PYFORD BROOK, APPLICATION PLANNING STATEMENT ADDENDUM – FURTHER INFORMATION ON NEED FOR THE PROPOSAL

The queries set out by County Council are in bold below, with the applicant’s answers underneath. The responses have been prepared by Cemex and Balfour Beatty Vinci, an approved contractor to HS2.

1. PROVISION OF SAND AND GRAVEL FOR CONCRETE MAKING (re Policy 1.4, 1.5 & 1.6 of the Minerals Local Plan)

1.1 Why can’t the mineral be sourced from existing sites, e.g. other sites in Trent Valley, Rugeley or Weeford (Moneymore)?

1.1.1 Existing sites in the area are supplying an existing market. The additional requirement for aggregate and concrete over and above that of the existing market for HS2 is significant. It is also crucial to the delivery of the project that sites are part of the dedicated supply chain for reasons of continuity of supply, capacity to supply the very large quantities required, and consistency of aggregate required for the concrete blends. HS2 also have a commitment to supply the project in the most sustainable way, so that means reducing vehicle movements to transport material as far as possible.

Overall aggregate requirements

1.1.2 The overall aggregate requirements are summarized as follows:

 The total aggregates required for Area North (N1 & N2) for the project are circa 14.5 million tonnes.  In excess of 10 million tonnes of unbound aggregates are required for non- concrete applications with supply routes via rail and rock quarries, covering 9 million tonnes of this requirement. This is coming from outside Staffordshire for a section within Staffordshire, thereby reducing the need for additional material being extracted in Staffordshire  The remaining 1 million tonnes of the above will be drainage aggregates, sourced from existing quarries within Staffordshire.  In addition to the 10 million tonnes of unbound aggregate, 4.5 million tonnes of aggregate is required for concrete production of around 2-2.3 million cubic metres, the volume of which may increase. Of this, 0.5 million tonnes will again be from crushed rock sources, supplied from outside the county by rail, where technically required for the concrete blends.  Sand and gravel is crucial for the concrete making, as if you used crushed rock, the rock would be different and you would lose the ability of demonstrably similar aggregate packages for plants to back each other up in the event of a problem. Consistency of the concrete blend is key to delivery, particularly for some of the larger structures that require a significant amount of concrete in one go.

1.1.3 As such, the majority of the aggregate for Area North is being imported from outside of the Staffordshire area. Staffordshire is therefore benefitting from a significant amount (9mt) of aggregate coming into the county from elsewhere which reduces pressure on its own supply. While there is some crushed rock available in Staffordshire, these quarries have no rail link and to reduce EMRs, this crushed rock was required to come into the County by rail, to save a considerable number of vehicle movements through Staffordshire. However, the overall supply solution relies on a multi sourced strategy including local sand and gravels, as well as these crushed rock sources. 1.1.4 The project has also made significant investment for the upgrade of rail connected sources. This includes upgrades to existing sidings at both quarry sources and local sidings, with a new aggregates by rail handling terminal being developed close to the project for a dedicated supply to Area North. The project has also invested in additional rail freight to provide the capacity to deliver these requirements. The use of rail connected supply and the use of other rock sources available has been maxed out, with no spare capacity to negate the need for local sand and gravel. 1.1.5 It should be noted that the above figures are for the earthworks package only. The track installation package contracts have not yet been awarded and will result in a significant quantity of aggregate being required over and above the figures set out above. Circa 200,000m3 of concrete is likely to be required for Area North alone. Certainty of supply 1.1.6 Certainty of supply to meet the programme is essential for delivery of the N1 and N2 project. This applies to the concrete supply itself, as well as the plant, equipment, experienced personnel and resources, and the constituent materials required. Protecting from potential market shortfall is an absolute necessity for N1 and N2, with development planned for other major schemes including the 2022 Birmingham Commonwealth Games, and Highways ’s Roads Investment Programme. Some suppliers have different priorities and are preferring to supply the current market requirements rather than the significant commitments required to supply HS2 Area North. 1.1.7 For concrete supply, major companies with the infrastructure, capability and ability to deliver the supply required for the projects were approached. Of the national supply chain, some companies have targeted other sections of HS2 as their priority, which suits their overall supply capability. BBV engaged with local suppliers for aggregate supply, with none able to supply the significant quantities to the programme, and the quality required for concrete production. 1.1.8 It is also crucial that a consistent source of concreting aggregate is supplied to ensure consistency in terms of concrete strength, quality and performance, given the large amounts required for single pours, and the need for plants to back each other up in the event of breakdown. While other sources may have a small amount of spare capacity, multiple sources with varying properties would be impractical to control and adversely affect the control and performance of the concrete. The need is for 1mt of a consistent source of concreting aggregate which is otherwise not currently available. Other sites in the Trent Valley 1.1.9 Both Tarmac and Aggregate Industries have also been awarded supply packages for HS2 Area North, which forms part of the aggregates required for concrete supply. We understand that applications to increase extraction at their current sites in the Trent Valley have also been submitted. This is also essential to allow them to allocate minerals to satisfy their existing market demands, and free up minerals to supply Area North. 1.1.10 Hanson were invited to tender for the concrete supply packages for N1 and N2. The HS2 project has very specific procurement rules governing invitations to tender and assessment of bids submitted to ensure fairness and transparency. Hanson were not successful in award of a supply contract and have in any case prioritised supply to other sections of HS2 Phase 1. Hanson’s offer to Area North did include using their sand and gravel at Weeford, which is currently mothballed. However, this was conditional on specific early commitments from Area North which were not possible at that time. Consequently, Hanson are now committed elsewhere on Phase 1 and the supply of aggregate only to Area North was not offered. This level of uncertainty and lack of commitment cannot form the basis of Area North’s supply strategy to deliver this project. For these reasons, Hanson’s sites do not form part of the supply chain for this project.

