Futures Forum: Quarrying in East Devon: can it be done 'sustainably'?

Aggregate Industries have put the case for quarrying at Straightgate:
Futures Forum: Quarrying in East Devon: Aggregate Industries' latest public consultation

They have produced a 'Sustainability Policy':
www.aggregate.com/documents/brochures/sustainability-policy.pdf
Sustainable construction | Sustainable environment

As part of their 'Carbon and energy' strategy, Aggregate Industries have made several commitments:

Our commitment and goals:

By 2016 we will reduce process carbon emissions by 20%
on 2012 levels in absolute terms.

In 2012 our total process carbon emissions were 236,800.24 tCO2e

In 2013 our total process emissions increased to 254,495.44 tCO2e as a result of increased production. A refocused energy programme is being implemented to mitigate this through energy efficiency and renewable energy projects.
Climate Change

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, and there is a real focus and drive to minimise the environmental impact of all we do.

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) and the forthcoming Energy Saving Opportunities Scheme (ESOS).
> Reducing cost of production of our products.

Carbon and energy | Sustainable construction

And they have quite a range of 'sustainable' or secondary products:

Life - our sustainable products range

We put sustainable practices at the heart of our business, now we are helping our customers do the same.

We have introduced Life to clearly identify our sustainable products and services, making it easier for specifiers to understand and use them. This is the first time a construction supplier has gathered together all its sustainable products and solutions under one simple and understandable brand.

Life doesn’t just set a precedent, it also sets a standard. Each of the solutions that carry the Life logo meet or exceed the three benchmarks that we have set in the key areas of carbon reduction, non-primary material content and water treatment or control within a SUDS solution. The sustainable contribution of each Life solution is clearly and simply quantified for our customers to reference.

Our unique Life range is powerful in its substance, offering sustainable solutions across a wide range of construction materials with solid, valuable and clearly identified sustainable benefits.

Sustainable products

The Straightgate Action Group sees things rather differently:

Alternatives

People will take one look at Aggregate Industries’ Straitgate Farm - B3180 - Woodbury Commonscheme and think is this really the best that the company can come up with - for itself, for Devon, or for the environment? Because, even from a dispassionate standpoint, it really doesn’t look like it.

AI, and its consultants SLR, will have to address why the company has chosen this way of doing things, and not any of the less environmentally damaging alternatives, in its Environmental Statement. As a minimum, AI will need to supply:

An outline of the main alternatives studied by the applicant or appellant and an indication of the main reasons for the choice made, taking into account the environmental effects.

Good practice will look for more, says the Institute of Environmental Management & Assessment.

How important is it that planning applicants - whether for an environmentally sensitive potential quarry site, for a B-road haulage route or for a processing plant in an area of European importance to nature - thoroughly investigate the alternatives? Sometimes it can be very important.

Take Anglian Water, for example, who failed to secure permission for a sludge transfer scheme; an inspector concluded that more suitable sites potentially existed which would reduce the impact:

Overall, there is insufficient convincing evidence to support the conclusions drawn in relation to alternative locations to clearly demonstrate that the proposed site is the most suitable, deliverable and available option for the [Liquid Sludge Import Centre]

Or take AI and its plans for a concrete plant opposite The O2 in London that were rejected because the planning inspector was critical of the apparent failure of the company to consider "alternative layouts and arrangements of structures" that would be less harmful to the surroundings.

This is what DCC has already said on the subject of alternatives in its scoping opinion:

The MPA would also strongly advise the applicant that the alternatives section of the ES should consider processing at sites other than Blackhill as the MPA has already advised AI that permission for processing of material from Straitgate at this location raises significant policy and environmental concerns.

The relative environmental impacts of known alternative means of providing the aggregate supply should be considered including processing materials at Rockbeare and sourcing material from existing consented supplies within the eastern Devon area as advised by the NPPF. It would be helpful if any assessment of alternatives could include a “do nothing” option as the applicant has already advised the MPA that without the Blackhill option the Phase 1 working is unlikely to be viable and so it is known that this option has been considered. The applicant is therefore advised to consider the main alternatives to mitigate the likely impacts of this proposal which in the opinion of the MPA would be: (a) Sourcing material from existing permitted reserves (b) Processing the materials in a less environmentally sensitive location. (c) Do nothing.

What alternatives are there? Well, apart from using the secondary aggregate littering the county, AI could fully work out and restore its existing local sites for a start. There are still 4 million tonnes of sand and gravel with permission at Houndaller near Hillhead Quarry. AI may claim ‘it’s too sandy’, but the deposit was good enough when the company intended to move Blackhill plant to it six years ago:

Uffculme Parish Council Minutes of the Meeting held on 2 October 2008:
Plant at Hillhead Quarry demolished, site closed except for storage. The current economic downturn has put movement of plant from Blackhill to Houndaller on hold

Hillhead Quarry itself still has 0.5 million tonnes. So that’s already 4.5 million tonnes, potentially 12 years worth, before even having to think about the 8 million tonnes at Penslade, a greenfield site identified by DCC in the 2012 consultation as N6/N8, to the east of Houndaller. None of these sites have the same hydrological and environmental constraints, on-site processing restrictions, or airport safeguarding issues that Straitgate has. All could deliver saleable sand and gravel to the M5 at Exeter with less total haulage-miles (using predominantly A-roads and motorway) than any Straitgate material.

So it will be interesting to see how AI argues that none of these alternatives would be more acceptable. And if AI doesn’t look properly at ALL the alternatives - for site, route and processing - local people, councillors and, if it gets to that, a planning inspector no doubt will, because hauling as-dug sand and gravel, whether 16.4 miles for Plan A or 28.8 miles for Plan B through Devon villages, to an isolated processing plant in the middle of of an AONB/SPA/SAC is patently absurd.

Straitgate Action Group: Alternatives

The campaign group also has something to say about climate change:

Surely the NPPF must have something to say on unsustainable proposals like AI's?

In the meantime, let's highlight two very salient parts of the NPPF that are relevant here:

Firstly, on the issue of Meeting the challenge of climate change, flooding and coastal change, the NPPF says: "Planning plays a key role in helping shape places to secure radical reductions in greenhouse gas emissions... This is central to the economic, social and environmental dimensions of sustainable development [93]. Local planning authorities should adopt proactive strategies to mitigate and adapt to climate change... in line with the objectives and provisions of the Climate Change Act 2008" [94].

In other words, planning must be in accordance with the Climate Change Act, whereby "it is the duty of the Secretary of State to ensure that the net UK carbon account for the year 2050 is at least 80% lower than the 1990 baseline", and that’s not going to happen by allowing proposals like AI’s.

The Committee on Climate Change was tasked by the Government to provide advice on How local authorities can reduce emissions and manage climate risk. One of the key messages is: "It is particularly important that local authorities use their plan making and development management control functions to... reduce transport emissions...".

Straitgate Action Group: Surely the NPPF must have something to say on unsustainable proposals like AI's?

How far??

Forty times around the Earth - that’s how far Aggregate Industries plans to transport the sand and gravel it digs out of Straitgate Farm - and that's just to process it.

When the world is shouting for polluters to reduce greenhouse gases, AI's track record on CO2reduction - or lack of it, and its latest million-mile proposal for Devon, suggests it carries on regardless; regardless of warnings from eminent scientists that "climate change is a moral issue on a par with slavery":

The situation we're creating for young people and future generations is that we're handing them a climate system which is potentially out of their control.

Are we surprised? After all, CEOs don’t take climate change seriously:

Only 6% of respondents listed reducing the risk of climate change as a priority, putting it at the bottom of the list… [but] unless we see a sea change in the global business community’s involvement in fighting climate change, corporations will continue to be seen as part of the problem rather than the solution – and consumers’ trust that companies will do the right thing will fade even further.

However, when it comes to planning applications, it’s not up to CEOs, it’s up to councils and councillors, working within the guidance of the NPPF. And on this point, the NPPF is clear:

To support the move to a low carbon future, local planning authorities should plan for new development in locations and ways which reduce greenhouse gas emissions

In locations and ways which reduce greenhouse gas emissions - a point we made in one of our earliest submissions. AI's proposal to process Straitgate material at Blackhill is not sustainable development. Every one of the 1.2 million tonnes at Straitgate would incur a 16 mile round trip - just to be processed into something saleable; curtailing the material’s viable supply radius, damaging roads, polluting the air we breathe with NOX and other diesel emission carcinogens, all because a multinational won’t expense processing in an appropriate location, a location that's not in the middle of a site of "national importance for its heathland, grasslands, mires and fens, breeding birds, and dragonflies and damselflies".

In Lancashire, Cuadrilla is going to have to fork out a few more million pounds, to address planning officer concerns over noise and the “severe” impact of 50 daily lorry movements for two of their fracking sites. At the end of the day, AI would also have to spend some money and move plant closer to the point of extraction - to a nearby industrial estate for example, not Woodbury Common - if it wants any chance of winning permission to quarry Straitgate Farm.

Straitgate Action Group: How far??

In the United States, the politics of mining is much more strident

The industry is making efforts to spread the word:

Mineral Usage Statistics | Minerals Education Coalition
Mining Videos - Modern
The disconnect on the importance of mining - YouTube

On the other hand:

WHERE HAVE ALL THE MOUNTAINS GONE?

In this week before I Love Mountains Day (an annual day of lobbying, rallying, and marching in Frankfort), it is more important than ever to be conscious of where our energy comes from and what we can do to protect our mountains and

our people from the atrocities of mountaintop removal mining. This practice of accessing coal from the mountains of the Appalachian region consists of literally blowing off the top of the mountain with explosives to get to the thin layer of coal underneath. The environmental effects of this practice are fairly apparent. Mountaintop removal mining has affected over 400,000 acres of land in Kentucky, Tennessee, Virginia, and West Virginia combined, including over 1,200 miles of streambeds. In the state of Kentucky alone, over 724 miles of streams have been destroyed and more than 150 square miles of mountains are now flat due to this process. Even though coal companies are technically required to restore the destroyed land area to its former quality through the process of reclamation, this process rarely repairs much damage at all—if any. Currently, reclamation practices simply convert these ancient forests into grasslands; the original level of biodiversity and life could not possibly be restored for thousands of years. In mining permit applications, coal companies are required to specifically describe what the land will be used for post-mining (e.g. recreational use, commercial use, agricultural use, etc.); however, many permits are approved without such details.

More time efficient than underground mining, mountaintop removal requires significantly fewer “miners” and is considerably cheaper for the coal companies carrying out such projects. While coal production

rose in the decade between 1987 and 1997 by more than 30%, the number of workers employed in mining occupations actually dropped by 29%. Hence, despite arguments from locals that protesters of this form of mining are taking jobs away from the region, mountaintop removal mining in itself takes jobs away from Appalachians, causing damage to the local economy. Furthermore, although it may make sense for a region rich in coal to reap the financial benefits of such richness, the fact of the matter is that all of such assets are given over to the coal companies, leaving the region containing the mineral-saturated land impoverished. For instance, in the state of West Virginia, the top fifteen coal-producing counties are some of the poorest in the entire nation—despite producing 15% of coal in the U.S. One only needs to take a quick glance at poverty rates in counties where mountaintop removal is prevalent to notice that something is not quite right. As of the year 2000, the majority of counties of Kentucky, Tennessee, Virginia, and West Virginia that contained mountaintop removal sites had poverty rates of over 20%; an entire fifth of these counties’ populations were living under the poverty line.

Where Have All the Mountains Gone? | HEAL
Apple's icloud is Blowing up Appalachian Mountains - Green Pages News 08.05.12 with Katie Patrick on Vimeo

In Australia the debate is perhaps even more strident: