Sand and gravel sales still falling

Sand and gravel production in Devon is likely to be down again this year, if national trends are followed. In 2011 production in Devon was just 0.44 million tonnes; ten years before that it was 1.15.

The Mineral Products Association's recent release Further decline in third quarter mineral product sales confirms steep decline in construction activity in 2012 claims "demand this year will be lower than the previous depths of the recession in 2009", with sand and gravel sales down 11% on the same quarter last year.

If DCC continues to call for additional sand and gravel provision in the face of continually falling demand, it will need to explain to the people of Ottery St Mary and Devon why a 20 year long downwards trend is likely to reverse, and why a perfectly good dairy farm should be sacrificed when the County still has reserves of over 9 million tonnes.

DCC refuses permission for incinerator at New England Quarry - Lee Mill, Devon

The risk to a site and its locality does not end when the minerals have been extracted - as the planning application from Viridor highlights. This was not a proposal for a boating lake or a woodland clearing with picnic area, but a £200 million energy-from-waste plant, with twin 90 metre chimneys, an Incinerator Bottom Ash plant, and landfill anticipated to run until 2043.

Fortunately, this time, the application was refused for its visual impact, the risk to Ancient Woodland in a County Wildlife Site, and access road considerations. Reasons that could equally apply to a quarry at Straitgate Farm.

Jobs - after years of decline that argument no longer has merit

Any application to quarry Straitgate would, no doubt, use the argument of "jobs for local people" - not new jobs, as Aggregate Industries have stated there would not be any, but the safeguarding of jobs.

However, the number of jobs safeguarded would in fact be small - earlier in the year there were just nine employees at Blackhill Quarry, and at-risk Straitgate Farm itself employs four. A modern sand and gravel quarry does not support anywhere near, say, the 230 jobs offered by a tungsten mine.

The jobs argument may have had merit at the Public Inquiry in 1968 to support English China Clay's application to quarry Straitgate, Blackhill, and Colaton Raleigh, but, in those days 41 people worked at Blackhill, and a further 148 at Rockbeare.

Nationally the sand and gravel business has been in decline ever since, and "consolidation through mergers and acquisitions has seen in excess of 5,000 quarrying companies in 1960 reduced to some 200 currently" of which Tarmac, Lafarge, Aggregate Industries, RMC and Hanson now account for over 80% of output. Even over the last 10 years there has been a dramatic fall in employee numbers in sand and gravel, with the UK Minerals Yearbook reporting over 8000 employees in 2001, but under 3000 in 2010. The HSE says the "industry has difficulty attracting and recruiting staff" and "anecdotal evidence suggests an ageing workforce".

The economic ramifications of a Straitgate Quarry on the wider area would be far greater than the immediate loss of the four farm jobs, and the extract from a DCC document below highlights the "Impacts of Mineral Development on the Economy". For Ottery St Mary and surrounding communities it is clear that the "Adverse Impacts" would far outweigh any of the "Opportunities". 

AI selling the 'family silver'

You have to feel some sympathy for Aggregate Industries' staff at the moment. Not only is their pay being delayed, but now Marston House, the company's 17th century Grade II* listed regional HQ near Frome, is being sold off - for £6m. Staff will be relocated to a rather subdued leasehold property nearby.

Is this another sign that AI is experiencing difficult times, or is Holcim, its Swiss parent, simply asset stripping? Or could it be to finance the fighting fund that AI now realises it will need to secure planning permission for Straitgate, and the cost of building itself a new processing plant away from the European nature conservation designations of Woodbury Common?

AI's trade body bemoans the planning system

Whilst to local people the odds seem heavily skewed in favour of the developer, the Mineral Products Association (MPA), on the other hand, laments the lack of progress in the planning system and the effort it takes to secure permission for sand and gravel quarries.

In its new Annual Mineral Planning Survey for 2010 the MPA, the trade association for aggregate companies, "is calling on the Government to overcome the inertia in the planning system". It claims:

Less than 50% of sand and gravel reserves have been replenished in the last 10 years [Maybe because the demand is only half what it was 10 years ago?]

Sand and gravel approvals took an average of 28 months in 2010 [Maybe because the environmental impact needs to be carefully assessed, before an operator tears into the countryside?] 

There has been no appreciable improvement in the time it takes to obtain planning permission since 1996 [Maybe because quarries are as damaging now as they were in 1996?] 

In 2010, only 9 planning applications for new extraction were submitted by members, compared with 40 in 1996 [Maybe something to do with demand again, as well as profit margins, and secondary and recycled aggregates?]

The MPA complains “It’s not surprising that the planning applications aren’t coming forward. Whilst the overall approval rate of applications is adequate, they take too long, they cost too much – between £100k and £800k - and lengthy pre-application discussions don’t help.” “With too few plans, low landbanks, diminishing replenishment rates, increasing costs, and planning inertia fuelling uncertainty we are storing up supply problems for the recovery. Lack of demand is masking underlying supply problems for the future”.

