Monday, 20 February 2017

AI's haulage plans could cause the same road damage as 17 billion car movements

The LGA warns that pothole levels across the UK are likely to surge due to a spike in HGV numbers:
The Local Government Association... says chronic government underfunding has left the local roads network facing an "unprecedented crisis" and this new increase in lorries could push the network "over the edge".
Councils are warning 2017 could be a tipping point year for potholes, with the repair bill... projected to rise to £14 billion by around 2019... more than three times councils' entire annual revenue spending on highways and transport...
"Motorists should literally be bracing themselves for a surge in potholes. Our local roads network faces an unprecedented funding crisis and the latest spike in lorries could push our local roads network over the edge. Lorries exert massively more weight on road surfaces than cars, causing them to crumble far quicker.
Road damage rises steeply with axle weight, and is widely acknowledged to be proportional to the fourth power of the axle weight. This means that doubling the axle weight increases road damage 16 times, and in the case of the heaviest (44-tonne) trucks... HGVs are up to 160,000 times more damaging to road surfaces than the smallest vehicles.
Aggregate Industries is wanting to shift 1.5 million tonnes of as-dug sand and gravel from Straitgate Farm to Uffculme. This equates to some 105,260 HGV movements, which - according to the above - could generate the same road wear and tear as up to 17 billion standard car movements. Has AI factored road repairs into its costings yet?

Of course, for Devon County Council, the irony is that - by adopting a Minerals Plan with a Preferred Area for sand and gravel quarrying that can only be processed 23 miles away - this situation is entirely of its own making; a 2.5 million mile own goal.

Record noise nuisance on your phone

The Noise App has been designed to simplify noise reporting and investigation.
Since it was launched in 2015, the app has processed more than 50,000 noise reports and is used by 100-plus organisations including police forces, councils, housing associations and construction companies.
Because it is hassle free, with no expensive or specialist equipment needed, it is popular with residents and the professionals investigating noise problems.
It is another one of the "publicly-funded apps helping to streamline services, save money and make citizens’ lives easier". One council says the Noise App "has revolutionised how we deal with noise nuisance cases". You can understand why. As another council using the Noise App said, in an article describing how a couple were fined £18,000 after complaints about noise:
If a complaint is made to the council, we have a duty to investigate it, and wherever possible we try to resolve the issue amicably.
As we posted in Noise, dust, statutory nuisance, the leaflet produced for Buckfastleigh Town Council - in response to complaints about Whitecleave Quarry - clarifies the law on noise:
Local authorities have a wide range of legal powers to act against noise. They have a duty to deal with any noise they consider to be a ‘statutory nuisance’. You have a right to request monitoring at your property or other location where noise affects you.
There is no specific decibel level or limit to determine nuisance. If it is found to be 'statutory nuisance' the authority must serve an abatement notice – which is an order to deal with the nuisance. This order may demand the noise stops altogether.
A quarry in Cornwall was served such an abatement notice last year. The same article in which this was reported gives examples of How loud is loud?



Thursday, 16 February 2017

Eric Olsen: “Tackling #climatechange requires a shift in the way we do business”

No-one would disagree with this statement from LafargeHolcim's CEO.

But when subsidiary Aggregate Industries thinks it can foist a 2.5 million mile #CO2 polluting haulage plan onto the county of Devon, perhaps he should put his own house in order first.



Industry undertakes

The industry believes that there is an urgent need for a UK Minerals Strategy to ensure medium and long-term demand is supplied to support economic growth and delivery of the Government’s emerging UK Industrial Strategy and the National Infrastructure Delivery Plan.
The industry cannot ensure that objectives are achieved without engagement and understanding from others such as Government, planning authorities and regulatory agencies, environmental NGOs and the wider public to maintain a resilient supply chain for these vital materials.
An action plan has been produced. There's a range of things that industry undertakes to do. Here's one:


Perhaps someone should have told Aggregate Industries that industry undertakes to reduce the need for long distance mineral transport, not plan multi-million mile haulage schemes across Devon.

Monday, 13 February 2017

This is what a haul road looks like


It takes material from the quarry face to the processing plant.

It does not look like Birdcage Lane.
It does not look like Exeter Road.
It does not look like Daisymount Junction
It does not look like the A30.
It does not look like Junction 29.
It does not look like the M5
It does not look like Junction 27.
It does not look like the A38.
It does not look like Clay Lane.

A sand and gravel quarry haul road does not ever look like 46 miles on public roads, for 52,600 round trips over a period of 10-12 years.

Devon’s new Minerals Plan has taken 10 years to prepare, since the first workshop in February 2007.

A decade of consultations, delays and public expense - for what?

For Devon County Council to deliver Straitgate Farm as a Preferred Area for sand and gravel quarrying that can only be worked with a 2.5 million mile haulage plan using the above public roads.

If that’s the Council’s idea of Minerals Planning, then Devon would be better off without it.

No-one would want to see a repeat of what happened in Aberdeenshire on Friday: Dad and little girl cheat death after car rammed through wall and mangled beyond recognition by lorry.


After all, we've already had scenes like these - here and here - on local roads in 2016:



Devon Wildlife Trust tweets about Dormice





Friday, 10 February 2017

People can decide for themselves 'if the whole bloody system is functional or bent'

In December, we made a complaint about the Devon Minerals Plan to the Secretary of State for Communities and Local Government, and requested a holding direction. The basis of our complaint was that extensive haulage plans from Straitgate to a processing site beyond the immediate area had at no time been the subject of a Sustainability Appraisal.

A SA is required under Strategic Environmental Assessment Directive 2001/42/EC for each Local Plan proposal. The SEA Directive is to ensure that "an environmental assessment is carried out of certain plans and programmes which are likely to have significant effects on the environment." This directive is transposed into the NPPF, which says that "a sustainability appraisal which meets the requirements of the European Directive on strategic environmental assessment should be an integral part of the plan preparation process, and should consider all the likely significant effects on the environment, economic and social factors."

During the Minerals Plan process, there was a stand-off between operator and council over processing locations. Aggregate Industries insisted it could only process Straitgate Farm material at Blackhill, not Rockbeare; DCC was pushing for the reverse. No alternative processing locations were ever considered.

Natural England’s concerns over importing nitrate-rich material to Blackhill, and the approval of an alternative planning application for Rockbeare, finally confirmed the unavailability of both locations for processing. Despite having been told both of these facts, the Inspector nevertheless concluded:
71. Rockbeare... is an option that could be explored if Blackhill Quarry could not be used.
AI is looking to process Straitgate material at Uffculme, 23 miles away - the only location available to the company. Most normal people would consider a 2.5 million mile haulage scheme to have a significant effect on the environment, yet this was never assessed in the Minerals Plan process by SA or otherwise.

DCC’s SA runs to 100s of pages. We learn that "the purpose of SA is to promote sustainable development by integrating sustainability considerations in to the preparation and adoption of plans."

For Straitgate, we learn things such as:
Straitgate Farm also has nesting House Sparrows and possibly a Schedule 1 bird species - the Barn Owl.
We learn that:
...residency time of carbon dioxide in the atmosphere is 200 years and therefore the impacts will continue to affect the climate for an extended period.
We learn that:
At this site, processing is likely to occur elsewhere which contributes further emissions compared to a site option that has capacity for on-site processing.
What we do NOT learn, however, is that Straitgate Farm - one of DCC's two Preferred Areas for future sand and gravel quarrying - can only be worked with a 2.5 million mile haulage plan.

We made this point to the DCLG. We also made the point, as we did in 2012 along with the Environment Agency and Natural England, that a SA did not inform the choice of sand and gravel sites for inclusion in the Plan. DCC rejected eighteen alternative sites several months before the SA. The SA confirmed that Straitgate was one of the most constrained sites of all the sites considered.

But actually, we needn't have bothered. The DCLG - who has had dialogue with DCC subsequent to our complaint - has now written, without explanation:
I have considered your letter and have found no grounds for concern in the inspector’s report, nor grounds for the Secretary of State to intervene at this time.
The Devon Minerals Plan will now be formally adopted on 16 February 2017. It remains to be seen how a 2.5 million mile haulage plan would fit with the very first objective of this new Plan:
Objective 1: Spatial Strategy
Within geological constraints, secure a spatial pattern of mineral development that delivers the essential resources to markets within and outside Devon while minimising transportation by road and generation of greenhouse gases, supporting the development of its economy while conserving and enhancing the County’s key environmental assets.

Wednesday, 8 February 2017

Whilst AI has 44-tonne designs for Birdcage Lane...


Miscellaneous


2. Whilst China's solar power capacity doubled in 2016, the UK backed a new source of fossil fuels. Fracking is highly controversial and supported by just 17% of people in a government survey. Aggregate Industries was one of the first in line to profit from fracking. This week, one aggregates company did the decent thing after a quarry protest in Bolton. A second supplier has followed suit.

Bolton News

[Marine sources] were responsible for supplying 25% of the sand and gravel needs in England and 49% of the equivalent needs in Wales.
The vessels will be the first new aggregate dredgers to be commissioned by the company in the UK for more than 25 years.

... results in significant disturbance through removal of substrate and the generation of sediment plumes through processing of the aggregate. The latter can lead to local burial of habitats and smothering of animals.
4. Let's put Aggregate Industries' plans to destroy 2km of ancient hedgerows and dormouse habitat at just one site in East Devon into context; not all farms are like Straitgate.

Yes, 'consider the possibilities that drones can bring to the world of construction'


We mentioned one of the possibilities in A new level of scrutiny on quarry operators... which cast a new light on an abandoned Aggregate Industries' quarry in Derbyshire.



Here are some of the other possibilities that drones can bring to the world of construction.






Monday, 6 February 2017

AI's asphalt plant at Rockbeare continues to operate without permission




Whilst a 'Towering inferno at an Aggregate Industries Express Asphalt plant in Greater Manchester proved 'awkward' for firefighters' and 'could have been extremely dangerous', the company's asphalt plant at Rockbeare in Devon continues to operate without permission.

Last May, AI submitted a planning application, DCC/3867/2016, to retain the plant. AI has been operating the asphalt plant at Rockbeare without planning permission since 2014.  According to its own supporting statement:
3.1 The existing asphalt plant was permitted, in its current location, under planning permission 99/P0568 (see Appendix 1). Under condition 8 of this permission, the asphalt plant was time limited by way of requiring removal of the plant upon cessation of mineral extraction. Condition 8 states:
“Unless otherwise agreed in writing with the Mineral Planning Authority, upon completion of the mineral working at the mineral site, the plant hereby approved shall be removed and the area restored in accordance with details to be submitted pursuant to Review of Old Mineral Permission No.7/11/98/P0050.
Reason: To ensure satisfactory restoration in the interests of visual amenity.”
3.3 Mineral extraction ceased at Rockbeare Quarry (Marshbroadmoor) in 2014. The purpose of this planning application is to seek the permanent retention of the asphalt plant, aggregate store and associated facilities.
Extraction at next door Marshbroadmoor may have ceased in 2014... but since none of this mineral was ever processed at Rockbeare that date seems immaterial. What does seem material is, as AI pointed out in its planning application for Straitgate Farm, that "mineral processing was last carried out at Rockbeare in 1994" [5.36] when "most of the production was used on a daily basis by the on-site asphalt plant and the Charcon Concrete Products Factory (now closed)".
We made the point that if mineral processing - and production of a sand and gravel feedstock for the asphalt plant - is no longer carried out at Rockbeare:
Why should Rockbeare continue to be a suitable and sustainable location for asphalt processing? Why should the community permanently forgo the "satisfactory restoration in the interests of visual amenity"?
The consultation to this application closed in July 2016. DCC has since advised:
The deadline date for the determination of this application has been extended to the 7th March 2017 in order to allow further discussions and consideration of biodiversity off setting which may be required as a result of the land occupied by the asphalt plant not being restored for the benefit of nature conservation, as originally envisaged in the Rockbeare Quarry permission.
As yet, DCC and AI "have not discussed any specific sort of offsetting and where it would be".

Friday, 3 February 2017

"Building hedgerows, habitat corridors & bridges is critical to this species' survival"


Dormice inhabit the ancient hedgerows of Straitgate Farm - the same hedgerows that Aggregate Industries plans to destroy. Virtually no established and appropriate mitigation planting is yet in place: 85% of the trees planted will have to be removed for airport safeguarding purposes [6.6, 6.12] and the hedgerows that have been planted are now in the wrong place.

Dormice, a European Protected Species, are on the verge of extinction. New research tells us why:
The existence of the UK's endangered Hazel dormouse is under threat as gaps in tree canopies are leaving the creatures unable to use their hypersensitive whiskers to naturally cross between habitats, a new study reveals...
Gaps in the tree canopy proved to be a major problem for the dormice meaning that gaps in their habitats need to be connected in order to help preserve numbers. Building hedgerows, habitat corridors and dormouse bridges is critical to this species’ survival...
Dr Grant said: “Although dormice can jump quite large distances, when the gaps between platforms were larger than 10-15cm, the dormice started behaving differently – they would eat less of the food available to them and also spend more time travelling on the floor as opposed to the canopy. This behaviour change would put the dormice in danger as this species is vulnerable to threats on the ground.”
Here's where dormice have been found at Straitgate. AI's plans rip right through their habitat.


Wednesday, 1 February 2017

Venn Ottery Quarry surface water run-off


It’s encouraging to see restoration now proceeding at Venn Ottery Quarry. The roads are quieter and the horse-riders are back out in force.

But surface water run-off from the quarry has been a persistent problem, particularly for the Public Right of Way that runs along the eastern side of the site. Complaints have been raised over the years.

Aggregate Industries has seemingly made no provision for surface water run-off from the quarry, which has now washed part of the footpath away.

At Straitgate Farm, with flood-prone communities downstream, surface water run-off will be critical in any quarry design. At Venn Ottery Quarry even a footpath presents a problem.


Edit 04.02.17: We’ve since been advised of more serious erosion immediately downstream of the above.

Tuesday, 31 January 2017

Quarrying and processing restarts at Hillhead


Further to AI's had second thoughts about processing Hillhead material at Blackhill, mobile plant has now been installed in Hillhead Quarry, and is processing material from next door Houndaller. Aggregate Industries has 4.23 million tonnes of sand and gravel available at Houndaller - with planning permission - enough to last the company 12 years or more.


Hillhead Quarry is where AI wants to process any material it wins from Straitgate Farm. It's 23 miles from Straitgate, and currently without the sort of fixed, capital-intensive plant used at Blackhill that AI had previously said would be required for Straitgate material:
The substitution of the Blackhill plant with a mobile processing plant would severely restrict the output and product range to serve market demand. 8.30
For those unfamiliar with Hillhead, here's where AI's mobile plant is sited in relation to Houndaller.


And here's what's left to quarry, shown on one of the plans from AI's recent Hillhead ROMP application.



Meanwhile, huge stockpiles remain at Blackhill Quarry on Woodbury Common, but processing has now ceased. The processing plant and sales operations will be removed from the site within 12 months, in accordance with the Blackhill Restoration and Aftercare Scheme Revision F 2013:
4.14 Area 12
4.14.1 Restoration will commence in accordance with the requirements of planning permission ref: 10/0473/CM at the end of 2016 and be completed by the end of 2017...
4.14.3 The existing quarry processing plant, associated infrastructure, weighbridge, weighbridge office will be removed from the site.

Monday, 30 January 2017

Rail movement of aggregates on the increase

Aggregate Industries is planning 2.5 million HGV miles on Devon roads with the Straitgate Farm planning application, but elsewhere more aggregate is being moved by rail:


Because rail produces 90% less particulates and 15 times less NOx than trucks, which are key contributors to air pollution.
Rail freight additionally produces 76% less CO2 emissions than the equivalent HGV journey.
And rail freight is safer; HGVs have been six times more likely than cars to be involved in fatal collisions on urban roads over the past three years (based on the percentage of miles they represent).

Thursday, 26 January 2017

Straitgate groundwater levels at their lowest... in the middle of winter

January is typically a month when groundwater levels are around their highest. There was therefore surprise when readings taken from piezometers around the site today were at their lowest since monitoring started in 2013.

One piezometer was some 2.8m lower than the average of the previous three winter measurements, and 50cm lower than any reading previously recorded, summer or winter.

These readings will not have informed Aggregate Industries’ latest planning application - which is still awaiting validation by DCC.

All 4 Better Development

Campaign groups across the country have joined All 4 Better Development, a national alliance against rural over-development. Sign the petition calling for changes to planning legislation:
This petition calls for a parliamentary debate on government Housing and Planning policy over building on greenfield land and seeks community right of appeal on planning decisions and the removal of the presumption in favour of sustainable development.

Sunday, 22 January 2017

Refusal recommended for Tewkesbury quarry application on noise and dust grounds

Planning officers at Gloucestershire County Council have recommended refusal for a sand and gravel quarry in Church End, near Twyning. The applicant proposed to:
extract 98,000 tonnes of sand and gravel from 3.04 hectares and restore site to agriculture, amenity and nature conservation uses with imported fill over a period of 2.5 years
The "minimum extraction stand-off margins would be 60m from the nearest residential property" - not unlike the wholly inadequate stand-offs proposed at Straitgate, an operation that would last 10-12 years.

Despite the modest scale of the Church End scheme, Gloucestershire planning officers concluded:
8.1 It is recommended that planning permission be REFUSED for the following reasons: 
1. The proposal fails to demonstrate that the noise from mineral extraction operations can be mitigated to an acceptable level so as not to interfere with local residents’ use and enjoyment of their property contrary to Minerals Local Plan policies DC1 and E14, the Tewkesbury Borough Local Plan policy EVT3 and Paragraph 144 of the NPPF. 
2. The proposal would have an unacceptable, adverse impact on the environment arising from the impact of dust for those living, visiting and working in the vicinity of the site contrary to Minerals Local Plan Policy DC1 and Paragraph 144 of the NPPF... 

Scottish aggregate shipped to Devon

The Devon Minerals Plan (Proposed Adoption Version) tells us that:
5.4.6 Small quantities of marine-dredged sand and gravel are landed at Appledore and Yelland to serve local markets in northern Devon that are remote from the land-won sources in the east of the County.

Is the North Devon Marketing Bureau trying to draw tourists from East & Mid Devon?

Or is Evans Transport - one of the South West's largest privately owned transport companies and owner of the lorry branded to encourage people to visit North Devon - sizing up the Straitgate haulage job?

Friday, 20 January 2017

A new level of scrutiny on quarry operators...

... and the mark they leave on our landscape. The first two films star an abandoned Aggregate Industries' quarry in Derbyshire.









Big Issue

In its rush to profit from fracking, Aggregate Industries makes the front cover of Big Issue North.

Wednesday, 18 January 2017

Planning application for Straitgate inextricably linked to Hillhead



The first application is for a new sand and gravel quarry at Straitgate Farm located 3km west of Ottery St Mary. The second application is to allow for the importation of as-dug sand and gravel from Straitgate Farm into Hillhead Quarry for processing.
It was the same with the last application for Straitgate; that was inextricably linked to the application for processing at Blackhill - they shared an Environmental Statement.

If the new applications for Straitgate and Hillhead are inextricably linked, then surely the Hillhead ROMP application must also be linked? We've mentioned some of the problems with this application already: More groundwater problems for AI, Hillhead truck numbers ‘don’t stack up’, Another objection to AI's Hillhead ROMP application.

DCC has now issued a Regulation 22 request for the ROMP application outlining even more problems, including the fact that no noise, dust or cumulative impact assessments have been performed.

It should be remembered that DCC first gave notice to AI in 2013 that a review of operating conditions at Hillhead Quarry was due. AI submitted a ROMP application in March 2014 and DCC issued a Scoping Opinion in January 2015. It is therefore difficult to understand why, at the start of 2017, AI has still to supply such fundamental information.

Many will also wonder how a new application for Straitgate, an application that is inextricably linked to Hillhead, can proceed when there are still so many outstanding issues relating to this ROMP application.

Saturday, 14 January 2017

AI's planning application set in motion - again

Aggregate Industries has given formal notice to affected tenants that a revised planning application to quarry Straitgate Farm was submitted to DCC on 12 January. The application will be open for comments once it has been validated by DCC. We will post further information when we have it.


The Devon Minerals Local Plan will provide the planning policy framework for assessing AI’s applications for quarrying at Straitgate and off-site processing at Uffculme, 23 miles away - a haulage scheme totalling some 2.5 million miles. The new Plan has yet to be formally adopted, but says this on transportation:


Here are a few more relevant policies:



The mysterious and unpredictable world of planning

Aggregate Industries will be looking to put anything up to 200 HGV movements per day onto Birdcage Lane, as part of its crazy haulage scheme to and from Uffculme 23 miles away.

Birdcage Lane is a quiet country lane. It sees one or two trucks a week for rubbish and recycling collections. It’s used for walking, running, cycling and horse-riding.

Now look at a planning application that came before DCC last year, DCC/3863/2016, an application - involving a similarly narrow country lane - that proposed an increase in the number of HGVs bringing waste to an industrial site near Cheriton Bishop, an increase from one to three movements per day.

Not HGV movements of the 44-tonne AI kind, more like the "10 tonne tractor/trailer combo" farming kind.

Letters of objection were lodged, but Mid Devon District Council had no objection, nether did the Environment Agency nor the Highways Authority. Planning officers recommended approval "in accordance with the policies of the Waste Local Plan"

However, the DMC committee went against that advice, and considered that three movements a day "would have an adverse impact on the peaceful enjoyment of the countryside and of the individual residences". In fact, the full refusal considered that the proposal was not in accordance with the Waste Local Plan:
It is considered that the increase in traffic as a result of the proposal would have an unacceptable impact on the amenity of residential properties close to the roads leading to the application site and upon the peaceful enjoyment of the countryside, in terms of traffic noise and vibration, contrary to policy W18 of the adopted Devon Waste Local Plan.
Policy W18: Quality of Life:
Peoples’ quality of life and amenity will be protected from the adverse effects of waste management development and transportation…
That might have been the end of it, had the applicant not appealed. DCC then argued that:
The DMC were mindful of the representations as reported in the committee report which included 19 letters of objection from local residents and an objection from the Local Member (Devon County), as well as representations made at the DMC by [a local resident], who spoke on behalf of a number of members of the local community.
15. ... the private residential gardens of the properties extend up to the road and occupiers’ ability to enjoy their outdoor space is an important component of their quality of life.
17. The frequency of noise and vibration events would increase significantly as a result of the proposal...
22. I have found above that the proposal would result in a significant increase in HGV movements along the haul route to the site. I consider that the greater frequency of noise and vibration events related to HGV movements would erode the tranquil character of the surrounding rural area. I also consider that this increase would adversely affect the ability of local people to peacefully enjoy the lanes and surrounding area through activities such as walking, running, cycling and horse-riding.
All things to bear in mind when AI launch their planning application for a quarry just a stone's throw from nearby homes with 100,000 HGV movements thrown in for good measure. How much will the living conditions of nearby residents and the peaceful enjoyment of the countryside come into it then??

How much confidence does Amec have in those contours?

Aggregate Industries' last planning application was all about separating fact from fiction. The new application will no doubt be much the same. Perhaps that’s not surprising, in this new "post-truth" age in which we find ourselves.

AI will wheel out its expert reports again, but read I'm a Scientist, and I Don't Believe in Fact from Julia Shaw, author of "The Memory Illusion: Remembering, Forgetting, and the Science of False Memory". She reminds us that "scientists don’t prove anything". In fact:
... please stop saying "because, science" to justify your argument, and using “FACT” as a preface to your statements. These are just the grown-up versions of "because I said so." We need to remind each other to stay on our toes and to actually backup our claims.
And this applies to AI’s water consultants, Amec Foster Wheeler, too.

There is uncertainty with any data, and any prediction derived from that data. No model can make predictions with 100% certainty. Scientists start their academic life having that drummed into them, and know to give an indication of confidence in any results they produce.

Amec used just 6 numbers (from PZ01 to PZ06) to map maximum groundwater contours across more than 60 acres at Straitgate Farm; contours that "represent just two of the many possible interpretations of the data which themselves are based on an incomplete parameterization of the detailed groundwater dynamics of the site".

Does it sound like Amec is 100% confident in those contours to you? It is these contours that AI wants to quarry down to, without leaving 1m above the maximum water table to protect drinking water supplies.

If Amec is not 100% confident in those contours - and how can it be - then how confident is it? How does that translate to a +/- figure? If it's no more precise than +/- 1m, say, how can AI justify not leaving the 1m? If it's more precise, then Amec needs to actually back up its claims.

Last year, we asked DCC:
Since AI now intends to dig right down to the maximum water table, perhaps you could ask Amec to confirm the specific level of accuracy (in +/- m) to which their maximum groundwater contours are mapped?
DCC asked AI and Amec for an answer. To date, none has been forthcoming.

Reducing freight CO2 emissions

Aggregate Industries' plans for Straitgate would involve over 100,000 truck movements and some 2.5 million miles. The Campaign for Better Transport warns us that:
Given that HGVs produce 22 per cent of transport’s CO2 land transport emissions while only accounting for 5 per cent of vehicles it is crucial that more freight be transferred to rail and that HGVs become more efficient. While road haulage has long been competitive, load efficiency has not improved significantly nor has empty running which remains at around 28 per cent of HGVs.


For those used to old money, 35 litres/100km is about 8 miles per gallon.