Monday, 29 February 2016

AI truck in collision with coach on B3180 in 2014 - SLR rewrites events in cover-up

Aggregate Industries' planning applications are packed full of fiction, but this surely wins the prize.

As part of AI's planning application, its consultants SLR produced a Transport Assessment for the haulage route from Straitgate Farm along the B3180 to Blackhill Quarry. At the time, we said the TA was as far removed from reality as any we had seen. The TA only included accident data up to the end of 2013; which seemed strange, for a planning application of May 2015. DCC requested:
The CHA would also wish see more comprehensive up-to-date accident data for the whole of the proposed haulage route included within the application.
AI and SLR supplied further information, and lo and behold it turned out that not only had SLR miscounted the number of HGV incidents, but that 23% of accidents on B3180 involved HGVs in 2014.

But SLR didn’t tell the whole story. In fact, it told a different one. Perhaps AI and SLR could explain why they tried to bury the facts and mislead DCC and the public? Because the whole story is not to be found in AI/SLR's Item 5 on Highway Safety, but on Twitter:



That’s AI’s HGV in the photograph. There were three incidents involving HGVs over 7.5 tonnes on this stretch of the B3180 in 2014. DCC’s road accident data describes the above collision as:



The local paper described the collision as:
Witnesses say a coach and a lorry were involved in a collision and the road is closed from the A3052 Sidmouth Road, Halfway House junction, to Woodbury Park.
But for reasons known only to those "committed to acting honestly", SLR took DCC’s data above - contained in the appendices - and changed "bus/coach" to "rear of a car":
B3180 - Sanctuary Lane to Castle Lane
Two accidents that resulted in slight injury only occurred along this section of road. One of the accidents involved three cars... The other accident occurred when an HGV collided with the rear of a car in front. 2.44
Not content with that change, SLR also failed to point out that it wasn’t just any old HGV involved in the collision, it was its client's HGV, an Aggregate Industries HGV in collision with a coach.

Why is SLR corrupting the facts? Did SLR bow to AI pressure? Or did SLR take it upon itself? What can people believe if AI/SLR are prepared to manipulate data like this; how much of what AI and SLR tell us is reality and how much is fantasy?

Because AI/SLR want us to believe that:
The accident analysis at Section 2.4 of the TA and Item 5 of this Regulation 22 response suggests that there are no historical safety issues from HGVs using the proposed haulage route. 2.80
The TA provided a thorough and robust assessment of the impact of the proposed development on the current and future local highway network… 2.85
Records show that the majority of the proposed haulage route has been used for the regular transport of extracted material from Rockbeare, Marshbroadmoor and Venn Ottery historically without adverse impacts to road network operation or safety. 8.47
But the evidence above, together with other evidence, shows that those statements are simply not true. It’s obvious that AI’s HGVs - up to 200 movements a day - should not be on the B3180 and Woodbury Common; 2016 is the year those HGVs should stop for good, before something more serious happens.

Is the B3180 getting more dangerous?

Picture: Simon Horn

Aggregate Industries wants to use the B3180 to haul sand and gravel from Straitgate Farm, across Woodbury Common, to Blackhill Quarry for processing - up to 200 HGV movements a day for 5 years; HGVs like the one above. Is the B3180 getting more dangerous? Not every incident on this stretch will have been picked up by @BBCTravelSW over the last 12 months, but look at those that have:












Monday, 22 February 2016

Another year, another example of 'dry-working' at AI's Venn Ottery Quarry


We posted about the amount of water at Venn Ottery last year, about how Aggregate Industries had made assurances to the Environment Agency in 1998 that the site would be dry-worked. This is what the site looks like this year - even more water.

This site has the same geology as Straitgate, the same hillside position as Straitgate, the same operator as Straitgate, and plainly the same dodgy assurances as for Straitgate.

We have also posted about what’s left of Thorn Trees Plantation on Woodbury Common after AI finished quarrying there about six years ago, and the amount of standing water.

AI has made assurances about dry-working at Straitgate, how any water bodies would be ephemeral, how "standing water would only be observed during periods of extreme rainfall". 7.101

The issue is of course more critical at Straitgate, with an international flight path directly above it; with more than a 100 people dependent on the site for clean unpolluted drinking water; with a history of flooding events downstream.

AI only recently came clean about how deep it wants to quarry at Straitgate. Look at the photograph again. Does AI look like the sort of company to be trusted with assurances about dry-working?

On the issue of flooding and pollution, only last month the EA said, in response to Devon's Minerals Plan:
Climate change, especially increasing rainfall intensity and volume, is a growing risk to the mining industry locally. There have been increasing instances of sediment run-off pollution events from operational sites due to a failure to appropriately plan for and address volumes of rainfall received on unvegetated operational sites, combined with a poor understanding of critical surface runoff pathways and the degree of attenuation required.
Doesn’t give you much faith does it?

AI schedules test pits and boreholes for next week...

...to perform the drainage and nitrates testing that was due last year. No archaeologist has been booked to attend; nitrates testing has been located along hedgerows where no slurry or fertiliser is ever spread.

This is how much damage was done to Roman remains the last time AI arrived to dig test pits.

Edit 25.2.16: SLR archaeologist now instructed to oversee works.
Edit 29.2.16: Nitrates testing now to be 20m from hedgerows.

DCC’s comments on Minerals Plan representations

For those interested, DCC has responded to the representations made in the pre-submission consultation on the Minerals Plan, and has made the following document available for the forthcoming Examination.


While Devon County Council has endeavoured to summarise each representation accurately, the length of some representations and the need for conciseness in this document may lead to some loss of detail in the summaries. Examination participants may therefore wish to refer to the full representations provided in document SD07.

Tuesday, 16 February 2016

Devon Minerals Plan submitted for examination

DCC advised today that:
Following its pre-submission consultation which ended on 16th November 2015, the Devon Minerals Plan has been submitted to the Secretary of State for Communities and Local Government for the purpose of examination.
The submitted Minerals Plan, together with consultation responses and supporting documents, can be viewed on the Council’s website here. The Devon Minerals Plan can also be viewed at County and District Council offices as explained in the attached Statement of Submission.
An inspector will shortly be appointed to conduct the examination of the Minerals Plan. To assist the inspector and act as the point of contact for examination participants, Mr Robert Young has been appointed as the programme officer and his contact details, together with information on the examination, will be published shortly here.
If you have any immediate questions on the Devon Minerals Plan, please contact the County Council’s Minerals Planning team by emailing mineralsplanning@devon.gov.uk or calling 01392 383510.
According to DCC's website, an inspector has already been appointed:
Mr Andrew Freeman BSc(Hons) DipTP DipEM FRTPI FCIHT MIEnvSc has been appointed as inspector to undertake examination of the Plan.
Furthermore:
During the course of the examination, a number of further documents will be produced by the County Council, the inspector and other examination participants. These will be added to the Examination Library as they are published.
One of the documents of interest to those following the farce being played out at Straitgate will be:
This series of documents shows how, because of statements such as these from Amec:
The removal of the unsaturated zone down to a level 1m above that defined by the maximum winter water level will mean that any change in the recharge/runoff split...
By maintaining an unsaturated zone thickness of at least 1m...
... a 1 m unsaturated zone should be enough to accommodate this intense rainfall event.
DCC was able to secure the following assurance from the Environment Agency:
Thank you for your email of 05 June 2015 forwarding the additional information submitted by AMEC in respect of the above. We are satisfied that the impacts on the hydrograph and ecology of the 4 springs, headwater streams and Cadhay Bog County Wildlife Site from dry working will not be significant. We are now satisfied with the information submitted with regard to the allocation of this site and have no objections to the inclusion of the Straitgate site from the minerals plan.
A couple of weeks later the EA confirmed:
Aggregate Industries have proposed to stop quarrying a metre above the water-table. We expect DCC to make this a condition of any permission that is granted.
Of course, it now transpires that AI has absolutely no intention "to stop quarrying a metre above the water-table". DCC put its new Minerals Plan on hold for three years while it waited for this assurance from the EA - an assurance that now turns out to be based on a completely false premise. What the Inspector will make of all this is anybody's guess.

Wednesday, 10 February 2016

Great crested newts... and rising water tables

Aggregate Industries is desperate to use Blackhill beyond 2016 to process material from Straitgate, and has put up a range of arguments as to why it couldn’t use its derelict site at nearby Rockbeare instead; one of these arguments is the presence of great crested newts:
It has been demonstrated that processing at Rockbeare is not physically possible due to a lack of silt space and clean water storage, insufficient stocking and processing area and the presence of great crested newts in existing ponds. 8.37
Natural England has demolished these arguments and doesn't see GCNs as a constraintBut guess what? Tarmac doesn’t see GCNs as a barrier to working either. It’s been working with them for years at a quarry in Cheshire, where "a number of ponds, pools and ditches have been created at Crown Farm Quarry as a result of historic quarrying activities". There’s even a paper on the subject:
The discovery of a widespread population of great crested newts at Crown Farm Quarry could have been a major constraint to the operators at this mineral extraction site. However, with early involvement of ecologists, appropriate management, innovative mitigation measures, and a positive approach by Tarmac, this potential constraint has become a success story.
But why all these "ponds, pools and ditches"?
An unexpected rise in the water-table has also contributed to the formation of these waterbodies.
An unexpected rise? It's hardly surprising. At Straitgate, hydrogeological consultants are trying to predict the maximum winter water table across some 63 acres with just six data points from around the perimeter. It's obviously not possible with any precision, however much their maps and contours would like to give the impression that it is. It’s one of the reasons why 1m is typically left unquarried above the maximum winter water table where private water supplies are at stake.

AI now says it has no intention of leaving this 1m unquarried at Straitgate. Perhaps it should ask itself, what would happen if there was an "unexpected rise in the water-table" here - and the void had been backfilled with just 1m of soil? What would happen to the integrity of private water supplies to 106 people, for example from animal faeces, nitrates or other pollutants? What would happen to restoration to any future farming use? What would happen to airport safeguarding?

What happened to dry-working at Thorn Trees and Venn Ottery? Unexpected rises in the water-table?


DCC refused farm-based AD facility in AONB

Aggregate Industries' plans for Straitgate Farm rely on securing continued permission for its Blackhill processing plant in the East Devon AONB. AI has failed to demonstrate the 'exceptional circumstances' required for such major development in an AONB.

On the issue of development in an AONB, a DCC officer reminded us of a recent planning application in the Tamar Valley AONB. DCC refused the application for the anaerobic digestion facility, saying:
1. The proposed development would have an unacceptable adverse impact on the Tamar Area of Outstanding Natural Beauty contrary to policy W12 and W18 of the adopted Devon Waste Plan. 2. There are no exceptional circumstances or need for the development which would override the reason for refusal set out in 1 above.
The inspector concluded that the proposal would have a less than significant impact and did not amount to major development, despite the importation of waste material, as it was small scale and utilised redundant land within the farm. Although it was in a sensitive location and the NPPF gave great weight to conserving landscape and natural beauty in designated areas, the AD facility would be screened on all sides and no higher than the surrounding bunds and buildings. Vehicles visiting the site would be of the type and size associated with farming activities.
Permission was subsequently granted.

We raise this because, notwithstanding the appeal, it would obviously seem illogical and inconsistent if DCC were ever to recommend approval for an isolated heavy industrial sand and gravel processing operation in an AONB, with hundreds of incoming and outgoing HGVs a day - after recommending refusal for a small scale farm-based AD facility that "would involve no more than 2 vehicles per day".

Lip service

noun... to say that you ​agree with something but do nothing to ​support it
Many would argue that climate change is the biggest threat that humanity faces.

Indeed, DCC states in its draft Minerals Plan that:
One of the biggest challenges facing Devon’s communities and environment, together with the wider world, is climate change driven by global warming. It is generally accepted that the main cause of global warming is human activity producing increasing concentrations of ‘greenhouse gases’, notably carbon dioxide in the atmosphere. As well as resulting in changing temperatures, climate change is also predicted to have a range of other consequences including increased frequency of extreme weather events, changing global patterns of weather and rising sea levels. 3.4.1
Devon's new Minerals Plan even pledges to do something about it:
Mitigation of and adaptation to climate change is a key consideration and statutory duty for the Devon Minerals Plan, and will be a cross-cutting theme for the Strategy. In particular, the spatial pattern of minerals development and the safeguarding of rail and water transport infrastructure will influence the distances that minerals are transported by road, while the management and restoration of mineral sites are capable of delivering positive measures for flood water management and habitat creation. 2.2.4
One of the first planning applications for a new quarry in Devon to be determined under this Plan - emerging or otherwise - is likely to be one of the most CO2 polluting: 1.2 million HGV miles just to transport the as-dug material for processing - before any onward sales distribution. It will be interesting to see what DCC and its new Minerals Plan will do about that? If the DMC meeting last month was any guide, then not very much.

What about the polluters themselves? Aggregate Industries’ parent, now LafargeHolcim after Holcim's takeover of Lafarge, says:
The 21st century will be defined by the challenge of climate change, in which the construction sector can play a key role. For LafargeHolcim, this global challenge requires a collaborative response that goes beyond our ambitious efforts in own [sic] operations. The Group is committed to reducing CO2 emissions across the entire construction value chain.
We have written about Aggregate Industries on climate change before, and how AI says:
We have long recognised the consequences of CO2 emissions and how both the manufacture of our products and their use in the built environment contribute to climate change... there is a real focus and drive to minimise the environmental impact of all we do.
Admirable words - ambitious efforts, real focus and drive - but what's the reality? For AI:
In 2013 our total process carbon emissions were 393,087 tonnes CO2e
In 2014 our total process emissions increased to 420,132 tonnes CO2e
Not to worry though, because the company has a plan:
By 2016 we will reduce process carbon emissions by 20% on 2013 levels in absolute terms.
The trouble is, AI said the same thing last year:
By 2016 we will reduce process carbon emissions by 20% on 2012 levels in absolute terms.
In fact, as far back as 2008:
Carbon remains a key focus for both us and society... We continue to work towards our 2012 target of 20% reduction per tonne of production from the 2008 verified baseline.
And how's AI doing? Look at the figures and judge for yourself:

AI would have you believe that:
For many years we have had our own CO2 reduction targets driven by a number of factors: Security of our energy supply, reducing the risk and exposure to unsustainable fossil fuels. Reducing the embodied CO2 impact of our products. Sites operating efficiently cost less to operate, and suffer fewer breakdowns. Legislation including Carbon Reduction Commitment Energy Efficiency Scheme (CRCEES), European Union Emissions Trading Scheme (EUETS)...
But look at the EU ETS civil penalties, and see how many times AI has failed to comply with legal requirements.

Does this look like a company that's serious about climate change? Or is it, as with the planning applications for Straitgate and Blackhill, that AI can't get its head around CO2 and that there's a huge mismatch between its words and the reality?

Miscellaneous

1. ‘93 days to pay its bills’ - Aggregate Industries in row with the Forum of Private Business:
The group claims that AI is in breach of EU directive 2011/7/EU. Check out the Forum's 'Hall of Shame'.

2. Is this the sort of thing that could happen to the private water supplies from Straitgate? Middle Musquodoboit man blames quarry for murky, smelly well water.

"When you're going close to the water table, there's always an issue with potential contamination"
4. Think a quarry could be good news for Ottery St Mary? Read this article, and think again. Campaigners celebrated a "significant victory" after controversial proposals to reopen Caldercruix’s Hillend Quarry were rejected:
"As far as I’m concerned this shows the dust and pollution coming from the quarry was harmful and I am pleased these plans have been rejected. It gives me peace of mind." Airdrie & Shotts MP Neil Gray said: "I welcome the unanimity of the decision, with all parties voting against an extension. To have done otherwise would have been to act against the interests of local people. It is important that the planning committee heeded the views of those who live in Caldercruix and the surrounding area." Alex Neil MSP added: "This was the right decision for local people. They had suffered enough from the fall-out from the quarry works. It is also good for the local environment, as it places a limit on the operation’s life. This will also help in persuading more people to live in Caldercruix."
5. Construction methods are changing. A report, published by Forrester Research in October, estimated that automation will eliminate 16 per cent of all jobs in construction and extraction by 2025.

6. Sources of minerals are also changing, particularly recycled minerals: 
Even our friends at AI recognise the potential:
7. Mark Twain's definition of a mine: "A hole in the ground with a liar at the top". He may have been thinking about gold mining, but you get the idea.

Monday, 1 February 2016

For major development where dormice are present…


Aggregate Industries already plans to rip out 2km of ancient hedgerows. No significant acceptable mitigation has yet been planted.

On the issue of habitat connectivity, look at the results of the dormouse survey below. AI’s new access plans are based at Little Straitgate. It obviously thinks it can rip out more hedgerows and chop down more mature trees to build a site access big enough to cope with up to 200 44-tonne HGVs a day. However, back in 2013, "survey results indicated two clusters of dormouse activity", one of which was:
A change of access arrangements would now put that cluster of a European Protected Species firmly inside the proposed site boundary.

Further hedgerows and habitat connectivity would also be lost to any internal haul road to this point.

AI will no doubt plough on regardless. The company is running out of options. However, the NPPF says:
When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused 118

AI’s applications slip again

Aggregate Industries wrote to DCC at the end of November with likely timescales for the supply of further information for the Straitgate Farm and Blackhill planning applications, saying that "the next [development management] committee date is 16th March 2016 and this should now be our aim".

It's now clear that AI will not meet that target. In fact, it’s unlikely that the matter will be determined anytime soon. Drainage trials scheduled for December were postponed until January, and are now expected sometime before the end of March. Plans for a new site access would necessitate a new site boundary, a new planning application, new designs, new reports and new surveys.

So, for all DCC’s bluster that this site is deliverable for the Minerals Plan, for all AI’s "years of careful planning", there's still much to prove before a Swiss cement conglomerate can tear apart an East Devon farm. With all the reports and expense, and the limited resource above the maximum winter water table with the 1m standoff, Straitgate must be a consultant’s dream, and a mineral company’s nightmare.

Cozy relationships

It might look to many - from the debacle last Wednesday - that Devon County Council’s Minerals Planning function is joined at the hip with a global cement conglomerate.

Aggregate Industries' planning applications have yet to be determined, but many of the numbers and arguments contained within them have already fallen down on scrutiny; some of these can be found in the draft Minerals Plan.

But it goes further. Take one look at DCC’s 4th Local Aggregates Assessment published late last year. Some of its conclusions are supported by references. When one of those references* - backing the flawed argument for both 'southern' and 'northern' sites because the "proportion and size of gravel decreases from south to north" 2.5.4 - is taken from AI’s own undetermined-catalogue-of-errors planning application for Straitgate, you know you're in trouble.

We’ve already dealt with the issue of Gravel at Hillhead, and the fact that this didn’t stop Hillhead Quarry operating for decades, the fact that this doesn’t stop Hanson working Town Farm Quarry near Burlescombe, the fact that this won't stop AI from applying to quarry Penslade if its application for Straitgate founders, and the fact that this hasn't stopped DCC from relying on Penslade to cover the sand and gravel shortfall indicated in its Minerals Plan.

Indeed, one of the planning applications DCC received last year was the "variation of existing permission at Blackhill Quarry to allow for importation of sand and gravel from Houndaller (Hillhead) Quarry for processing to end of 2016 (awaiting validation)" 2.5.7.

But some people in DCC gave up listening to anybody other than the quarrying industry years ago. Consultation with the public has been a charade. In reality, Devon’s new Minerals Plan has been shaped by the minerals industry, for the minerals industry. Silly of us for thinking it could be any other way.

*SLR Consulting Ltd (2015) Proposed Extraction of Sand & Gravel at Straitgate Farm, Devon and Retention of Quarry Processing Plant at Blackhill Quarry, Woodbury, Devon: Environmental Statement Volume 2. Sheffield: SLR.

In the news

The Press page is updated as and when the issue of Straitgate crops up in the local news; here's the latest article from the Sidmouth Herald: