Tuesday, 27 February 2024

Groundwater levels continue to rise at Straitgate

This week, the groundwater level at PZ2017/02 – a borehole that sits on the eastern boundary of the proposed extraction area – was 30cm higher than reported here last week.

It now sits just 0.90m below ground level – a new maximum. 

As previously posted, the sand and gravel that Aggregate Industries wants at Straitgate Farm starts on average 2.3m below ground level. 

The company’s permission only permits quarrying above the maximum water table. 
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AI looks for new quarry manager to take on Straitgate can-of-worms

Is there anybody left working at Aggregate Industries who has played a meaningful part in putting together the plans to quarry Straitgate Farm? 

Of course, the company took so long to secure its permission – the best part of a decade, with site investigations, two applications, one refusal and a planning appeal – it’s not surprising that most of the actors behind the company’s scheme have exited stage left. 

Aggregate Industries is now advertising for a new Quarry Manager for Hillhead Quarry. It is this person who would be responsible operationally for mineral working at Straitgate. 

And what a responsibility, knowing what a convoluted, half-baked scheme this whole thing has become. 

The advert says: 
With an annual extraction of 350,000 tonnes and large projects in the planning phase, this position will offer you excellent growth in your career. 
Let’s hope so for their sake – because what person would want to take on the Straitgate can-of-worms? 

It was already clear last year, from the Council’s monitoring report, that the previous quarry manager for Hillhead, and before that for Blackhill, had chosen to hang up his boots. Given his fervent support for the Straitgate dream, including at the DMC meeting that refused the application, you might have thought he’d be tempted to see his plans in action – to see the first HVO-filled HGVs pull off site, the first crossing of displaced cows across Ottery’s main road, the first use of livestock tracks across the working site, the first archaeological digs of Iron Age and Roman remains, the first daily groundwater interpolations, the first resulting revisions of the MWWT, the first ancient hedgerows grubbed up, the first veteran oaks felled, the first earth movers ripping up precious bmv farmland, the first birds on newly created water bodies – but perhaps he realised more than most just how difficult the whole thing would be to pull off. 

Anyway, the cogs at Aggregate Industries have slowly turned and the position is now being advertised, for those mineral-minded readers who fancy a challenge. 

Someone else will now be landed with the job of trying to make sense of it all at Straitgate, trying to get all the disparate parts to somehow hang together, trying to satisfy the profusion of constraints and conditions. 

It won’t be an easy task. Remember, Aggregate Industries said whatever it needed to say to reach each stage of the planning process. It’s not clear that anyone ever stopped to think whether the whole thing was actually feasible.
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Govt announces partial reversal of EA cuts

East Devon Watch reminds us that between 2013 and 2018, the Environment Agency shed the equivalent of more than 2,500 full time jobs – 20% of its workforce. 

No doubt spooked by the public’s response to the sewage scandal, the Government has now announced that 500 additional staff for inspections, enforcement and stronger regulation will be recruited over the over the next three years. 

Environment Agency Chair, Alan Lovell, said:   
Last year we set out measures to transform the way we regulate the water industry to uncover non-compliance and drive better performance. Today’s announcement builds on that. Campaign groups and the public want to see the Environment Agency better resourced to do what it does best, regulate for a better environment. 
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Wednesday, 21 February 2024

Another borehole showing ZERO depth of available resource

The sand and gravel that Aggregate Industries wants at Straitgate Farm starts on average 2.3m below ground level.

The company’s permission only permits quarrying above the maximum water table. 

Clearly, therefore, in areas where the maximum groundwater level is closer than 2.3m below the ground surface, there is likely to be no sand and gravel available for the company to recover. 

In practice, to make it at all worthwhile – bearing in mind the costs, ecologically or otherwise, involved in stripping, storing, restoring more than 2.3m of 'best and most versatile' topsoil, subsoils and overburden – the maximum groundwater would need to be no nearer than 3.3m below ground level to be able to extract even 1 metre’s worth of sand and gravel. 


Obviously, there is no resource available to the company for an indeterminate area around this borehole on the eastern boundary of the extraction area. It's now the same for the area around another borehole. 

Last week, the groundwater level at borehole PZ2017/02 was just 1.19m below ground level. This is again on the eastern boundary - as shown below:
   

This groundwater level is higher, by our estimation, than the borehole’s previously recorded maximum on 18/02/2020. It is notable that levels in this location have only been monitored between 2017 and 2022, and not, like a number of the other locations, during the wet winter of 2013-2014. 

It’s not altogether surprising that the previous maximum has been exceeded, given the recent rainfall:


This all ties in with what we said in 2021, when we posted Depth of available resource at Straitgate is in places ZERO. 

Borehole PZ2017/02 is where Aggregate Industries plans to locate infiltration trenches to stop downslope flooding. Clearly, with water levels this high, those trenches can't work as intended. Again, as we posted in 2021, Infiltration areas to stop flooding couldn't be 3m deep – without breaching MWWT and in 2018, AI’s infiltration plans can’t work either – with groundwater this close to the surface. 

Ordinarily, if Aggregate Industries were monitoring the site, another calculation of the extrapolated maximum winter water table, the MWWT, would now be triggered, the company’s permitted base of extraction would have to be moved upwards and the available tonnage moved downwards. 

For reasons we can all guess, the company is not currently monitoring groundwater levels across the site.
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Planning conditions mean AI must drill more water monitoring boreholes

In order to protect surrounding private water supplies, Condition 30 of Aggregate Industries’ permission to quarry Straitgate Farm stipulates: 
Piezometer coverage across the site shall be, at any time, no less than the proposed one piezometer at each corner of each working sub-phase. Piezometers which are lost through quarry working shall be replaced within seven days. Continuous monitoring of all site piezometers (and interpolation between them) shall be used to ensure, during working, that the base level to which the quarry is worked is no closer to the measured groundwater level than 1 metre. 
Our emphasis.


Even as things currently stand, there is no piezometer on the SE corner of Phase 1. 

Furthermore, it is patently clear – and has been for years – that there are large areas on the eastern boundary that cannot be quarried without breaching the MWWT, given that groundwater has now been recorded just 1.19m, 0m, 1.26m and 1.59m below the surface at PZ2017/02, PZ2017/03, SG1990/021 and SG1990/012 respectively. 



The eastern boundary of Phase 1 and Phase 2 will therefore need to be redrawn.

Piezometer PZ2017/03, at the NE corner of Phase 1 and SE corner of Phase 2, is obviously unable to provide any meaningful information on how far to the west of this point the maximum groundwater levels would allow sufficient depth for mineral extraction, given water levels here have reached ground level. 

Clearly, therefore, there need to be further boreholes drilled at the redrawn eastern boundary of the extraction area – to fulfil Condition 30, ie. so that there are piezometers at "each corner of each working sub-phase". 

At least 12 months of groundwater monitoring in these new boreholes would then be required to provide any meaningful baseline. 

Without new piezometers in these locations there can be no way "to ensure, during working, that the base level to which the quarry is worked is no closer to the measured groundwater level than 1 metre."
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What exactly is a water body?

Although the creation of temporary water bodies – for surface water management and restoration – is shown on Aggregate Industries’ plans to quarry Straitgate Farm, Planning Inspectors conditioned that the site can only be quarried if: 
25. No water body shall be created within the site other than the approved weigh bridge lagoon. 
The reason for this was set out in the condition in its draft form (20):
To prevent the site becoming attractive to flocks of birds that may lead to an aviation hazard in the interests of public safety and in accordance with Policy M20 (Sustainable Design) of the Devon Minerals Plan.
Straitgate Farm sits directly below the landing approach for Exeter Airport.
 

Condition 25 is unequivocal. 

It is not weakened by an unless otherwise agreed tailpiece. The Inspectors strengthened the draft condition by removing "without the prior written approval of the Council...".

It is not limited by size. The Inspectors did not specify any minimum. 

It is not limited by duration. The Inspectors removed the qualifier permanent from the draft condition after hearing how temporary water bodies can attract seasonal birds. 

What exactly is a water body? Lawinsider says: 
Waterbody means any accumulation of water, surface or underground, natural or artificial, including rivers, streams, creeks, ditches, swales, lakes, ponds, marshes, wetlands, and ground water. 
Wikipedia says:
The term most often refers to oceans, seas, and lakes, but it includes smaller pools of water such as ponds, wetlands, or more rarely, puddles.
Puddles? Apparently so. In 47 Types Of Bodies Of Water: Pictures And More, Puddle sits at No. 31. 

In fact, in Puddle Britain: 11 amazing facts about tiny bodies of water, Prof Jeremy Biggs, the CEO of the Freshwater Habitats Trust, author of the book Ponds, Pools and Puddles, explains when a puddle becomes a pond, or, for that matter, a lake:
In the UK, we call everything up to 2 hectares [about 5 acres] a pond, but a lake that’s 2.1 hectares is really no different from a pond that’s 1.9 hectares. Down the bottom end, we call things down to 1 sq metre a pond, so then it’s below that we have puddles.


What hope does Aggregate Industries have of controlling puddles – if it can’t even control this? 
Indeed, what hope does Aggregate Industries have of not creating any new bodies of water, when Google Earth images confirm they were introduced at all of the company's other BSPB quarries? 


But perhaps Aggregate Industries has a cunning plan. 

Why does all this matter? Aggregate Industries left water bodies at nearby Blackhill Quarry – and these were some of the visitors that arrived.

It was Canada geese that brought down US Airways Flight 1549.
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Tuesday, 13 February 2024

Another accident today on the B3174 Exeter Road by Straitgate Farm

Today – just days after two similar incidents – another car crashed into the ditch near where the new cattle crossing is required for Aggregate Industries' scheme to quarry Straitgate Farm, a scheme that will put another 200 HGV movements a day onto this road. 
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Monday, 12 February 2024

Water level at borehole PZ2017/03 rises to GROUND LEVEL

Following the post AI has been pulling the wool over everybody’s eyes – planning inspectors included, the water level in PZ2017/03 was last week found sitting at ground level. 
The water level has no doubt reached ground level in this location before – but is not something that has been disclosed by Aggregate Industries.


What are groundwater levels doing in other boreholes across the site? Have maximum levels been exceeded again, given all the recent rainfall? 

No one has any idea because Aggregate Industries is not monitoring them. 

This matters, because the maximum water table across the site – the MWWT, guesstimated using previously recorded levels from this borehole and others – will not only form the base of the permitted excavation, to protect the groundwater supplying nearby private water supplies, but will also determine how surface water is managed, to avoid flooding and maintain stream flows.

Last month, Aggregate Industries made clear that it only intended to monitor the boreholes across the excavation site once a month using manual dipping. 

Groundwater levels can rise quickly at Straitgate Farm. Borehole readings show that even from a low base they can reach maximum levels in just 4 weeks. Continuous data loggers, as Aggregate Industries and its consultants have used in the past, are therefore essential for capturing these movements. Clearly, the company doesn’t want to do any more than the barest minimum. It certainly doesn’t want to discover that the MWWT has been exceeded again.
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MPA: ‘Housing-led construction slump hits mineral product sales hard’

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Judge quashes Cornwall planning condition sign off

Aggregate Industries’ permission to quarry Straitgate Farm is subject to a plethora of conditions, a number of which will need to be discharged before any soils can be stripped. 

How should councils grapple with the discharge of planning conditions? 

A judgement, handed down last month by the High Court (Barbara Laing, R (on the application of) v The Cornwall Council [2024] EWHC 120 (Admin)), in relation to the replacement of a length of Cornish hedgerow, gives an insight into the interpretation and discharge of planning conditions. 

Judge Jarman KC summarised the legal principles involved, writing: 
There are no special rules for the interpretation of planning conditions. The test is what a reasonable reader would understand the words to mean in the context of the other conditions and of the consent as a whole. This is an objective exercise in which the court will have regard to the natural and ordinary meaning of the relevant words, the overall purpose of the consent, any other conditions which cast light on the purpose of the relevant words, and common sense: DB Symmetry Ltd v Swindon Borough Council [2022] UKSC 33 at [66]. 
In the particular case he was presiding over, linked to a permission for a nine-home development, the judge quashed Cornwall Council’s decision to discharge a planning condition linked to an ecological plan. That plan had stipulated that double the length of hedgerow to be lost must be constructed elsewhere on-site. The developer applied to discharge the condition, submitting that 23m of lost hedgerow would be replaced by 25m of new. A principal planning officer for the Council considered this acceptable, reporting: 
The condition can therefore be discharged as the [ecological plan] is deemed to be acceptable and in accordance with the general requirements set out in the originally submitted [ecological appraisal]. 
The claimant, who lives next door to the site, challenged the Council’s decision. The Judge ruled: 
The authority interpreted condition 6 too narrowly, and consequently did not grapple with the noncompliance of the ecological plan in two important respects, namely the length of new hedge and direct connectivity with retained hedge... The decision on the application must be quashed and resubmitted to the authority for redetermination.
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Tungsten West receives Draft Permit for Mineral Processing Facility

A "major step-forward" has been taken towards resuming operations at Hemerdon Mine near Plymouth: 
Tungsten West, the owner and operator of the Hemerdon tungsten and tin mine (the "Project" or "Hemerdon") in Southwest England, is pleased to announce that it has received a draft permit from the Environment Agency for the operation of the Mineral Processing Facility ("MPF") at Hemerdon. The draft permit is currently undergoing internal review to ensure all aspects are aligned with the operational requirements of the MPF. Following this review by the Company and the finalisation of the documentation, a public consultation will be held where the Environment Agency will identify that they are 'minded to' grant this permit. This is the final step before the Environment Agency can issue the permit.  Throughout the consultation period, Tungsten West will remain committed to engaging with the Environment Agency and relevant stakeholders. The receipt of the draft permit represents a significant step in securing further financing for the Project and is the gateway for commencement of the updated Feasibility Study, which the Company anticipates will then lead into the main financing round.   

Neil Gawthorpe, CEO of Tungsten West, commented: "I am delighted to confirm receipt of the draft permit for the MPF, which represents a major step-forward in our goal of bringing Hemerdon back into production by the end of 2025, providing an ethical and sustainable domestic supply of critical minerals. I would like to thank the team at the Environment Agency for working closely with the Company and its consultants throughout 2023 to deliver this draft, and we look forward to progressing this process timeously through to a permit." 
It was the Mineral Processing Facility at Hemerdon that was previously the source of complaints by local people last time the mine was operational, as we posted about here and here.
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‘New Holcim boss faces long road to decarbonisation’

Miljan Gutovic, the new CEO at Holcim, parent of Aggregate Industries, speaking at the World Economic Forum in Davos, claimed: 
We are working on decarbonising Holcim, the construction industry, making our cities more sustainable and we are also driving circular construction.
New CEO. Same old story. 
Some industry executives question Holcim’s commitment to decarbonising the “whole construction industry” when its M&A activity has not solved the notoriously “hard-to-abate” carbon footprint problem facing cement. 

Despite Gutovic’s efforts to refocus Holcim’s business, the negative impacts of the legacy business will be hard to avoid. In an ongoing legal case filed last year against Holcim in the Swiss canton of Zug, where it is headquartered, residents of the Indonesian island of Pulau Pari affected by rising flood waters demanded Holcim pay compensation for the costs of their water damage and flood protection measures. 

Holcim is responsible for 0.42 per cent of global fossil fuel and cement emissions in the atmosphere since the mid 18th century, according to a study by the Climate Accountability Institute research group.
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Friday, 2 February 2024

AI has been pulling the wool over everybody’s eyes – planning inspectors included

Nowhere in the mountain of documentation – either for the planning application to quarry Straitgate Farm, or the subsequent 2-week public inquiry – did Aggregate Industries make known that groundwater on the east of the proposed extraction area – an area designated a soakaway for flood mitigation – can at times sit just 16 cm or less? below the surface. 

Fancy omitting such a crucial piece of information. 

Aggregate Industries has not monitored groundwater at Straitgate Farm since March 2022. A curious lack of inquisitiveness, you might think, given how wet the last few months have been. 

But Aggregate Industries doesn’t want to know about any elevated water levels that might reduce the amount of recoverable material. 

However, curiosity can get the better of some people. 

At borehole PZ2017/03 – shown on this map, on this hydrograph, and below – groundwater was found this week to be sitting just 16 cm below the ground surface. 

16 cm.

We have been warning about this issue on multiple occasions – including here, here, here, here, etc – but even we didn't realise just how close the groundwater actually sits below the ground surface*. 

Aggregate Industries’ consultants, on the other hand – who, in addition to relying on an automatic data logger, have been manually dipping this borehole quarterly since 2017 – would have known. They would have seen with their own eyes how close the water sat below the ground surface, but chose not to share the information more widely – not with Devon County Council, not with the Environment Agency, not with the Planning Inspectors at the Public Inquiry. 

Having been alerted to the elevated groundwater levels in this location, Devon County Council raised the issue with the company back in 2018, when PZ2017/03 recorded its maximum height of water of 138.68 mAOD on 27/04/2018. In a now superseded document, Aggregate Industries wrote:
Results from routine quarterly monitoring in April 2018 identified groundwater levels in localised piezometers on the eastern extraction area boundary higher than those depicted by the existing MWWT contour plot. Consequently, Devon County Council has determined this to be a material matter in that it has requested that the effects of these results be assessed to determine the effects on the quantity of mineral resource. Its position is defined in the following extract from an email dated 1st August 2018 (S Penaluna, Devon CC) as a: “......need to know exactly which areas might be excluded for reasons of groundwater protection and these would need to be indicated on a plan.” 
But the Council was misled, fobbed off, or lied to, when the company claimed: 
1. The extraction area, as shown on the Wood E&IS plan, remains unchanged... 
4. The change [in mineral resource], moreover, results in no area being “excluded for reasons of groundwater protection” but merely a localised effect on the depth of working in a localised (eastern) part of the site. 
What’s the big deal? Condition 28 of the permission allows the design of the base of the quarry to be changed to reflect revised estimations of the maximum water table: 
Prior to the commencement of any soil stripping on any phase of the development, a review of the Maximum Winter Water Table (MWWT) grid (being the hydrogeologically modelled surface of the maximum winter water table based on the highest recorded winter groundwater levels) shall be submitted to the Mineral Planning Authority for its approval in writing.
In Aggregate Industries' latest resource assessment for the site: 
The MWWT will ultimately form the base of the workable deposit, and any variation will impact the potential resource. 
But what’s most concerning is that borehole PZ2017/03 is in an area designated for flood mitigation, an area where it is intended to dig a trench, with a 1m buffer above the maximum groundwater level, to hold back surface water runoff and allow it to soak away.
   

Surface water will not soak away as designed with groundwater sitting just 16 cm below the surface. 

Why is it important to get the management of surface water right? You only have to look at the ponding problems at Aggregate Industries' Houndaller site for the answer.

There can therefore be no confidence that the planned trenches to stop downslope flooding will act as intended, and every confidence a water body will be created. 

As we have already posted, quarrying at Straitgate can only be permitted if: 
25. No water body shall be created within the site other than the approved weigh bridge lagoon.   
Without drilling another borehole further into the site, and implementing another period of monitoring, no one has any idea where the maximum groundwater levels are in the area surrounding PZ2017/03 – Aggregate Industries’ MWWT is at best a guesstimate. 

What should be done? 

In 1967 they knew exactly what to do – they left this area alone. Aggregate Industries should be forced to do the same.

*The exact depth to water from the ground surface could not previously be calculated using piezometer groundwater level data in mAOD, because a precise surface elevation figure for the borehole had not been supplied by Aggregate Industries.
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Two accidents today on the B3174 Exeter Road by Straitgate Farm

Aggregate Industries’ permitted plans to quarry Straitgate Farm will put another 200 HGV movements a day on this road. The incidents occurred in the same location as the cattle crossing, required as part of the scheme.
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Aggregate Industries’ Straitgate update for January

Aggregate Industries provided the following update this week in relation to implementing its permission to quarry Straitgate Farm: 
We have now completed our initial visits to the owners of the private water supplies who are part of the monitoring scheme and confirm that it is our intention to start the 12 month of pre-commencement baseline monitoring in April this year. To confirm numbers we will be monitoring at 20 properties (note as previously this does not include Straitgate farm but we will be monitoring there). The reduction in number from that which I gave you previously is due to some properties not actually having a private water supply and also some that share the same supply. 

Regarding the boreholes on the Straitgate site itself there are 17 of those and please note that this number does not include PZ10 as that is included in the private water supply number given above.
You would think Aggregate Industries would know by now, but there are in fact 15 boreholes on the Straitgate site itself – PZ07, PZ08 and PZ10 are on third party land.

EDIT 8.2.24 

In answer to a subsequent request to confirm which springs and streams will also be included in the monitoring scheme, Aggregate Industries replied: 
I can confirm that this is something we are looking at as part of the monitoring scheme and I will be able to confirm locations in due course.
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Monday, 29 January 2024

Aggregate Industries’ parent Holcim announces break-up plan and new CEO

The Swiss cement giant Holcim plans to spin off its North American business and list it in the US, as it seeks to unlock value and speed up growth for the unit. 

The Zug-based group also announced that the head of its European business, Miljan Gutovic, would take over as group chief executive from May. Outgoing chief Jan Jenisch will remain chair and lead the planned break-up… 

Makers of building materials such as Holcim have fallen out of favour with more climate-conscious investors in recent years, because of the carbon footprint of products such as cement and concrete. Holcim has sought to shift its business towards greener construction in recent years, and emphasised its role in "decarbonising building". 

Holcim will remain listed in Switzerland after the spin-off, with a presence across Europe, Asia, the Middle East, Africa and Latin America.
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Double blow for construction industry

According to the Construction Products Association (CPA) Winter Forecasts, published today, construction output is forecast to fall by 2.1% this year... 

Six months ago the CPA was forecasting 0.7% growth for UK construction output in 2024. Three months ago, it changed this to a 0.3% contraction. That it is now forecasting a 2.1% contraction represents a significant further deterioration in sentiment.

 

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Thursday, 25 January 2024

AI’s ponding problems at Hillhead worsen – attracting ducks & gulls too











Aggregate Industries’ plans for Straitgate Farm positively encourage the creation of water bodies – for surface water management and restoration. However, for Airport Safeguarding reasons, the Planning Inspectors only granted permission to quarry Straitgate on the condition that: 
25. No water body shall be created within the site other than the approved weigh bridge lagoon.  
As we posted a year ago: 
This condition... is clear and unambiguous. It is not limited by the size or duration of any water body – large or small, permanent or temporary.  

In June last year, we posted – here and here – about the ponding problems Aggregate Industries has suffered at Houndaller quarry at Hillhead, near Uffculme, where the company is extracting the same type of sand and gravel available at Straitgate. 

What’s the scale of the problem? Devon County Council's monitoring report for Hillhead Quarry in 2022 provided this photo:
The latest monitoring report for the site issued this week reveals that the ponding problems remain ongoing and are slowing down restoration: 
4.16 ...The water is ponding in this Phase and the operator would like to direct this water to Houndaller Pond, north of the farmhouse, in order to complete restoration. Therefore, a non-material amendment was submitted in order to alter the phasing of working. The has resulted in the operator entering the western end of Phase 8 to allow water to move from Phase 6, into Phase 7 and 8 temporarily whilst restoration is under way. Originally, working in Phase 8 was to commence at the eastern end. Alterations to allow water to enter Houndaller Pond will need to be subject to a full application. 

4.17 Despite the ponding, work has begun on restoring Phase 6 at the eastern end to the final restoration levels. It is anticipated this will be completed in 2025, however, it is understood the ponding is slowing this down... 
The report didn't say if the ponding problem had worsened. However, photos taken this week, above and below, show that it has:
Furthermore, the water is attracting ducks and gulls – the sort of species that would be particularly hazardous at Straitgate, being just 200m below the landing approach for Exeter Airport.

Even without its plans that encourage water bodies at Straitgate, Aggregate Industries’ problems at Hillhead – and the ponding at its other sand and gravel sites in Devon for that matter – demonstrate the company hasn’t a ghost of a chance of complying with condition 25 at Straitgate.
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HVO – where on earth will all the used cooking oil come from?

Aggregate Industries’ magical solution to its unsustainable 2.5 million mile haulage scheme for Straitgate Farm – a result of processing the as-dug sand and gravel 23 miles away at Hillhead near Uffculme – is to rely on hydrotreated vegetable oil, HVO, despite, as of early 2024, HVO being around 40 pence per litre more expensive than normal diesel. 

Condition 22 of the planning permission to quarry the farm says: 
Prior to the export of any sand or gravel from the site, a scheme which ensures that all heavy goods vehicles entering and leaving the site, together with all plant and equipment located within the site, use hydrotreated vegetable oil fuel shall be submitted to and approved in writing by the Mineral Planning Authority. The scheme shall include details of how the use of hydrotreated vegetable oil fuel will be monitored to secure compliance with this condition. All heavy goods vehicles and plant shall be used in accordance with the approved scheme. 
In 2022, we posted HVO – AI’s answer to the Straitgate sustainability issue – gets bad press and questioned how the company's HVO scheme would work in practice: 
How this would be done is anybody’s guess, since the company does not own its own fleet of trucks and HVO is not available on garage forecourts – as Devon County Council pointed out. How this would be monitored and policed is another issue – as the Council also acknowledged. 
We also posted that HVO is blamed for indirectly "encouraging more deforestation in Southeast Asia" with some research claiming it’s "three times worse for the climate than regular diesel when indirect emissions from changes in the use of land are accounted for". How so? HVO is primarily made from used cooking oils, UCO, which is used in the production of animal feed. Increased demand for UCO will lead to increasing use of palm oil as a replacement, therefore increasing deforestation. Across Europe, imports account for more than half of the UCO that's made into fuel. According to this study, there's no way to prove these imports are sustainable: 
China supplies over a third (34%) of Europe’s UCO imports while almost a fifth (19%) comes from major palm oil producers Malaysia and Indonesia combined. Within a decade the volume Europe needs could double to 6 million tonnes as EU countries strive to meet targets for renewable fuels in transport, the study finds. This in turn could trigger palm oil being used to replace cooking oil in exporting countries while also incentivising fraud (mixing virgin oil).
HVO is fully compatible with petroleum diesel and can also be upgraded for use as ‘Sustainable Aviation Fuel’ (SAF). 
According to Ryanair’s Michael O’Leary, sustainable aviation fuels are a con.

They’re a wheeze. Unless governments get in behind the production and sourcing of sustainable aviation fuels – and they’re only going to come from, ultimately, the oil majors, the only ones who are going to make them – I don’t see where we will get the supply in the volumes we need. You want everybody running around collecting fucking cooking oil? There isn’t enough cooking oil in the world to power more than one day’s aviation. 
Whilst Ryanair has deals with oil majors for up to 9.5% of its fuel needs in SAF by 2030, O’Leary said: 
But we have no idea that they’ll be able to make those kinds of volumes. 
Whilst capacity for HVO is forecast to double by 2028, demand is set to outstrip supply. 

Aggregate Industries is new to the HVO scene. In June last year, the company made a big song and dance about a single HVO-fuelled cement tanker being a "UK biofuel first". For Straitgate, it is conditioned, as pointed out above, that all the trucks, and all the plant and equipment located within the site, will need to use HVO.
 

At our Bardon Hill Quarry we are replacing diesel with HVO on equipment such as generators, compressors and crushing and screening plant. All of our HVO is traceable to source under the International Sustainability & Carbon Certification Scheme, does not result in any deforestation and will save an estimated 3,301 tonnes of CO2e at Bardon Hill. The savings from this, together with our suspended conveyor system saves enough carbon annually equivalent to driving a car 26,000 miles. 
Which is all very commendable – albeit the 26k miles is insignificant compared with the company’s HGV haulage plan for Straitgate. But whilst it may be possible to claim that the HVO used by AI does not directly cause deforestation, proving it does not indirectly cause it, proving that the UCO used in making its HVO is not causing more palm oil to be grown elsewhere as a replacement, is another matter. 

The concern must be that if every corporate is now going to be greenwashing their pollution away with the delights of HVO, where on earth will all the used cooking oil come from? And how many millions more acres of rainforest will have to be cleared to replace it? 

Almuth Ernsting of NGO Biofuelwatch warns: 
We are deeply concerned that HVO is being used and promoted in ever more sectors, from aviation fuels to cars and now as a heating fuel, too. While a limited amount of HVO can be made from genuine waste products such as used cooking oil, such waste products are in very short supply and come nowhere near meeting current HVO demand... EU and UK biofuel sustainability and greenhouse gas standards still permit biofuels from palm oil and soy to count towards renewable energy targets, and they are based on a flawed greenhouse gas methodology which ignores the greatest source of emissions – indirect land use change.
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Another part of Aggregate Industries accused of breaching planning controls

In Devon, Aggregate Industries has a history of breaching planning conditions – as we have frequently posted about, most recently here. 

Last year, Aggregate Industries acquired Sivyer Logistics, "a leading handler of construction and demolition waste (CDW) materials to the London construction industry." Dragan Maksimovic, Aggregate Industries’ latest CEO, crowed: 
Sivyer Logistics is an impressive business that has multiple synergies with our own…
Residents local to Morden Wharf in Greenwich seem far from impressed with Sivyer, claiming the company has "a reputation for flouting planning conditions".

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MPA urges next Government to streamline planning

The country is in a mess, but the Mineral Products Association, the trade body representing Aggregate Industries et al., is calling on the next government to spare some time for minerals, and streamline the planning process to make it easier for operators to trash our green and pleasant land, lamenting: 
Planning is hugely onerous for quarry operators putting pressure on the availability of resources. For example, for every 100 tonnes of sand and gravel extracted for use in UK construction, permission is granted for just 62 tonnes of new reserves – an unsustainable replenishment rate. The availability and supply of domestic mineral resources must not be assumed. Streamlining the planning system for minerals will be essential in the next Parliament, especially if parties include ambitious housing targets and infrastructure commitments in their manifestos.
The problem with that old chestnut, the unsustainable replenishment rate argument, is that the situation has been the same for years, yet we don’t hear builders crying that they’ve run out of sand or gravel. 

According to BGS figures, during the 10 year period from 1995 to 2004, 27% of sales of sand and gravel in England were not replaced by new permissions.
Why has construction not collapsed between then and now? Because sales of primary or virgin sand and gravel are in decline, and have been so for years – as the figures for Devon bear out, where annual sales are less than a third of what they were in 1990.

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Government commits to more timber construction


Investing in timber is investing in growth and levelling up. The built environment is responsible for a huge proportion of UK carbon emissions, and using home-grown timber in construction is key to reducing emissions.
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Cemex UK trial use of up to 100% recycled aggregates


Mike Higgins, Cemex’s national technical manager for UK research and development, commented: 
Reusing recycled products in our materials where possible not only reduces waste, it helps to preserve our aggregates reserves and protects our business in the long term.
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‘Companies regularly set ambitious climate goals... that often quietly fizzle away’


While companies often gain positive media attention by trumpeting plans for reducing greenhouse gas emissions, many are failing to reach their climate goals, and the media rarely picks it up. There is little accountability and transparency on the outcomes of these goals, where various stakeholders, like investors and rating agencies that measure environmental, social, and governance (ESG) risk, do not penalize firms for missing these targets
Once upon a time, Aggregate Industries trumpeted ambitious plans for reducing greenhouse gas emissions. In 2018, we posted The CO2 emissions that AI ‘forgot’ in 2016 and wrote: ...
we've heard about establishing baselines before – in 2012, 2008, 2003 – and the company has consistently failed to achieve any progress against them. Let's look, for example, at how AI fared against its 2012 baseline: 
2013: "Absolute process carbon emissions have increased against the 2012 baseline" 
2014: "Absolute carbon process emissions continue to rise and are now 13% higher than the baseline year" 
2015: "Absolute process carbon emissions continue to rise and are 20% above the 2012 baseline" 
2016: No mention of baselines 
AI has talked about reducing its CO2 emissions for more than 15 years, and has achieved exactly the reverse. 
Since then, Aggregate Industries has given up reporting its CO2 figures. In 1999, the company reported 228,267 tonnes of CO2. In 2019, in the post Climate emergency? Not at Aggregate Industries. CO2 emissions increase again, we estimated the company was emitting more than 5x that amount – somewhere in the region of 1.3 million tonnes of CO2 each year. 

Aggregate Industries is part of cement conglomerate Holcim. Last year, the company claimed that for 2022, "we delivered on all our net-zero levers", and that for 2023: 
We are accelerating our net-zero journey to decarbonize Holcim. Taking a science-driven approach, we upgraded our climate targets to align them with the 1.5°C framework and validated them with the Science Based Targets initiative
Bravo. But who's checking whether any of these targets are achieved?

Perhaps these Indonesians will. As previously posted, they are taking legal action against Holcim.

 


ECCHR, the European Center for Constitutional and Human Rights, claims Holcim is "among the top 50 largest CO2 emitters in the world", and that its climate strategy is "Too little – too late": 
Climate change is happening. The clock is ticking. The global consensus is that global warming must not go beyond 1.5°C. Yet, to stand a chance of achieving this 1.5°C limit, the remaining carbon budget must be distributed fairly among all actors. Currently, the global cement industry contributes up to 8% of the global annual carbon dioxide (CO2) emissions, since the production of cement is extremely CO2 intensive. The Swiss-based cement group Holcim Ltd. is the biggest player within the cement and concrete industry, and among the top 50 largest CO2 emitters in the world. Since 1950, Holcim has emitted over 7 billion tonnes of CO2, which accounts for 0.42% of all global industrial CO2 emissions, or twice as many emissions as produced by the whole of Switzerland during the same period. Holcim has published a climate strategy which includes the ambition to become a net zero corporation by 2050. However, as this report shows, Holcim’s climate targets and business strategy are not in line with the 1.5°C limit and are therefore further exacerbating the climate crisis. 

This report looks at Holcim’s past, current and future climate impact through assessing its past and present emissions, as well as its future emission reduction plans. It explains that Holcim has largely contributed to the climate crisis due to its enormous historical emissions. The corporation’s 2021 emissions still account for three times the annual emissions of Switzerland and have risen in recent years. The report concludes that Holcim’s emission reduction targets are incompatible with the 1.5°C limit. According to the latest climate science, to stand a 50% chance of achieving the 1.5°C limit with no or limited overshoot, absolute emission reductions of 43% until 2030, 69% until 2040 and 84% until 2050 from a 2019 base year are required.
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DCC approves Tungsten West secondary aggregates plans for Hemerdon Mine

Last month, Devon County Council approved Tungsten West’s secondary aggregates plans for Hemerdon Mine, plans that were last posted about here. 

Tungsten West’s planning application was: 
Variation of Condition 19 of planning permission 9/42/49/0542/85/3 (DCC/3823/2015) (dated 16 February 2017) to remove weekly and annual tonnage caps on the export of secondary aggregates and to amend the condition to introduce restrictions on hours of export and prohibit exports at the weekend and on bank holidays, Hemerdon Mine, Plympton  
The Officer's Report can be found here. 

Under Need and Market Considerations, the Council made the case that: 
7.10 The Devon Minerals Planning Monitoring Report 2021 (February 2023) reports that the MPA are underdelivering on their objective to have a 20% proportion of total sales of land won and secondary aggregates within wider Devon accounted for by secondary aggregates, with the latest figure stated as 17.7%. 
The Devon Minerals Planning Monitoring Report 2021 can be found here, and here. 

Later in December, Tungsten West announced a £1.8m lifeline, and then a £9.1m loss.
 
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