Representing its minerally-minded members, the MPA would be inclined to say all that, but, it is assuming that demand for sand and gravel will recover, and for the last 20 years there has been no such indication.

Birdstrikes - the threat is real

If DCC thinks birdstrikes are just a theoretical possibility, and that Exeter Airport is being overly protective of its flightpath and the surrounding airspace, it should think again.

The dangers of birdstrike are all too apparent from the video produced by Grass Engineering, a company in the business of making grassland around airports less attractive to birds.

But birdstrikes have an economic impact too. Even though 65% of birdstrikes cause little damage to the aircraft, "the cost of bird strikes to commercial aircraft worldwide has been estimated to be in excess of $1bn annually" - 12% for direct damage and the rest for delays and cancellations. For example, Easyjet: "The aircraft operating the inbound flight experienced a birdstrike during landing and needed to undergo a mandatory safety inspection by our engineers"; Flybe: "The Embraer 195 aircraft is now being inspected by engineers and the passengers were re-accommodated on a replacement aircraft"; Ryanair: "The majority of birdstrikes Ryanair encounter do not cause damage to their aircraft, however the commercial cost from delays is significant."

Airport "operators are required to take the necessary steps to ensure that the birdstrike risk is reduced to the lowest practicable level". If Aggregate Industries was to quarry Straitgate, it would have to do so without creating any bodies of water. 

Could AI dig a deep hole at Straitgate Farm and not expect it to fill up with water? As young children learn in the sand on the beach, it's not easy. Maybe if the hole was just restricted to the limited resource above the water table. Maybe if the hole was pumped out in perpetuity. Maybe if it was infilled with inert waste. Maybe if it stopped raining.

In 1967, when the Devon River Authority considered English China Clay's application to quarry Straitgate, it was agreed that the lake created from extraction needed to cover an area of 49 acres in order to mitigate any flooding effects on nearby communities. Local residents, farmers and no doubt the Environment Agency will question any claim by AI that it is now able to quarry Straitgate creating only an ephemeral body of water, particularly as, according to some locals, the water table is now at its highest in living memory.

ephemeral: transitory, short-lived, temporary, fleeting. Unlike a quarry, or the threat of one.

What they teach our children in schools today… and what they don't

The facts of life? Certainly. The facts of quarrying? Apparently, yes.

Using funding that was meant to tackle the problems created by quarrying and benefit communities affected by it, the Mineral Products Association (MPA), the trade body that "represents the whole of the British cement sector, 90 per cent of aggregates production and 95 per cent of both asphalt and ready-mixed concrete", has developed an interactive Virtual Quarry for use in schools, and teaching material for key stages 1-4 of the national curriculum for science, geography and citizenship. Understandably the material does not dwell on the disadvantages of quarrying:

You're in charge of restoring this quarry to a place for people and wildlife to enjoy. You can create a lake for people to sail on, plant some trees and reeds that will attract birds and build some hides to watch them from. Just click on the item you'd like and then on the place you want it to go. Water will only go into the bottom of the quarry and you can't grow trees in water! Keep an eye on the budget at the bottom of the screen as everything you choose costs money!

Not "Choose from landfill, industrial, or incinerator bottom ash reprocessing plant."

Who would have thought that a trade body, that counts amongst its successes:

MPA successfully lobbied the Government to freeze the rate of the aggregates levy for two years, saving the industry some £7 million in 2010/11,
MPA protected tens of millions of tonnes of potential site allocations in local development frameworks as a result of revised national guidelines for regional apportionment potentially worth hundreds of £ millions,

is influencing young minds in our schools, as well as the older ones in government?

Meanwhile, BBC Bitesize for GCSE geography takes a more balanced view, listing the pros:

Quarrying creates jobs in areas where there are limited opportunities.
There is a huge demand for the products of quarrying, such as building stone and cement. This is linked to the demand for new homes in the UK.
Quarrying provides income to local councils through taxation.
Good communications are needed for transporting the products of quarrying. As a result many remote rural areas benefit from improved access.
It is an important part of the UK economy. Over 30,000 people are employed in quarrying itself and related industries.

and the cons:

Wildlife habitats are destroyed.
Valuable agricultural land is taken away.
Quarrying creates pollution from noise and dust.
Heavy traffic causes pollution and congestion on narrow country roads. The vibrations from heavy traffic can cause damage to buildings.
Quarries create visual pollution and tourists may be deterred by the scars on the landscape.
Landfill sites and waste tips need to be monitored to check for a build up of gases, such as methane.
Limestone is a non-renewable resource - so it can be argued that quarrying is unsustainable.

If Straitgate was quarried, no new jobs would be created and the children of Ottery St Mary and West Hill would not enjoy any advantages. They would be the ones to suffer the disadvantages, and potentially the dangers too. Quarries are not only dangerous places for workers, the HSE identifying a "fatality rate over 20 times the all-industry average" and "potential for long-latency disease from exposure to respirable crystalline silica", but also for local youngsters, for whom a quarry presents a different set of dangers. The MPA has a "Stay Safe...Stay Out" campaign, and on Facebook it hopes that "by illustrating the tragic consequences of young people entering a quarry uninvited, this page hopes to raise public awareness of the potential hazards they expose themselves to. Every year young people are killed or seriously injured in quarries". It warns of a "sharp escalation" of break-ins and metal thefts, and that "trespassers often leave broken fences – and an open invitation for children in search of adventure". Devon & Somerset Fire & Rescue Service recently issued their own warning.

Quarrying - an important part of the UK economy maybe, but - at a price.

Is AI attempting to disguise itself as a wildlife business?

Is Aggregate Industries now more concerned with wildlife than it is with quarrying or the local people whose lives it disrupts?

Fir0002/Flagstaffotos

Those not so cynically minded might, on reading the press release Aggregate Industries form powerful new partnership to protect London's wildlife, be inclined to think that its main line of business was actually in wildlife, with a bit of readymix on the side. 

Does AI hope that by showing people pictures of butterflies and damselflies they might overlook just how environmentally unsustainable and destructive to natural habitats quarrying is?

No damselfly survives the onslaught of AI's earth-movers, and it's disingenuous of an aggregates company to feign a love of nature. AI showed no such concern in 2002 when it protested that "the decision to protect the birds, as well as what English Nature called 'a rich assemblage of dragonfly and damselfly' restricted its use of [Bramshill]."

The recent corporate video - "Biodiversity - a priority at Aggregate Industries" (with some clips of Blackhill Quarry) - seeks to show how seriously AI now takes biodiversity. In which case we can be assured that it will not quarry Straitgate Farm and put the bio-diverse wetland habitats in the Ancient Woodlands of Cadhay Bog and Cadhay Wood at risk. Or are AI's proclamations empty words, and "biodiversity protection and enhancement" not quite the "priority" it claims?

An opinion

A number of people may believe that because DCC has become quiet, gone back to have a rethink and delay its new Minerals Plan, that the threat at Straitgate Farm has receded, and the idea has been 'kicked into the long grass'. This is a dangerous view. We must not think for a moment that Aggregate Industries has given up on Straitgate - despite all the obstacles thrown up in the Consultation.

As far as AI is concerned, Straitgate is where they want to come next. Whether DCC has Straitgate as a Preferred Site or not. Whether DCC has its new Minerals Plan ready or not. AI still owns the site, the gravel is still there, Venn Ottery Quarry has a limited life, and DCC has identified - wrongly in our view - a shortfall in sand and gravel reserves before the end of its Plan in 2031. Having sat on Straitgate for nearly 50 years, AI will not give it up without a fight.

For them Straitgate is the cheapest option - dig a hole, haul the as-dug material across Woodbury Common, process it at the existing Blackhill Quarry, sell the hole afterwards for inert landfill. No new expensive plant to build, maintain a foothold in the area and keep Rockbeare supplied. Just carry on as it has at Venn Ottery. Current economics are not favourable for AI - as their workers have found out - and demand is low. They would find it difficult to justify a new plant, so processing at Blackhill may be their only viable option.

So, we must expect to be ready for a fight. The planning climate has swung in favour of the developer, and if we are to be in with a chance of defeating a multinational giant, with its barristers and consultants, we will need to be organised, funded, and ready with the arguments. Having long petitions and local Councillors and MPs onside is good and shows weight of public feeling, but will not ultimately influence an Inspector at a Planning Inquiry. It's all about the reasons why this is the wrong site from a planning point of view. Fortunately for the people of Ottery St Mary and West Hill there are substantial planning grounds on which to refuse an application to quarry Straitgate Farm - such as the impact on groundwater supplies, the impact on flooding, the impact on Ancient Woodland, the impact on airport safeguarding, the impact on the European protected Woodbury Common, the need not robustly demonstrated, the viability not demonstrated, the impact on Grade I and Grade II listed buildings, and so on.

Oh, and if AI applies for permission before a new Minerals Plan is in place it must overcome the hurdle of "For as long as adequate sand and gravel reserves (i.e. a minimum of seven years’ supply) continue to be present at the existing quarries, there are no grounds to allow their further extension or new quarries" specified by DCC's current Minerals Plan. Devon has over 16 years' supply.

Some may question what a campaign could achieve, but if run effectively, and Buckfastleigh and Chew Valley are good examples, it can make a difference. There's a multitude of substantive planning reasons why Straitgate Farm should not be quarried. It will be up to us to ensure the authorities recognise these.

Lose the battle against a sand and gravel quarry and our children could be fighting an "asbestos dump"

If there's anybody who thinks that a sand and gravel quarry at Straitgate Farm would be innocuous, consider the campaigners in the Chew Valley who have been fighting against the disposal of asbestos at nearby Stowey Quarry.

If Aggregate Industries was to quarry Straitgate it is all too likely that after extraction has finished a change in planning conditions would be granted, and the site sold to an inert waste contractor. With sand and gravel profit margins so low, selling the resultant void adds a significant amount to a quarry's overall profit, whilst restoration costs only reduce it.

Stowey Quarry is an example of how planning conditions change. The site was originally granted planning permission in 1954 for the extraction of limestone. In 1979 permission was granted for the tipping of demolition and construction waste and other inert materials. In 2011 permission was sought for the tipping of Stable Non-Reactive Hazardous Waste, including asbestos. 

An extensive local campaign was waged and the application was refused last week. The waste operator can appeal.

It's not just the sand and gravel, the noise and the dust, the disruption to watercourses and the drinking water supplies, the flood risk, the haulage past people's homes and across Woodbury Common. It's what could happen to that big hole in the ground that should also concern people.

Aside from polluting watercourses, the above photograph makes it clear why the site could not be used for household landfill, attracting gulls directly under the approach for aircraft landing at Exeter Airport

What 'Earth Scar' would be OSM's legacy?

After the ground has given up its mineral, the agriculture gone, Aggregate Industries' profit made, what then for Ottery St Mary and its surrounds?

Aggregate Industries is proud to supply Windsor Castle with 80-100 tonnes of crushed Blackhill gravel each year, but is it as proud of the 'Earth Scars' it leaves behind for local people?

If Aggregate Industries was ever allowed to quarry Straitgate Farm, the 'Earth Scar' would not be as deep as in the pictures above. If the company was restricted in the same way as at Thorn Tree Plantation at Blackhill, it would only be permitted to quarry down to one metre above the maximum water table.

But over time the 'Earth Scar' could grow to be almost as extensive, due to the extent of the deposit - with the sites S1-S10 at risk of befalling the same fate. Aggregate Industries already has most of the mineral rights, and could make OSM its home for generations.

And what imaginative ideas would Aggregate Industries or DCC have in mind for all those holes created so conveniently close to the Exeter populace? Housing, inert landfill, industrial units, composting? Any natural restoration scheme that increased the potential for bird habitats in Exeter Airport's flight path would of course not be permitted.

NIMBYism

Councillors should take care before dismissing local consultation respondents as nothing more than NIMBYs. The BBC article "Would YOU live next to a NIMBY?" considers that:

"To be called a NIMBY can be a devastating insult, undermining one's well argued case and labelling it as simply a statement of self-interest (...) But environmental lawyer Professor Peter Kunzlik says the instinct to be a NIMBY can be valuable (...) "One of the slogans that came after the Rio Summit was Think Globally, Act Locally. Governments claim to want everybody to do that, and so far as the environment is concerned, where do you experience it? It's where you live. So if you're going to take issues seriously, you do so locally, otherwise it becomes a bit hypothetical.""

A survey by The Saint Consulting Group (SCG) found that "nearly nine out of 10 people in Britain are NIMBYs". In fact "almost a quarter of all UK households have objected to a planning application of one kind or another in their local area over the last 12 months". In other words, for the very people who elect councillors into office, the act of defending their home and neighbourhood against threats from local government or Swiss multinational giants is natural. It is certainly no more selfish than the profit motives of the world's largest cement producer. 

And it's hardly surprising when you hear of plans passed such as the one in Plymouth last year - it's obviously not just DCC that doesn't listen to local concerns. Would the councillors who voted for the waste incinerator and its 95m chimney stack, just 60m from the closest home in a socially deprived part of the City, have voted differently if they had lived in one of the 450 homes within 250m of the site?

Whether one agrees or not with its conclusions, the think-tank Policy Exchange recognised in a recent paper that "...local people see many costs and few benefits from new developments". "As 'neighbourhood' is people’s number one priority for homes, many NIMBYs are not selfish or unreasonable but defending their property rights" and "the legitimate fears of NIMBYs must be acknowledged, rather than NIMBYs being insulted".

According to SCG "quarries remain one of the most disliked forms of development behind casinos, power plants and landfill sites". When the BGS warn "Quarrying can significantly deflate the perceived and actual value of local property prices by reducing the desirability and demand for housing near the quarry as a result of noise, traffic, safety, dust, and visual intrusion concerns observed or envisaged by potential purchasers" are councillors surprised that not everybody might be in favour? Would they be happy living next to all that? Losing value on their home? And then losing their water supply too?

SCG advice to mineral operators is to "engage with the local community and educate members of the public (and likely opponents) about how important the aggregates sector is, and the positive impact that a quarry can have on the community." But if it won't bring any new jobs, the 384 consultation respondents would be interested to hear from Aggregate Industries what positive impacts a quarry at Straitgate Farm would have for the population of Ottery and West Hill. And they don't just want talk about restoration, because those plans have a habit of changing or simply not happening at all.

Signs produced by
Ottery Quarry
Action Group

SCG adds "Operators need to establish close ties with their local communities early on, as it is much easier to present the industry’s message to local residents whose position has not already been influenced, than it is to change their preformed opinions." Yet at the recent consultation Aggregate Industries was nowhere to be seen, and was not even prepared to share the working or restoration plans drawn up for the site. "Preformed opinions"? Sorry - too late.

As it was DCC pitching northern and southern sites against each other in the consultation, respondents did not deserve to be brushed aside with the misconceived accusation of NIMBYism. It's only too apparent from the documentation that locals know more about their locality than either Aggregate Industries or DCC. Councillors should appreciate people taking the time to furnish the facts, rather than criticise.

Local people are pragmatic enough to accept the need for sand and gravel, but Devon has over nine million tonnes already reserved and is using less than half a million tonnes each year. "But don't we need to build for economic recovery"? Like Spain, Ireland et al?

Strike ballot at AI

If the company treats its workers like this, what hope would there be for our community?

GMB is in dispute with the Company following a history of total disregard of our members' right to be consulted about major changes. Aggregate Industries has a track record of imposing not consulting, telling not asking and, in general, treating its loyal and committed employees with no dignity or respect. 

Aggregate Industries, however, said the financial climate meant it had no choice but to alter the pay date...

One can understand GMB's position. Workers are being forced to subsidise AI and its £13.8bn parent, "by a few days each month", without the company first seeking agreement. The Employment Rights Act 1996 makes it "unlawful for an employer to make any deduction from the wages of a worker employed by him unless the worker has agreed in writing to the deduction being made or it is required by law". 

SSSI - a denial of AI's Human Rights?

If Aggregate Industries was denied permission to continue operating on Woodbury Common due to SSSI (Site of Special Scientific Interest) and other designations, would it again complain, as it did at the High Court in 2002 - R (on the application of Aggregate Industries UK Ltd) v English Nature, that it was a "breach of section 6(1) of the Human Rights Act"? 

In February 2000, shortly after AI was notified that new European nature conservation designations would restrict quarrying at Blackhill on Woodbury Common, the company purchased almost 700 acres of land in Hampshire, only to see it then designated a SSSI by English Nature in July 2001, to safeguard the habitat of rare birds - the Nightjar, Woodlark and Dartford Warbler.

AI sought a Judicial Review of English Nature's decision, claiming the land had been deprived of its development potential, but this was rejected on the grounds that the site is "rightly regarded as an area of European importance".

Woodbury Common, the largest continuous expanse of heathland in England, is also recognised to be of European importance - Special Area of Conservation, Special Protection Area (SAC, SPA) - with populations of Nightjar, Woodlark, Dartford Warbler, and other legally protected species.

Yet having first been served notice in 1999, AI is still there, now with permission to process sand and gravel until 2016. How did DCC let that happen? Firstly in 2002 AI persuaded DCC to allow it to quarry a site adjacent to the SAC/SPA at Thorn Tree Plantation. Then in 2008 AI persuaded DCC to allow it to process material at Blackhill from Marshbroadmoor, Rockbeare. Then in 2011 AI persuaded DCC to allow it to process material there from Venn Ottery.

And now AI wants to persuade DCC again, this time to allow it to continue beyond 2016 to process material there from Straitgate. Until when? 2026? Longer? Hauling millions of tonnes past peoples' homes and across the East Devon Pebblebed Heaths - SAC, SPA, SSSI, AONB?

Is Woodbury Common the right place for a sand and gravel "factory" processing material from further afield? Blackhill's processing plant was only ever intended to process material extracted from the site, and that finished in 2009. At some point AI will have to expense a move. In 2003 it was intending to move to Rockbeare. By 2008 plans had changed and the intention was to move to Houndaller at Uffculme. Those plans were then put on hold. Desperate times may call for desperate measures - but a round trip of 15 miles, transporting each load of as-dug sand and gravel from Straitgate for 10 years or more? 100 movements or more a day? The profitable supply radius reduced by half. What can AI be thinking?

So never mind AI's "Human Rights". What about the rights of those - be they birds or people - who make this area their home, not just a profit centre?

SA ‘audit’ raises inconsistencies

Now that it is clear that the Sustainability Appraisal (SA) was performed as an "audit" of the site appraisals rather than to inform them, as Dave Black explains in his letter of 10 August, an inconsistency arises that DCC will need to explain. Specifically, how did the Aggregate Industries owned Straitgate Farm (S7), with the joint second most references to "significant negative impacts" (where there is no likely mitigation) in the SA summary for the southern sites, manage to conveniently avoid any "showstoppers" in DCC's earlier site appraisal?

The Environment Agency (EA) also recognised the inconsistency, and wrote "It is apparent from the SA that some of the excluded sites may [be] preferable in environmental terms". DCC would argue that the site appraisal assessed a smaller area for S7 than the SA, but as the EA pointed out for one of the impacts "distance is irrelevant, as the wetland functioning of the [County Wildlife Site] is reliant on the watercourse supply". The SA considered S9 "too small to be viable" and did not assess it.

To many it will look like site ownership influenced DCC's judgement; the site appraisals would hardly have been different if Aggregate Industries had performed the exercise themselves.

If you have a private water supply the Environment Agency needs your help

The Environment Agency has recently sent a letter to households who are potentially reliant on water from the Straitgate area. In the first instance they wish to put together a list of all the wells, boreholes and springs in the area "...with the aim of being better able to protect the source of that water, now and in the future." For those who have received a letter it is important to reply, not only to confirm and enhance the information they already hold, but also so that the Environment Agency can gauge the importance of the Straitgate aquifer and make an informed response to any future quarrying proposal. If anybody has not received a letter but lives near Straitgate Farm and has a private water supply, please contact the Environment Agency on 01392 354057.

Is it even viable?

Is this AI's only financially viable plan?

Back in April, DCC was asked whether it could verify "That Aggregate Industries confirmed to the Council prior to the Consultation that, besides Blackhill, there are a number of other commercially viable alternative locations for the processing of material from the area at Straitgate being consulted upon." 

DCC replied that "Aggregate Industries have confirmed there are other suitable locations for the processing of material but we cannot state whether they are commercially viable. We would not expect to go into the detail of commercial viability at this stage of the process." 

This was surprising because the NPPF says “173. Pursuing sustainable development requires careful attention to viability and costs in plan-making and decision-taking. Plans should be deliverable.” DCC appraised 45 factors for each site, but commercial viability was not one of them. A site might perform best environmentally but if it does not make business sense for an operator it is not going to be deliverable.

For Straitgate to be included in the Minerals Plan, DCC would need to know that, if processing at Blackhill on the heavily protected Woodbury Common was not to be permitted beyond 2016, it would be commercially viable for Aggregate Industries to set up plant at Rockbeare or Straitgate for the relatively limited amount of sand and gravel available. Without that knowledge there would be no substance to the Council's Plan, merely wishful thinking.

Poor profit margins on sand and gravel mean an assessment of commercial viability is important. Not only for the Council to be assured of continuity of supply, but also so that local people may have a modicum of faith that the operator will afford restoration plans, or in the case of financial default another operator could be attracted to continue and restore the site.

RICS has just released "Financial viability in planning". Whilst this is more concerned with housing development, it still emphasises that "Financial viability has become an increasingly important material consideration in the planning system" and "Viability considerations should form a critical part of the evidence base behind planning policies".

To date it would seem that commercial "viability considerations" have been absent from DCC's thinking, and before going any further Aggregate Industries should be asked for assurances that if they had to finance another plant the numbers would stack up.

Why was DCC in such a hurry?

© Crown Copyright/MOD 2007

DCC recognised some time ago that airport safeguarding issues could restrict quarrying at Straitgate, and when the CAA has said that "It must be recognized that it is not possible for an aerodrome or aircraft operator to mitigate the hazard caused by water bodies and watercourses, or to prevent birds using areas of open water in the vicinity of the aerodrome" why was DCC so determined and in such a rush to select a site directly under Exeter Airport's flight path?

It's unclear who in DCC wrote Safeguarding Mineral Resources and Infrastructure in February 2011, but here it recognised that "To the north of the AONB, parts of the [Budleigh Salterton Pebble Beds] have been sterilised by existing development at West Hill and Uffculme. However, the remainder of the resource is relatively unconstrained, although local designations, groundwater considerations and airport safeguarding arrangements may provide localised constraints."

These "localised constraints" plainly didn't concern DCC when it selected Straitgate as a Preferred Site. DCC had made its mind up some time before its Development Management Control (DMC) meeting of 7 March 2012, saying "All but one of the sites in the southern area were found to have at least one ‘showstopper’ impact in the site appraisals". In all likelihood DCC had decided much earlier, since Aggregate Industries had been assured enough to expense consultants' reports and plans, made available to the Council on 27 February. But how could DCC be so sure that Straitgate was the right site when the Site Appraisal was incomplete - "Conflict with Aerodrome Safeguarding Areas" being left with "In process of checking implication with airport"?

After all this was not an insignificant detail when Straitgate and other southern sites are directly under the flight path. The CAA has made clear that "almost without exception, water developments increase the bird hazard in ways that cannot be adequately controlled. Often, they are a consequence of minerals extraction, in which case there will probably be more similar proposals that will progressively surround the aerodrome with water. Even where this is not the case, there are nearly always pre-existing water bodies with populations of waterfowl nearby. In practice, isolated ponds that will not generate waterfowl movements do not exist. Any additional water will inevitably increase a pre-existing hazard from waterfowl."

DCC sent a copy of Aggregate Industries' plans to Exeter Airport shortly after 27 February, but didn't wait for their response before voting at the DMC meeting to consult on Straitgate and rejecting the alternatives. The Airport's reply arrived 2 days later, and said that "To ensure aviation safety it is suggested that no ponds or body of water be allowed as part of this development." At this point DCC could have still postponed its consultation, considered the advice, and had a re-think. But then DCC hadn't waited for the conclusions of the Sustainability Appraisal either, which reported on the "sustainability issues relevant to each of the 21 potential quarry sites". This report was redundant in this respect by the time it was published in June, since 18 of the potential sites had already been rejected by DCC, landowners having been informed on 12 March with a very final "the appraisal work has concluded that the site within your ownership is unsuitable at the present time for mineral working due to one or more environmental constraints, and the County Council will not be considering it for inclusion in the Devon Minerals Plan."

How was DCC so certain that Straitgate, with all its water issues, could be worked dry or restored without water features? Continual pumping into watercourses would be required for the former. Importation of millions of tonnes of inert waste for the latter. DCC convinced attendees at its West Hill exhibition that landfill at Straitgate was not an option. In any case, there may not be the availability of sufficient inert waste with much now recycled, or it may not be economic with recent landfill tax changes, or even environmentally acceptable.

No - it seemed that only one thing mattered - Straitgate was owned by Aggregate Industries, and DCC assumed it was deliverable. People might have hoped that when it came to aircraft safety, the Council would have considered matters more carefully and with less haste.

Bird spotting at Blackhill Quarry

The earlier post on Birdstrike omitted a detail. The body of water pictured at Blackhill Quarry is actually called "Seagull Pond" by quarry staff, for obvious reason. The quarry is also known by local bird-spotters, particularly for breeds of gulls. The gulls in the earlier photograph have now moved - and can be found at another lagoon in the quarry, as shown.

We mention this in case Aggregate Industries or DCC are minded to say at some future point that bodies of water in quarries are cold, nutrient poor, unattractive to bird life, and would present no risk whatsoever to aircraft flying low over Straitgate on their landing approach to Exeter Airport.

Reply from DCC

Letter from Dave Black, Head of Planning and Transportation at DCC, in reply to the Letter to DCC, regarding DCC's Sustainability Appraisal (SA) first referred to in Negative impact on flight safety only "minor"?

The reply from DCC argues that since the site appraisals considered "...social, environmental and economic impacts, it was not considered necessary to undertake SA of the site options prior to identifying the preferred and excluded sites for consultation." Government advice is however that Strategic Environmental Assessment [SEA, a European Directive which forms part of the SA] is most effective when started as early as possible...". In DCC's case the SA report, with its conclusions on the relative environmental impacts of each site, was published some three months after the Consultation started, and did not inform the selection of the Preferred Sites, or the rejection of the alternatives, a point also made by Natural England. It is therefore unclear how DCC will be able to demonstrate that Article 2(b) of directive 2001/42/EC "the taking into account of the Environmental Report... in decision making" has been fulfilled.

DCC does not see a conflict of interest in the same person overseeing preparation of the Minerals Plan and the Sustainability Appraisal. Many local authorities however, Oxfordshire, Somerset and Wiltshire to name three, engage outside consultants to "undertake an independent Sustainability Appraisal" which helps avoid any accusation that the SA is not entirely impartial. Government advice says it is "helpful to involve people... who are not directly concerned in producing the plan or programme and can contribute expertise or a detached and independent view". It is not a "legal requirement" for the SA to be independent, but good practice when working to find the best outcome, not just the most deliverable.

DCC does however welcome any comments from the public on the SA report "... including any inaccuracies or disagreement with judgements made in the report", but otherwise has decided that the SA report "... does not warrant a wider consultation." The SA report on S7 (Straitgate) can be found in S7 and S7 appendix. Click for the Sustainability Appraisal Team contact details. Here is a list of our comments so far.

Why are mineral workers warned of the dangers of RCS but not local residents?

Respirable Crystalline Silica is invisibly fine dust generated when quarrying and processing sand and gravel. Aggregate Industries' staff at Blackhill Quarry are warned of its dangers, as are at-risk workers elsewhere.

Report on Carcinogens by the US Health Department warns "Residents near quarries and sand and gravel operations potentially are exposed to respirable crystalline silica." Another report concludes "In our study, there seems to be a risk also in groups exposed to lower levels [of respirable quartz]. There is no consensus how low an acceptable risk level ought to be."

The deposits of sand and gravel at Straitgate are made of quartzite - a crystalline form of silicon dioxide or silica. Respirable Crystalline Silica (RCS) is angular Particulate Matter less than 10μm in size (PM10) that can enter the lungs. The quarrying sector is a major producer of PM10. The Health Protection Agency advises "The distance travelled by dust emissions will depend on the particle size and on the wind speed and turbulence. Smaller dust particles will stay airborne for longer and disperse over a wider area. Strong and turbulent winds will also keep larger particles airborne for longer. Data reported from quarries indicated that the courser dust particles (>30μm) are mainly deposited within 100m of the source, intermediate particles (10-30μm) between 250 and 500m, while fine particles (<10μm) can travel up to 1 km (DoE, 1995a,b). Ultrafine particles (<2.5μm) would be expected to travel considerably further." 

RCS can be generated a number of ways (not just from processing). "Inhaling finely divided crystalline silica dust in very small quantities over time can lead to silicosis, bronchitis, or cancer, as the dust becomes lodged in the lungs and continuously irritates them, reducing lung capacities. (In the body crystalline silica particles do not dissolve over clinically relevant periods of time.) Children, asthmatics of any age, allergy sufferers, and the elderly (all of whom have reduced lung capacity) can be affected in much less time." In its most common form, chronic silicosis "Usually [results] from long-term exposure (10 years or more) to relatively low concentrations of silica dust and usually appearing 10–30 years after first exposure."

The American Lung Association writes "...public concern may be raised about potential health effects from brief exposure to airborne silica or residence in locations where prevailing winds carry silica particles from natural or industrial sites. There is little evidence to suggest that brief or casual exposure [would living near a quarry be "brief or casual"?] to low levels of crystalline silica dust produces clinically significant lung disease or other adverse health effects. Chronic simple silicosis has, however, been described after environmental exposures to silica in regions where soil silica content is high and dust storms are common."

The Health and Safety Executive (HSE) advises (guidance sheets QY0 and QY2) "All RCS is hazardous". "Tell workers: that very fine quarry dust can cause silicosis, which leads to disablement and early death". The HSE adds, with regard to construction sites, "In 2006, the workplace exposure limit for RCS was reduced to 100μg/m3 and there is pressure to lower it further to 50μg/m3 as epidemiological data suggest there is no known level of exposure at which silicosis does not occur." "Whilst we are able to estimate the exposure to RCS of an individual at work from past data, little is known about the inadvertent exposure of people who are close to but not involved in the work activity". HSE measurements did however "indicate the migration of silica across sites and potentially beyond the site boundaries". As far as recorded cases go, the HSE maintains "No cases of silicosis have been documented among members of the general public in Great Britain, indicating that environmental exposures to silica dust are not sufficiently high to cause this occupational disease". However "It should also be noted that excessive long term exposures to almost any dust, are likely to lead to respiratory (breathing) problems." HSE's American equivalent, the OSHA, warns "If it’s silica, it’s not just dust".

Aggregate Industries warns about RCS, but what warnings has DCC given? Well, no mention at all of RCS. Its Sustainability Appraisal did warn "Due to a changing climate there is the potential for the impact of noise and dust on sensitive receptors to become more intense. Hotter summers will provide conditions that will produce additional dust, and people will spend more time outdoors and leave the windows of dwellings and workplaces open for longer." "There is likely to be a negative impact upon the well-being and health of the residents at Straitgate Farm. This impact, combined with those likely for low to medium sensitive properties in the vicinity, would lead to a significant negative impact during the working of minerals". Its recommendation? "Policy relating to dust could encourage screening measures and dust control/mitigation". In its current Minerals Plan DCC "...will consider the practicality and the cost of methods of environmental control such as the spraying of materials with water at suitable stages in their handling and transport, the watering of areas of the site regularly used by vehicles and the use of dust extractors." Are the phrases "could encourage" and "consider the practicality and the cost" enough? RCS is carcinogenic. Cllr. John Hart, Leader of DCC, reiterated recently "you have to extract minerals from where they were deposited" - but to the detriment of human health? DCC's slogan is, after all, "improving life for all".

How much protection would residents expect from this carcinogenic dust source? Planning4Minerals (P4M) stresses that "Prevention of dust generation is critical [for example by working the mineral wet and damping internal haul roads] - once in the open air ...the operator will have little or no control over where [dust] settling occurs." P4M expects the "use of buffer zones to isolate dust sources from surrounding communities, often incorporated into local planning policy, with distances of 250-500m typically adopted, unless there are unusual or exceptional reasons to permit a variation." However, one study "monitored silica concentrations ...near a sand and gravel facility in Central California" and found "the impact from this source was still evident, even at the furthest downwind monitor - 745 meters away". The Technical Guidance to the NPPF says "A dust assessment study should be undertaken..." and "...additional measures to control PM10 might be necessary if, within a site, the actual source of emission (e.g. the haul roads, crushers, stockpiles etc.) is within 1,000m of any residential property or other sensitive use". Dust monitoring would form part of the planning conditions for any new quarry, but the "definition of standards for dust is a particularly complex issue...there are no agreed standards or guidelines for the nuisance impacts of mineral dusts in the UK." However The Air Quality Regulations 1997 do set a statutory objective for PM10 of 50μg/m3 or less, and the Environment Agency stipulates a maximum RCS level of 0.6μg/m3 around waste sites.

So, what are the benefits for a community newly saddled with this risk of airborne carcinogenic dust? DCC says "Mineral working at an individual site may take place over a number of decades and, while this timescale may seem a burden on local communities, it does offer the opportunity to develop strong working relationships between community and mineral operator [wow, thanks!] (as well as providing a source of local employment)." Blackhill Quarry currently employs nine. What about "the Aggregate Levy Sustainability Fund for projects in communities that are affected by aggregates extraction"? Scrapped in 2011.