Summary of the position of other sites in Staffordshire

Quarry Operator Part of Comments supply chain

NEWBOLD AI Y Part of AI concrete supply offer and supply QUARRY of drainage aggregates

LEASOWES AI N Too far away from the route so supply from FARM here would not be sustainable.

BARTON HANSON N Not part of supply chain for Area North and no commitment given to supply HS2 Area North. Hanson have prioritized supply to other parts of Phase 1.

POTTAL POOL HANSON N Not part of supply chain for Area North and no commitment given to supply HS2 Area North. Hanson have prioritized supply to other parts of Phase 1.

MONEYMORE HANSON N Not part of supply chain and no (WEEFORD) commitment given to supply HS2 Area North. Site currently mothballed.

ALREWAS TARMAC Y Part of Tarmac concrete supply offer and supply of drainage aggregates

RUGELEY CEMEX N Rugeley is supplying an existing market and due to reasons regarding issues with the access to the site and current restrictions on the number of vehicle movements, would not be able to increase capacity to be able to supply the project. In addition, it is in a more sensitive location in the AONB and further from the route.

WEEFORD CEMEX N No mineral available

HINTS/ TARMAC Y Part of supply chain for drainage aggregates supply

CRANEBROOK WCL QUARRIES N Limited spare capacity based on existing market demands *

SHIRE OAK JPE HOLDINGS N Limited spare capacity based on existing market demands *

*BBV engaged with these sites early on in the process and they were not able to meet the requirements of the contract, due to limited spare capacity. It is crucial that the concrete is of the same quality, consistency, strength and in some cases colour to be able to meet the needs of the project. Therefore using various sources of small supply is not possible to meet the requirements in terms of consistency, capacity and volume of output required, and the certainty of supply to HS2 depends on the dedicated supply chain.

1.2 BBV have previously stated that: The quantity of concrete required for N2 is circa 1 million cubic metres. If the application site provides sufficient material to produce 500,000 cubic metres, where is the other material to be sourced? 1.2.1 Aggregate Industries and Tarmac will both also be supplying other parts of the N2 project within Area North – see table above. These plants are denoted as locations D1 (main plant) & D2 (precast plant for works at Kingsbury) operated by AI, and Plant E operated by Tarmac, backed up by Plant G, also operated by Tarmac.

1.3 Is there a supply strategy for the HS2 N2 section that can be made publicly available? Is there a report produced by Carter Jonas?

1.3.1 A copy of the supply strategy is attached. This is an internal schedule produced by BBV showing the locations of plants and their anticipated outputs, together with the suppliers’ solutions to deliver these. The locations of the plants correspond to those referenced on the map of concrete plants.

1.3.2 With regard to the new proposed plant at Weeford, this plant is also part of the overall supply chain with the volume of 500,000m3 split between the two depending on the location of where it is required along the route, ensuring that haulage distances are kept to a minimum, thereby reducing the EMRs. However, the vast majority of the amount is proposed to come from Alrewas as shown. Weeford is also essential as a back up to the Alrewas plant if it was out of action for any reason and to cover peak periods of demand.

1.3.3 The existing plant at Weeford does not have the correct technical specification or output to meet the demands of the contract, and serves an existing market, hence the need for the second, larger plant which is dedicated to HS2. It is crucial that the concrete produced by the plants is the same in terms of technical strength, quality and consistency because of the large volumes required for single structures, and in the event of a break down of a plant. It also needs to be able to produce the volumes required.

2 CONCRETE SUPPLY

2.1 The application states: “One location originally identified by HS2 near the A515 in south (Location A) is no longer available due to a number of reasons including flooding, access and buried services.” Please explain why these problems are not capable of mitigation.

2.1.1 The original plan was to locate a dedicated site plant at Location A. The plant was originally anticipated to supply approximately 161,000m3 of concrete. However the site is no longer available to accommodate a concrete batching plant. Land has been taken by HS2 including sites for offices and works compounds, to facilitate the numerous supporting activities and resources required to deliver the project. The assessment and processes for acquisition of land were undertaken prior to the appointment of the main works contractors, namely BBV for Area North. Unfortunately, the following issues were subsequently identified by BBV with mitigation that was not possible:

 Buried services, intersecting the site, restricting use of the site with diversions not feasible in this location  A significant proportion of the site is located within a flood zone, restricting use to only temporary facilities, which can be removed in the event of flooding.

2.2 The application states “Increasing capacity at a second site (Location B near the A38) was considered, however there is not space at the second location to locate a plant without compromising other key services that were to be located there”. What alternatives for location of a replacement concrete plant have been considered?

2.2.1 The original plan was to locate a dedicated site plant at Location B at Cappers Lane, near to the A38. This plant was originally anticipated to supply approximately 268,000m3. However, due to the impacts of losing site A, the compound at Cappers Lane has had to accommodate other activities, impacting on the ability to locate a concrete batching plant. 2.2.2 A search was made for alternative locations, however these compounds are required to be at the intersection of major routes, to avoid using small local roads. There are no other such locations available in the vicinity.

2.3 BBV have referred to issue of production capacity for concrete and security of supply. Can existing local plant be used to meet any shortfall? If not, why?

2.3.1 The outputs of existing plants are insufficient to meet the demands of Area North. An exercise was undertaken at the beginning of the process, where the wider supply chain was approached, and BBV requested details of available capacities for concrete supply. This looked at the output and locations of existing plants which established that there was very limited spare capacity. Most of the existing plants are urban plants of low production capacity, with small storage areas for constituent materials. 2.3.2 BBV have direct experience of the shortfall in the current market capacity, having completed the smart motorway improvement works on the M6 between Junctions 2 to 4 (Coleshill to Rugby) in 2020. Securing consistent supply for only 20,000m3 of concrete over a two-year period was an extremely difficult undertaking, with Area North’s requirements amounting to 100 times that amount. The spare capacity in this area is known to be negligible with small plants limited in output in the region of 30m3 an hour, serving an existing market. Area North’s needs are 80m3 per hour just for this project, at each of the dedicated plants, every day. 2.3.3 As an example of some of the single structures/elements of the program which require significant amounts of concrete in Area North: - 100,000m3 for the cutting retained solution - 23,000m3 for Harvey’s rough flyover - 37,000m3 for drainage improvement works - 28,000m3 for ground improvement works - 11,000m3 for Curborough Flyover 2.3.4 The concrete will be used for underground diaphragm walls, structures, bridges and so on, and a significant amount for the ground engineering and to carry the embankment. There will be vertical concrete walls lining each side of deep cuttings, with for example 100,000m3 for just one cutting as set out above. Consistency of blend for these is also essential, and certainty of delivery. If one plant breaks down and there is an emergency, they need to be able to back each other up. The commonality of technical source material and certainty of supply is key to risk mitigation for the project. 2.3.5 Area North’s strategy of dedicated concrete plants therefore is an essential programme driven requirement. Plants are proposed at strategic locations, utilizing both existing off-site locations and site compounds where they are available, particularly close to major routes. This strategy has also taken account of a best fit across the whole of Area North.

3 SUSTAINABLE SUPPLY OF CONCRETE

3.1 Why would the haulage of concrete from a quarry site be more sustainable than supply from an on-site plant or a nearby industrial site (in consideration of vehicles used to haul mineral and concrete)?

3.1.1 Extracting the aggregate and making the concrete on the same site, prevents vehicles having to take aggregate from one site to a concrete plant on a separate site, thereby saving a significant number of vehicle movements and reducing HS2’s Environmental Minimum Requirements (EMRs). 3.1.2 There will be no continuous route through HS2’s land take, and as such, even concrete produced within the land take would have to go back out on the public highway to reach the appropriate destination. A continuous route through the project will not be possible until structures spanning the specific restraints such as roads and railways that intersect the route are completed. 3.1.3 If an on-site plant was used, or a plant on an industrial site, this would require a two- way movement to take the sand and gravel from a quarry to the concrete plant, and then a further two-way movement to take the concrete from the plant to where it is needed along the route. This would essentially double the amount of journeys, and potentially result in longer journeys as well, depending on where the quarries and plants are located.

3.2 How would materials be hauled within the HS2 construction zone, e.g. from a concrete plant at Location B? Would concrete require re-hauling on the public highway?

3.2.1 Yes, concrete will require re-hauling on the public highway, until there is a continuous route constructed through the HS2 land take. A continuous route through the project will not be possible until structures spanning the specific restraints such as roads and railways that intersect the route are completed.

3.3 Given the agreed routes to supply HS2 via the A38, what are the advantages compared with other quarries? Please clarify how the proposal would reduce HS2’s EMRs.

3.3.1 Other quarries nearby are also involved in the supply of aggregate and/or concrete to HS2 and as such are not available in any case, as set out in the Table under Q1 above. This site is very close to the route and as such significantly reduces the distances that mineral will have to travel on the road to reach the HS2 route. The movements are further halved because of having the sand and gravel extraction and the concrete making on one site. This site is only a short distance from the A38. 3.3.2 The High Speed Rail (London-) Environmental Minimum Requirements General Principles document (Feb 2017) sets out more details about EMRs. It states that “the controls contained in the EMRs, along with powers contained in the High Speed Rail Act, and the Undertakings given by the Secretary of State, will ensure that impacts which have been assessed in the Environmental Statement for HS2 will not be exceeded unless certain circumstances apply. It states that any nominated undertaker will be contractually bound to comply with the controls set out in the EMRs and as may be developed during the passage of the Act through Parliament.” “The nominated undertaker will in any event, use reasonable endeavours to adopt mitigation measures that will further reduce any adverse environmental impacts caused by Phase One, insofar as these mitigation measures do not add unreasonable costs to the project or unreasonable delays to the construction programme”. 3.3.3 The EMR requirements contain maximum permitted numbers of HGV movements on average to a particular site location. Restricting the haul of aggregate to a particular location minimizes the impact of additional trucks on the local community, and with that in mind the purpose of Alrewas as a solution for larger volumes in the north, mitigates the impact of the number of vehicle movements specific to concrete delivery. Having the aggregate and concrete on one site saves the movements between the source of the aggregate and the concrete plant. 3.3.4 Minimising distances that the mineral travels on the road, and as such supplying the mineral in the most sustainable way, is therefore a significant part of reducing the adverse environmental impacts of the project overall.

3.4 The application states: “HS2 estimates that 40,000 vehicle movements would be saved by not having to transport 1mt of aggregate to Locations A or B, which equates to 100 to 150 vehicle movements per day, based on peak concrete supply of 20,000 tonnes per month”. How is 40,000 movements calculated? How should this figure be compared?

3.4.1 40,000 vehicle movements saved is based on the whole volume of concrete stated (500,000m3) and not moving the aggregates (1mt) to site plant locations originally planned. This is the overall saving of vehicle movements to the HS2 project, reducing impact on EMRs.

3.5 Representations have challenged the proposal in terms of carbon savings, and have suggested that using this site rather than Rugeley will emit nearly 500,000 kg of carbon into the atmosphere every year. Would there be any savings in carbon emissions?

3.5.1 The carbon figures quotes are not appropriate and there appears to be some confusion as to what is proposed at Alrewas. We note that some of the objections received refer to a cement plant being located at this location which is incorrect. A concrete batching plant is proposed, not a cement production plant. Carbon emissions of cement manufacture are well understood, but are not relevant to this site. 3.5.2 Carbon emissions for a concrete plant would be the same for the type of concrete plant proposed, whether located at this site or another site. The main source of carbon emissions is from transport, which is why the location of the site is crucial. Carbon savings for negating the need to transport aggregate to a separate site in the area (such as Location B, used in the attached example) and then from a concrete plant at Location B, which is further from where it is needed along the route, has been calculated as 726.66 tonnes (726,660kg). This also saves over 82 movements per day through the local area. Please see attached Carbon Savings spreadsheet for further details.

3.5.3 Rugeley is further from the route so moving mineral from there would add to the environmental footprint of the proposal. Rugeley is not suitable in any case for other reasons, as set out under Q1 above.

