Wednesday, 16 November 2022

Town Farm Quarry extension

A planning application by Hanson to extend working at Town Farm Quarry, near Burlescombe, of the Budleigh Salterton Pebble Beds – the same sand and gravel resource that underlies Straitgate Farm – has been validated by Devon County Council this week. Application DCC/4326/2022 is for: 
Variation of condition 2 of permission number DCC/2770/2009 for the extension of time for a period of 10 years to allow for the completion of approved mineral extraction and restoration 
Hanson’s Non-Technical Summary says: 
1.2 Planning permission was originally granted by Devon County Council (Devon), the mineral planning authority, in 2010 for the development of a lateral extension to the original Town Farm Quarry. The sand and gravel in the extension area was due to be worked out and the land restored by 14 November 2022. However, output from the quarry has been less than expected and there remains a substantial volume of sand and gravel that will not be extracted by the current end date. 

13.3 Mineral extraction and restoration is expected to take a further 10 years and it is proposed to extend the end date by 10 years from 14 November 2022 to 14 November 2032. The proposed variation to condition 2 is set out below. Proposed Variation of Condition 2 The winning and working of sand and gravel at the site shall cease and the site be restored in accord with the approved Restoration Masterplan by 14 November 2032. 

14.2 There remains approximately 1 million tonnes of sand and gravel reserves yet to be worked and this material cannot be extracted, nor the Site restored by 14 November 2022. A time extension of 10 years is sought to allow all the remaining mineral to be extracted and the restoration to be completed. There are no other alterations to the approved development. 
Devon County Council’s most recent Local Aggregates Assessment says: 
2.5.8 Town Farm forms part of Hanson’s Whiteball operation, for which the processing plant lies in Somerset adjacent to its border with Devon. In recent years, extraction of sand and gravel for Whiteball has taken place within Devon at Town Farm; however, an application was submitted to Somerset County Council in March 2017 for the extraction of 400,000 tonnes of sand and gravel at Whiteball within Somerset, and this is awaiting determination. 

2.5.9 Following completion of extraction at Town Farm, it is anticipated that the Whiteball processing plant will be supplied from materials extracted in Somerset, for which Somerset County Council’s Minerals Plan identifies a Preferred Area and an Area of Search. This suggests that, during the latter part of the period to 2033 covered by the Devon Minerals Plan, some of the sand and gravel supply previously delivered from Devon will be met from Somerset through continued working at Whiteball.
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Tuesday, 8 November 2022

COP27 has begun, and suddenly the polluters pretend to care

Aggregate Industries and its parent company Holcim’s lamentable record on CO2 and climate action is the subject of far too many posts on this blog. But now that COP27 has started, it’s clearly time for things like this again:


Even in Devon, how much Aggregate Industries actually cares about climate action is plain for all to see. 

In 2015, Aggregate Industries recognised the harm of processing Straitgate material 23 miles away at Hillhead, warning "processing at Hillhead may be feasible, but would generate a massively greater quantity of CO2 emissions", and would be "unsustainable": 
8.38 Hillhead Quarry does, however, present an option for processing of the Straitgate deposit, but the consequential impact of additional CO2 emissions from greater haulage distances are considered to be unsustainable. 
Fast forward to 2022 – with the climate emergency even more urgent – and processing at Hillhead is exactly what Aggregate Industries wants to do, appealing Devon County Council’s decision to refuse its proposed quarry at Straitgate Farm with haulage of as-dug material totalling some 2.5 million miles.  

At the appeal, the barrister representing Aggregate Industries had the gall to claim "transport has been "minimised", complying with M22 [of the Devon Minerals Plan]... Having regard to the available options, the HVO offer, and the greenhouse gas report."

Of course, no other UK aggregates operator hauls as-dug sand and gravel 23 miles for processing. 
 

And it’s surprising that Aggregate Industries even references the infamous greenhouse gas report, subject of much discussion at the appeal. Devon County Council's barrister called it "a deeply flawed piece of work" – completely ignoring the 8 million tonnes of sand and gravel allocated right next door to the Hillhead processing plant. 

That’s how much Aggregate Industries really cares about climate change.
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More evidence: unsaturated zone velocity – metres per YEAR not metres per day

At the Straitgate Inquiry, much of the hydrogeology discussion centred around the speed at which groundwater travels through the unsaturated zone. 

The barrister for Devon County Council said in his closing submission: 
52. In the face of the literature that has measured speed down through the Sherwood Sandstone (of which the BSPB is part) of 1.06m/year, the Appellant advances a remarkable claim: that speed is in fact in a range up to 16.9m/day, by reference to some open borehole and trial pit testing and relying on relatively rapid responses to rainfall shown by borehole loggers measuring (through pressure) the level of the water table. 
What a coincidence then that during the Inquiry this paper should be published:
 

It concerns the international problem of nitrate pollution in groundwater: 
When understanding the impacts of this nitrate legacy on water quality, the nitrate transport velocity (vN) in the unsaturated zone (USZ) is of great significance. Although some local USZ vN data measured or simulated are available, there has been no such a dataset at the global scale. Here, we present a Global-scale unsaturated zone Nitrate transport Velocity dataset (GNV) generated from a Nitrate Time Bomb (NTB) model using global permeability and porosity and global average annual groundwater recharge data.
As anyone casting their eye over the paper will see – velocity in the unsaturated zone is measured in metres per year NOT metres per day.
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Monday, 31 October 2022

Grand Designs: ‘Four unsuccessful attempts at drilling a borehole’

At the Straitgate Farm Planning Inquiry, no evidence was presented by Aggregate Industries to demonstrate how alternative water supplies could be provided to the 120 people reliant on the Straitgate aquifer in the event of derogation.

It’s a serious omission. Anyone watching Grand Designs last week will understand why. 

The issue of alternative water supplies and how they could be provided is one we have posted about in the past – here and here are just two examples. 

At the Public Inquiry, the barrister representing Devon County Council said in his closing submission: 
125. Minerals Plan Table C.4 is clear regarding the need to include provision for alternative supply in the event of derogation, and the Appellant has been reminded of the need throughout (see e.g. 2.8 of [CD4.07A]). But the Appellant has adopted an approach that amounts to a crossing of fingers, with an approach in the s.106 that is no more than a plan to make a plan, consistent with its unjustifiable downplaying of the significance to be afforded the PWSs and the potential impacts upon them.  
The barrister representing Straitgate Action Group said in his closing submission: 
33. There is no evidence that any of the 120 people reliant on private water supplies could easily be provided with mains water as an alternative. 
38. There is no evidence that an alternative borehole would be available.
46. SAG has consistently been asking for detail to satisfy it that practical mitigation that works in the real world has been worked up and secured. The Appellant has done preciously little to demonstrate that the mitigation would ensure no more than a negligible impact in practice. A take it or leave it offer letter setting out a series of measures, none of which has actually been shown to be practicable or achievable within a realistic timescale, is simply not good enough.
Even now, all that Aggregate Industries’ proposed Unilateral Undertaking legal agreement says is:
3. If the investigation confirms that it is AIUKs operations at Straitgate that are the cause of the loss or reduction in supply or contamination of a PWS, then AIUK will provide at their own expense one, or a combination of, the following solutions: 
Appropriate water treatment;
Deepen existing borehole;
Provide additional pumping equipment;
Pay compensation for increased pumping costs;
Install appropriate treatment systems to deal with contamination;
Provide a new borehole;
Provide additional storage facilities;
Install a mains supply connection;
Any other solution proposed by the expert (please see below)
How much of this is possible? No-one knows. No feasibility study has ever been commissioned. 

What if private water users don’t agree with the solution? 
If you do not agree to the solution proposed by AIUK or the expert (as appropriate) you shall be under no obligation to accept AIUK's proposal to implement that solution. However, should you reject the proposal (which shall include but not be limited to refusing AIUK access to your property to implement the solution), AIUK shall be under no further obligation to propose and/or implement a solution to the issue.  
And what about any extra ongoing charges – for treatment or from South West Water, for example? Surely, it’s the least that can be offered if your spring water has been compromised? 
For the avoidance of doubt, AIUK shall only be responsible for implementing the proposed solution and not for any subsequent charges, fees or any other costs associated with the solution once implemented.  
Which says a lot doesn’t it? If there were little risk to water supplies, this would be an easy promise to make. Obviously the bean counters at Aggregate Industries are not convinced there is little risk. 

Why at this stage do we need any more than "a plan to make a plan"? Anyone watching Grand Designs last week will appreciate that securing a source of water cannot be taken for granted. 

The programme followed a DIY off-grid cowshed conversion in Somerset. On the subject of water: 
Following four unsuccessful attempts at drilling a borehole to bring in a water supply, the couple switched to a water harvesting system.
Apparently, these intrepid self-builders have now come to value water as a precious resource, reportedly getting excited when it rains and having "a very relaxed attitude to flushing". 

Of course, as things currently stand, there are no problems with private water supplies around Straitgate. People don’t need to get excited when it rains, or have a relaxed attitude to flushing.



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AI’s appeal against Chard Junction Quarry refusal in Dorset AONB dismissed

Aggregate Industries’ planning application to extend its Chard Junction Quarry at Westford Park Farm in the Dorset AONB, WD/D/19/000451, was refused last year by Dorset Council.


The Planning Inspectorate has today dismissed the appeal:
 
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Thursday, 27 October 2022

Holcim emitted more than 7bn tonnes of CO2 between 1950 and 2021

... according to research by the Climate Accountability Institute – that’s 0.42% of all historical global industrial emissions. 

It’s a shameful legacy for one company to bequeath to humanity – especially since:
Leading companies and industry associations were aware of, or wilfully ignored, the threat of climate change from continued use of their products since the late 1950s.
Yesterday, the United Nations warned that current pledges to cut greenhouse gas emissions will lead to global heating of 2.5C – a level that would condemn the world to catastrophic climate breakdown. Today, Inger Andersen, executive director of the UN Environment Programme, said:
We had our chance to make incremental changes, but that time is over. Only a root-and-branch transformation of our economies and societies can save us from accelerating climate disaster... Every fraction of a degree matters: to vulnerable communities, to ecosystems, and to every one of us.
Cement giant Holcim – previously badged LafargeHolcim until controversies like the one below – is the parent company of Aggregate Industries.

It is ranked 47 out of the Top 100 emitters by The University of Massachusetts Amherst’s 2021 greenhouse polluters index. 

Of course, you'd never know. Holcim doesn’t broadcast its dirty secret. It is the same company pumping out statements like "Sustainability is at the core of what we do", and that concrete is "the ideal sustainable material for our future", and that "Our teams are going above and beyond to keep our people and communities safe, while firmly leading our decarbonization journey."

Maybe one day companies will be banned from greenwashing. There was a glimmer of hope last week from the Advertising Standards Authority, which banned a series of misleading adverts from HSBC promoting climate-friendly initiatives. The watchdog ruled that the bank had to ensure any future environmental claims were: 
adequately qualified and did not omit material information about its contribution to carbon dioxide and greenhouse gas emissions. 
Campaign groups welcomed the ASA’s ruling, saying it was a "significant moment in the fight to prevent banks from greenwashing their image." 

Clearly, it’s not just banks. Holcim proclaims it "takes climate action very seriously." But not seriously enough to stop its UK subsidiary from appealing the decision by Devon County Council to refuse permission to haul bog-standard aggregate 23 miles from quarry face to processing plant – a distance unheard of in the UK.

But, as we touched upon in the post Holcim’s cost to society in 2021? 156 million tons of CO2 emissions, the company’s carbon legacy and the impact it has left upon us is now being tested in the courts in "a first-of-its-kind lawsuit". 

According to Agung Wardana, an environmental law expert and a Humboldt Fellow at Max Planck Institute for International Law in Heidelberg, Germany, the lawsuit showcases an increase in public awareness on climate change and a desire for justice: 
This will be a landmark case in Indonesia. I think many others could follow suit in demanding accountability of major polluters. The homework to win the case is to find the causality between Holcim’s activities and its impact on Pari Island. That’s the challenge.

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Tuesday, 18 October 2022

Lafarge pleads guilty to US charges of supporting Islamic State

Accusations that Aggregate Industries’ parent company financed terrorism in Syria date back to 2016 – as we have previously posted.

Today, Reuters reports: 
NEW YORK, Oct 18 (Reuters) - French cement maker Lafarge pleaded guilty on Tuesday to U.S. charges of supporting the Islamic State by keeping a factory running in Syria after conflict broke out in 2011, according to a court hearing. 

The admission in Brooklyn federal court marked the first time a company has pleaded guilty in the United States to charges of providing material support to a terrorist organization. Lafarge, which became part of Swiss-listed Holcim in 2015, is also facing charges of complicity in crimes against humanity in Paris. 

Lafarge agreed to forfeit $687 million and pay a fine of $90 million in its guilty plea.

U.S. Attorney Breon Peace for the Eastern District of New York said: 
In the midst of a civil war, Lafarge made the unthinkable choice to put money into the hands of ISIS, one of the world’s most barbaric terrorist organizations, so that it could continue selling cement. Lafarge did this not merely in exchange for permission to operate its cement plant – which would have been bad enough – but also to leverage its relationship with ISIS for economic advantage, seeking ISIS’s assistance to hurt Lafarge’s competition in exchange for a cut of Lafarge’s sales. Today, Lafarge has admitted and taken responsibility for its staggering crime. Never before has a corporation been charged with providing material support and resources to foreign terrorist organizations. This unprecedented charge and resolution reflect the extraordinary crimes committed and demonstrates that corporations that take actions in contravention of our national security interests in violation of the law will be held to account.
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Sunday, 16 October 2022

The Public Inquiry has finished

The 8-day Public Inquiry into the appeal by Aggregate Industries against the refusal last year by Devon County Council for a sand and gravel quarry at Straitgate Farm with haulage of the as-dug material to Hillhead Quarry finished sitting on Friday. The Inquiry will be formally closed on 25 October* to allow for a 3-week consultation on the additional Regulation 22 information supplied by Aggregate Industries.
 
A big thank you to all those who have generously supported us, including Ottery St Mary Town Council and all those who donated via JustGiving. 

A big thank you too to our legal team, Tim Taylor of Khift Ltd and Richard Moules of Landmark Chambers, and to the rest of our team – Rick Brassington, Laura Horner, Alex Meletiou and Rupert Thistlethwayte – and to those who spoke at the Inquiry, including Cllrs Jess Bailey, Roger Giles and Amanda Townsend. 

A big thank you must also go to those at Devon County Council who facilitated the smooth running of the Inquiry, to the Minerals Team, and to the experts fielded by the Council – including barrister James Burton, hydrogeologists Paul Thomson and Nathan Littlewood, ecologist Chrissy Mason, arboriculturist Michael Steed, heritage expert Ignus Froneman and planning expert Robin Upton. 

The closing submissions by the three barristers can be found below. There is no need to repeat the issues raised, save for these few points: 

It was established that the groundwater system around Straitgate Farm is fragile and unique; that there is a risk to private water supplies, that a precautionary approach should be taken, and that alternative water supplies must be provided should there be any derogation. No evidence was presented to the Inquiry by AI to demonstrate how alternative water supplies could be provided to the 120 people reliant on the Straitgate aquifer. 

It was established that there is no precedent for working down to the maximum water table where there are sensitive water receptors nearby, without maintaining a permanent freeboard or safety margin. 

It was established that no testing had taken place to reliably determine the infiltration rates and hydraulic conductivity across the site. The tests that were performed were judged by the company’s own expert to be "pretty crude". It was established that no mineralogy studies have been conducted on the material at Straitgate to understand what effect the minerals have on groundwater, particularly on the pH. 

It was established by AI’s hydrogeologist that some of the monitoring boreholes showed confined behaviour, making – according to SAG’s and DCC's hydrogeologists – the area proposed for extraction even more important to sensitive groundwater receptors. 

It was established that AI’s flood risk model is based on an unreliable infiltration rate. 

It was established that AI had underplayed the importance and number of trees that would be lost. 

It was established that surveys for European protected species were out of date, and that there had been habitat changes since the survey work was undertaken. 

It was established that there would be a need for a cattle crossing; it was not established how the situation would be resolved. 

It was established that there is nothing particularly special about the Straitgate sand and gravel deposit. It is not, as AI had claimed, "a recognised source of high specification aggregate." It is not, as AI had claimed, a source of scarce yellow sand. It does not, as AI had claimed, contain 60% gravel. 

It was established that the Preferred Area West of Penslade Cross, next door to the processing plant at Hillhead, is an area of the Budleigh Salterton Pebble Beds that has fewer constraints than Straitgate Farm, and has eight-times the resource. It was established that AI intends to seek pre-application advice regarding Penslade before the end of this year, with a view to submitting a planning application in 2023. 

The Planning Inspectors’ decision is expected in the next few months.
EDIT * Inquiry formally closed on 4.11.22
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Friday, 14 October 2022

Public Inquiry closing submissions

 

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Wednesday, 12 October 2022

SAG lodges S106 Inquiry Note

... can be found here, and response here.
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Site visit documents

Cover sheet 
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Tuesday, 11 October 2022

Venue change

... can be found here.
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Monday, 10 October 2022

Revised timetable

... can be found here.
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Sunday, 9 October 2022

Straitgate Inquiry reports from Cllr Roger Giles

... can be found on Cllr Jess Bailey’s blog.
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Hydrogeology Presentation

On the first day of the Inquiry, the expert hydrogeologist acting on behalf of Devon County Council gave a presentation, which, for those with water supplies or an interest in the subject, we include below.
 

Devon County Council’s Planning Rebuttal, and Statement in respect of Reason for Refusal 3, can be found here and here.
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Tuesday, 4 October 2022

Public Inquiry opening submissions

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Thursday, 29 September 2022

7 years on – less than 7 days before the Inquiry – AI is still supplying information

You might have thought Aggregate Industries would have its ducks in a row after all this time. 

But no. More than 7 years on from its first application, Aggregate Industries is still supplying information in an effort to prop up its planning application to quarry Straitgate Farm.

The additional information was requested by the Planning Inspectorate in August, as we posted. 

Today, just days before the Planning Inquiry starts, a raft of new documents has been accepted by the Planning Inspectorate, and 21 days of public consultation on this information will now begin. As usual, it contains the normal clangers we have come to expect from Aggregate Industries.

The information supplied is CD4.85 to CD4.91 in this document list. 

The Planning Inspectorate says: 
The Inspector will be mindful of the dates at which the Council and Rule 6 party has received the further information (relative to the Inquiry start date) and in opening the Inquiry will ask for the parties’ views on whether they require additional time for preparation of their evidence.  An appropriate allowance will be made for this.      

Although publicity of further information in accordance with Regulation 22 of the 2011 EIA Regulations is not a statutory requirement for appeals going by hearing or inquiry, the Appellant is going to be running a publicity/consultation exercise on the further information, which we anticipate will close 21 days after publication of a newspaper notice (EIA Reg 22(3) refers). Interested parties could therefore submit any additional comments on the further information as part of that consultation process.  
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Inquiry draft programmes, agendas, time estimates, etc.

Inspectors' Pre-Inquiry Note 

MPA comments regarding draft s.106 and draft supplemental deed 
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Tuesday, 20 September 2022

Proofs of Evidence

Proofs of Evidence have today been lodged with the Planning Inspectorate, and can be found here.

Devon County Council

Aggregate Industries  

Straitgate Action Group  
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Monday, 12 September 2022

Site notice

... can be found here.
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Friday, 26 August 2022

Cadhay

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Thursday, 25 August 2022

Straitgate & Hillhead appeal update

On 23 August, the Planning Inspectorate held an online Case Management Conference, at which Straitgate Action Group was represented. Notes were issued by Aggregate Industries and Devon County Council beforehand. Today, a summary note has been issued by the Planning Inspectorate.

Aggregate Industries has, in addition, been asked to supply further information.

Devon County Council has added to its statement of case after further site visits by its hydrogeologists. Notes on this subject were issued by Devon County Council and Aggregate Industries.
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Tuesday, 23 August 2022

AI’s appeal against Chard Junction refusal in Dorset AONB starts today

Aggregate Industries’ planning application to extend its Chard Junction Quarry at Westford Park Farm in the Dorset AONB, application WD/D/19/000451, was also refused last year. 

Previous posts on the company’s attempt to despoil the Dorset AONB for the sake of a relatively small amount of decorative stone can be found here. 

As with the Straitgate Farm refusal, Aggregate Industries has decided to snub local democracy and appeal the decision. Proceedings start today:
A Planning Public Inquiry is scheduled to take place from 10am Tuesday 23 August 2022 at The Guildhall, Fore Street, Chard, Somerset TA20 1PP. Currently scheduled for 6 days. Please note the inquiry sitting days will be 23, 24, 25, 26 August and Wednesday 31 August and Thursday 01 September 2022. 
Planning Inspectorate Reference: APP/D1265/W/22/3295006.
Documents relating to the appeal can be found here and here. 

Of course, we all wish Dorset Council and the Rule 6 Parties the best of luck. 
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Construction industry greenwash fails to persuade majority – AI finds

Well, fancy that. 

Aggregate Industries – the company wanting to haul as-dug aggregate 23 miles between quarry face and processing plant, more than any other UK quarry operation and some 2.5 million HGV miles in all – the company that has given up reporting CO2 emissions after failing to make any progress over the last 20 years – wonders why 91% of people believe the construction sector is not delivering long-term sustainable solutions, and 51% of consumers do not trust the industry when it says it is committed to carbon reduction.

Surely the company need only take one look at itself to find the answer. 

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Monday, 1 August 2022

It’s all about the unsaturated zone – the independent expert hydrogeologists will say

What happens to rain when it falls on the ground? The simple answer is that it either evaporates back into the atmosphere, flows to surface water bodies such as streams, or infiltrates into the soil.


Some of the water infiltrating into the soil will be taken up by vegetation. The remaining water will percolate down through the unsaturated or vadose zone to the water table and the saturated zone, where it becomes recharge to the groundwater system. In the Straitgate area, less than half of the rain falling onto the ground will add to the groundwater system as hydrologically effective rainfall.


The rain falling onto the ground is slightly acidic. After evapotranspiration – the loss of water from the soil both by evaporation from the soil surface and by transpiration from the leaves of the plants growing on it – the substances dissolved in that water remain behind, and the water in the soil becomes more acidic. Carbon dioxide in the soil – from microbial decay of organic matter and respiration of plant roots – will dissolve into the water making it even more acidic. 

The table below – from Baseline groundwater chemistry: the Sherwood Sandstone of Devon and Somerset – shows the chemical composition of rainfall at North Wyke, 45 km west of Ottery St Mary.

The rain falling on Straitgate Farm will have much the same composition, which means that the groundwater – so important for many people's drinking water supplies – starts life with a pH of 4, or less.

Water with a pH of 4 is ten times more acidic than water with a pH of 5 and 100 times more acidic than a pH of 6. The Water Supply (Water Quality) Regulations 2016 state that tap water should have a pH between 6.5 and 9.5. A pH of 7 is neutral. 

At Straitgate, the weakly acidic solution travels slowly through the unsaturated zone over a period of years and, after reacting with carbonates in the rocks, loses most of the acidity and becomes drinkable.

Straitgate has no doubt provided a valuable source of drinking water for local inhabitants for hundreds, if not thousands of years.

Why is the unsaturated zone important? The rock/water interactions to control acidity are dependant on the time the water spends in contact with the underlying geology. The flow rate in the unsaturated zone – where the soil pores are drier and their ability to conduct water drastically decreases – can be many times slower than in the saturated zone below the water table, as this video explains. 


It is the unsaturated zone at Straitgate that Aggregate Industries wants to remove.

As you might expect, the company claims this would make no difference. Its Statement of Case says:
6.25 The appellant has considered each private water supply and it has been concluded that there will be no significant impact on these current private water supplies 
6.16 The hydrological impact assessment has resulted in the findings that the dry working option will not affect the groundwater and surface water quantities feeding into the four streams flowing off the site, including the two flowing into Cadhay Wood and Cadhay Bog. The fish ponds at Cadhay House will similarly not be affected.
However, Aggregate Industries' conceptual groundwater model is based on a BIG mistake. The company's consultants have argued that groundwater moves through the unsaturated zone in a matter of days. The science – here and here for example – says it takes years, that for Sherwood Sandstone – the geology at Straitgate Farm – the flow rate of water percolating through the unsaturated layer is measured in metres per year (m/a), not metres per day.


The difference between the current situation and the one that will pertain once 5 m of the unsaturated zone has been removed will be a loss of some 32% of the flow time taken for water to reach the Cadhay Spring from the ground surface at Straitgate Farm. This is a very large loss and will result in a significant reduction in the pH of the local spring waters. In my opinion, the acidity level in the spring waters in the area could fall to pH 5 or even less, a value that is very much lower than that today and, contrary to the EA’s understanding is well below the lowest level set in the Drinking Water Standards.
The Public Inquiry in October will undoubtedly tackle the effect on drinking water supplies of taking away virtually all of the unsaturated zone at Straitgate. To this end, Devon County Council and Straitgate Action Group have instructed independent expert hydrogeologists to act as witnesses. The Statement of Case from Devon County Council – the MPA – says:
6.12 ... the MPA has instructed an independent expert hydrogeologist to consider the evidence and materials produced on all sides to date, by Wood for the Appellant, by Professor Brassington for SAG, and by the EA. Having done so, their clear view is that Professor Brassington’s position that the Straitgate Proposals will result in a lowering of the pH of water reaching Cadhay is to be preferred (and has not been countered). The best available information is Professor Brassington’s analytical model. This predicts a halving of the average travel time of the water after it lands as rainwater. The water starts, due to evaporation and plant take up, as acidic. At present, its journey through the unsaturated zone sees it mineralise and the acidity “buffered” (its pH increases). Even then, at the moment (in baseline conditions), when water reaches Cadhay it is mildly acidic. The removal of the unsaturated zone by reason of the Straitgate Proposals would reduce the opportunity for the water to mineralise and so its pH would not be raised even to the extent it is presently.  
6.13 The result would be more acidic water at the fishponds than at present, and the likelihood is therefore that the ponds would be harmed by reason of a change in their ecology. The ponds themselves are part of a designated heritage asset (Grade II), as well as integral to the setting of Cadhay itself (Grade I). There may even be impacts to ecology outside the ponds themselves
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Tuesday, 26 July 2022

DCC’s statement of case

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SAG’s statement of case

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Friday, 22 July 2022

Landbank above 7 years at time of Straitgate decision – revision shows

This week, Devon County Council issued a revision of the county's sand and gravel landbank as it stood at the end of 2020. 

This was the landbank figure applicable last December when Aggregate Industries’ planning application to quarry Straitgate Farm was determined. The figure should have been 7.6 years – not the 5.7 years put forward by the Council. 

We pointed to the spurious fall in 2020's sand and gravel reserves – a loss of 0.9 million tonnes in excess of sales – at the time. The 10th Devon LAA claimed: 
There has been a significant reduction in reserves during 2020. This can be attributed to a reassessment of reserves by operators. 
Devon County Council has now sent a correction – Appeal Note – Landbank - 20/07/2022 – to the Planning Inspectorate, which states: 
1.3 In the course of preparation of the [as yet unpublished] 11th Devon LAA, based on aggregates sales and reserves data for 2021, it has been identified in July 2022 that an inaccurate figure for reserves provided by a mineral operator [not the Appellant] for the 2020 aggregates survey has resulted in the calculation of an incorrect duration for the sand and gravel landbank.

3.7 Contrary to the statements made in the committee report as outlined in paragraph 1.1 above, Devon’s sand and gravel landbank was, using the revised landbank figure of 7.6 years, above the seven years minimum required by Policy M11 of the Devon Minerals Plan [CD8.02] and paragraph 213 of the National Planning Policy Framework [CD8.01]. 
Indeed, the notion that the landbank was less than the 7 years suggested by the NPPF featured heavily in the committee report that informed councillors determining the Straitgate application: 
6.1.10 The 10th LAA for Devon... shows that, at the end of 2020, the landbank for sand and gravel was 5.7 years and it has therefore fallen below the seven years minimum required by paragraph 213 of the NPPF and Policy M11 of the DMP. 

6.1.12 In this context, Part 2 of Policy M11 presumes in favour of permitting proposals for a new or extended sand and gravel site as the relevant landbank is below the minimum duration… 
Crucially, the apparent shortfall guided the "Planning Balance and Reasons for Recommendation": 
7.5 A number of objectors have pointed out that the reduced amount of aggregate to be derived from the site must now mean that the harm caused by the proposal would outweigh the benefit of working the site; however, the current aggregate landbank has also fallen below the required seven years supply and this would weigh significantly in favour of this proposal in the absence of any other site coming onstream in the near future. 
Clearly, with more than 7 years’ worth of permitted sand and gravel, the size of the landbank should NOT have "weigh[ed] significantly in favour of this proposal". 

Indeed, knowing the true figure, the officers might even have had to recommend refusal, given what "a fine balance" the whole decision was: 
7.22 Although this site is allocated in the current Devon Minerals Plan, the length of time it has taken to bring it to determination has reflected the complicated issues that needed to be addressed, and it is acknowledged that the benefits of delivering the Minerals Plan proposal and maintaining the required aggregates supply, set against the impacts of the proposed development, has been a fine balance 
Aggregate Industries' statement of case for the appeal also plays heavily on the fact that the landbank for sand and gravel was below 7 years. 

One might reasonably conclude that the company's case is now even flimsier.
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Holcim’s cost to society in 2021? 156 million tons of CO2 emissions

As the UK hit 40°C this week, a milestone in UK climate history, spare a thought for residents of an Indonesian island threatened by rising sea levels who have begun legal action against the cement producer Holcim – parent company of Aggregate Industries. 


You can see why. We have posted about Aggregate Industries’ parent, and its record on CO2 emissions. Last year we posted LafargeHolcim’s cost to society in 2020? 146 million tons of CO2 emissions – more than many countries. 

Since then the name has changed but the pollution goes on. In 2021, Holcim's cost to society has INCREASED to 156 million tons. 


So much for all the claims, for all the greenwash:


Holcim maintained its focus on CO2 emission reduction in 2021... we acknowledge we must accelerate our CO2 reductions in the coming years.
And what about Aggregate Industries, Holcim's UK subsidiary? 


Kirstin McCarthy, sustainability director at Aggregate Industries, says: 
We need to transform our business and we have already made progress.
This is the same sustainability director who spoke in support of the company’s wholly unsustainable 2.5 million mile haulage plan for Devon. 

She says: 
Our priorities are to reduce our impact on the climate, protect and enhance nature and the environment, drive the transition to a circular economy and protect and support our people and communities.
More greenwash. 

But for how much longer can companies make meaningless, hollow claims? Lawyers and environmentalists have greenwashing companies in their sights.


As one article in the financial press remarked: 
The popular ploy of marketing everything from burgers to investment funds as 'green' doesn’t look sustainable any more.
Suggest they include concrete in that list.

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Concrete lobby takes swipe at sustainable timber

We all know that timber is a sustainable building material. It’s renewable and locks in carbon.

Not only does wood remove more CO2 from the atmosphere than it adds through manufacture, but by replacing carbon-intensive materials such as concrete or steel it doubles its contribution to lowering CO2. 
Could we return to wood as our primary building material? One architect says: 
It’s not only realistic, it’s imperative. It has to happen. In architecture you always go back to the sketch: the sketch is climate change.
The concrete industry plainly feels threatened.
 

Steve Elliott, chairman of BAR, the trade association for UK manufacturers and fabricators of concrete reinforcement products, claims: 
When you consider the destructive harvesting, industrial manufacturing process, additional chemicals and monoculture plantations it may be that too much credit has been given to timber being a green material. Indeed, it may better to keep the ‘wood’ alive rather than cut it down and build with it.
David Hopkins, chief executive of Timber Development UK refuted such "strawman arguments": 
This report from BAR really brings nothing new to the table other than a desperate attempt to smear a sustainable construction material by those sectors which have a less than positive tale to tell about their environmental impact 

There are already fully verified environmental product declarations behind all timber construction products which consider the whole supply chain. This means the impacts of timber products are measured, assessed, and verified by independent experts from forest to factory to operational building – right through to the product’s end of life. 

The truth is that timber is a renewable material which comes from sustainably managed resources – growing throughout Europe – which absorbs and stores carbon and requires very low energy inputs to process into high-performance low-carbon construction products. 

Concrete, on the other hand, requires materials such as sand – produced from dredging rivers and seabeds, destroying ecosystems and habitats in the process – and huge inputs of energy and water to manufacture. It’s a very high carbon material – and an issue which must be tackled to decarbonise construction. 

Rather than a constructive attempt to find solutions to the climate crisis, they would rather waste time dreaming up strawman arguments like this report because they know they cannot compete in a market with a greater focus on sustainability.
In other news:
 

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