrast, at Straitgate, which also has a SPZ2 designated across part of the site, groundwater levels have been monitored since 2013 and fluctuate in some areas by no more than 24cm and other areas by as much as 6m.

CEMEX’s report is in stark contrast to the risks AI is prepared to take with the "fragile groundwater system" at Straitgate. The conclusions from CEMEX's consultants, JBA Consulting:
Quarrying involves activities that have the potential to affect the hydrogeological environment of the area. These activities have been identified and an assessment of their potential effects made.
The operational phase potentially poses the greatest risk to the groundwater regime because it will involve constant earthworks and frequent vehicle movements. There will also be minimal vegetation and no soil within the excavation area.
The main potential impacts to the hydrogeological environment are: alteration of recharge pattern, reduction in groundwater quality and increased groundwater vulnerability.
Proposed mitigation measures include the use of a Pollution Prevention Plan and the limitation of all workings to at least 1m above the highest water table.
Yes, that’s right. For this very level Suffolk site, where the maximum groundwater level is relatively easy to model, CEMEX still proposes that working will be limited to "at least 1m above the highest water table". CEMEX's Non-Technical Summary reiterates:
Historically quarrying has always left 1 metre of undisturbed sand and gravel between the bottom of the quarry and the surface of the groundwater. It is proposed to continue to do this when quarrying Lime Kiln Farm. This will, however, reduce the depth of dry, or unsaturated, sand and gravel that lies above the groundwater. In turn, this means that it is easier for potentially polluting liquids, such as fuels and lubricants, to reach and pollute the groundwater if they are spilt. 2.7.4
In contrast, at Straitgate, AI is proposing to leave a 0m unquarried buffer above the maximum water table; a maximum water table the exact position of which is still unknown, and where – as AFW admitted before whitewashing its reports – "there is the possibility for steps in the water table related to faulting" and "there is also likely to be other unmapped local faulting".

The aquifer underlying Straitgate supplies water to more than 100 people, to livestock farms, wetland habitats in ancient woodland, mediaeval fishponds, and a Grade I manor house. Dr Rutter is "concerned that there is a very steep hydraulic gradient across the site... Variations in the shape of the water table cannot be contoured based on the number of piezometers used". Prof Brassington says "an unquarried buffer of at least 3 m [should be] left above the maximum water table to minimise the negative impacts".

If AI doesn't propose to leave an unquarried buffer above the maximum water table to safeguard water supplies – a buffer typically employed by CEMEX, Hanson and others, as we posted in Quarry companies struggle to dig in the right direction, let alone to the nearest cm – what does it propose? AI's cunning plan is to rely on groundwater levels falling by at least 1m over the summer months – and clearly in some areas they don’t – before digging down to the maximum water table, and backfilling with overburden before groundwater levels rebound in the winter. Prof Brassington says it’s "untried anywhere else in the country" and "too difficult for typical machine operators". We’ve posted on the scheme before in No wonder AI wants to keep Straitgate’s groundwater data secret, Seasonal working scheme for Straitgate can't work as AI describes and AI was asked a very simple question.

If that doesn’t ring warning bells, consider that the authors of this "revolutionary" scheme – at AI and consultants AFW – are both no longer with their respective companies.

What if this experiment screws up drinking water supplies and mediaeval fishponds? Who would sort out the mess, given AI’s legal assurances for alternative water supplies are “unfit for purpose”? Let’s hope the EA and DCC have some good answers. They could never say they weren’t warned.

An indication of things to come

In a post earlier in the year, Construction, demolition & excavation waste – largest waste stream in UK economy, we pointed to figures from the Minerals Products Association – the trade body representing Aggregate Industries and others, who claims "the need for resources and waste materials to be used more efficiently and effectively has never been so strong" – telling us that 120 million tonnes of construction, demolition and excavation waste is created each year – the largest waste stream in the UK economy – of which 26 million tonnes continues to be dumped in landfills.

The UK Green Building Council says "construction is still getting the circular economy wrong":
In the UK, construction, demolition and excavation account for 60% of both material use and waste generation. Humanity is on course to triple material extraction in the next 30 years and triple waste production by 2100.
Clearly the construction industry can't keep on like this. Fortunately there are signs – in these three recent stories – that some things are slowly moving in the right direction:

CDE recycling is set to receive a boost in the South West. A new £4m recycling plant has been set up on the outskirts of Bristol in response to demand. The materials recovery facility is set to be the most efficient and effective plant in the South West, processing construction and commercial waste, producing 'zero waste to landfill'.
The contractors that choose us are the ones that have environmental management systems at the forefront of their procurement so their sites have to be as close to ‘zero waste to landfill’ as possible. This new plant is the only one in the south-west that can process construction and demolition waste to that degree.


Meanwhile, Tarmac has become the first company in the UK to develop a new rubberised asphalt using recycled waste tyres. Some 40 million waste tyres are produced every year in the UK. The new material has been trialled in Coventry. Coventry City Council's senior highways engineer said:
We are delighted with the rubberised asphalt trial; we hope we can use more of the product across the city in the future to help divert waste tyres from landfill and incineration to reduce the carbon footprint for road construction projects in Coventry.
The Tyre Recovery Association, added:
While there has been significant progress in reusing and recycling waste tyres in the UK, there is still an over-reliance on the export of used tyres to countries such as China, India and Pakistan, who are importing fewer tyres as they become self-sufficient.
The UK needs a second disposal route for used tyres. Tarmac’s commitment to developing rubberised asphalt provides an excellent opportunity to achieve this and deliver environmental savings for this under-used waste stream.


Finally, in an indication of the recycling rates in construction waste that can be achieved – Station demolition achieves 95% recycling rate:
100% of the brick, timber and concrete removed from the site during the demolition work has been recycled for reuse elsewhere in the construction industry.

UK commits to ‘net zero’ emissions by 2050; Ottery declares climate emergency

The UK is set to become the first G7 country to legislate for net zero emissions. One architect of the Paris climate agreement said:
Theresa May, desperate to leave a positive legacy, said:
Now is the time to go further and faster to safeguard the environment for our children. This country led the world in innovation during the Industrial Revolution [through the use of fossil fuels], and now we must lead the world to a cleaner, greener form of growth.
Environmental groups welcomed the news, but were concerned that it wasn’t far or fast enough, and that the UK would retain the ability to use international carbon credits. The acting energy minister, said the government did not "intend" to use such credits but had kept it "as an option". The Committee on Climate Change had warned "it is essential that the commitment [to net-zero] is achieved without use of international credits". The chief scientist for Greenpeace UK said:
As the birthplace of the Industrial Revolution, it is right that the UK is the world’s first major economy to commit to completely end its contribution to climate change, but trying to shift the burden to developing nations through international carbon credits undermines that commitment. This type of offsetting has a history of failure and is not, according to the government’s climate advisers, cost-efficient.






As part of the declaration, Ottery Town Council will set up a working group consisting of "councillors, residents, experts, scientists, businesses and young citizens" to recommend actions, policies and changes "to make Ottery St Mary a carbon-zero town by 2030".
Anyone interested in joining the group or has interest or knowledge of environmental issues, the science behind climate change and the local geography and economy should email the assistant town clerk.
Ottery St Mary’s new Mayor said:
Ottery St Mary has been at the forefront of environmental actions for a very long time. We have enjoyed the benefit of several excellent green groups: Recycling in Ottery almost 25 years ago, followed by Otter Rotters and most recently the Plastic Free Ottery group.
It is, therefore, entirely appropriate Ottery will become one of the first towns to comprehensively address this crucially important issue.
I look forward to Ottery St Mary Town Council engaging with local people - especially with younger people - to fully play our part in tackling the great threat of climate change.