4 OUT OF HOURS WORKING

4.1 How would you anticipate control of haulage hours operating? I assume the S61 application would be made to the District Authority, but would you seek exemption to normal working hours at the quarry based on approved S61 applications, where they required supply from the quarry?

4.1.1 The application submitted by Cemex does not propose out of hours working as standard. Controls are specified as part of the HS2 project for out of hours working. It is proposed that any deviation to the HS2 project standard working hours are agreed with the Local Authority as part of the Section 61 process. 4.1.2 BBV have a dedicated community engagement plan, which sets out how they keep the local community updated. They also have a wider community investment plan, for example with volunteering opportunities or refurbishment of community halls etc. and this will extend to this parish area. 4.1.3 BBV inform all communities and stakeholders a minimum of 14 days before they do any works, they hold public events, they regularly brief MPs, local authorities and Members. They have a briefing with Staffordshire Members in early February, and they brief Parish Councils in the area. They will extend into Alrewas, so far this has reached as far as only. 4.1.4 A Section 61 application is very detailed in terms of what is to be done on site including, working hours, the number of vehicle movements, type of plant in detail, the noise levels of item of plant. This is to minimize disruption and noise. The activities are specific to the particular concrete pour. The use of lighting, vibrating equipment and anything else that is needed to work out of hours is also taken into account. This is then sent to the Local Authority Environment Team for consideration. These are done on a 12-month renewal basis. There are different levels of Section 61 approval. BBV will include the supply chain, so Cemex’s operation will also be covered, as well as any other sites involved in the supply chain. 4.1.5 It is anticipated that a condition restricting working hours to those set out in HS2’s Code of Construction practice could be imposed, however with the ability for 24-hour working for the concrete plant only as agreed through the Section 61 process. The condition could specify that Staffordshire County Council is notified in advance of these dates, prior to any 24-hour working commencing.

4.2 In this matter, are there alternative sites, e.g. Location B, that could fulfil night-time supply?

4.2.1 There are no alternative concrete supply sites that can provide concrete to this section of the project out of hours. While not routinely planned, it is essential that provision for out of hours supply for key activities is available. While other dedicated plants for Area North may also have out of hours supply capacity, it is not practical for concrete deliveries to travel long distances from other locations. These plants will also be subject to Section 61 control.

ADDITIONAL QUESTIONS

5 In relation to the supply that your Company has to meet (sub lot 8) would the Pyford Brook site also supply the proposed Weeford concrete plant?

Yes, as explained above there is no other capacity within the market place and sites must be part of the dedicated supply chain which has been put in place which is crucial to the delivery of the project. Supplying Weeford from Pyford Brook ensures consistency of material between the two plants and therefore consistency of the concrete output, and the ability for the plants to act as a back-up to one another in the event of failure. Given the short distance between the two plants it is the most sustainable way of supplying the plant. The application at Pyford Brook states that some surplus sand and gravel will be exported, which includes sand and gravel not suitable for concrete making, but also to give commercial flexibility. This is still estimated at around 10-15% of the aggregate as stated in the application.

It is noted that there is an application to extract sand and gravel at the Weeford site however this is a new proposal and was not put forward when the initial market assessment was undertaken, and as such the site does not form part of the supply chain. It is noted that the material proposed to be extracted from Weeford will be worked in conjunction with the deposits at Wildmoor Quarry, and blended with the Wildmoor deposit that produce sands of different grades to meet customer requirements. The two sites therefore work together to provide the required grades of sand. This will therefore produce a different type of product to serve an existing market.

6 Would material from Hopwas Quarry also be used to provide concreting materials for HS2 work?

This site is proposed to supply drainage aggregate only, not concreting aggregate.

7 Regarding the compound sites within the HS2 construction area (Sites A and B) does BBV have plans indicating up to date layouts for their use which would demonstrate the space constraints to carry out concrete making? Previously, I had not realised that there was now no provision for concrete production within the construction area and had assumed that from the ES that there would be opportunity for the haulage of materials along the construction route. In terms of illustrating where the major works are going to take place along the route within sub lot 8 that require concrete, would BBV be able to confirm the location of these works on a plan?

Please see attached plan showing the A515 compound. The plan shows the significant amount of buried and overhead services, as well as flood plain that would prohibit any concrete plant being situated on the site. The only area left available is that in the pink box which is too small for a concrete plant given the stockpiles and ancillary equipment that would also be required and is now taken up with offices, welfare units and car parking.

Please also see attached plan showing the Cappers Lane compound. This shows the uses proposed for the various areas and again there is no space here for a concrete plant.

We have included a list showing Asset Volumes which sets out all the elements which the concrete is proposed to be used for, and which plant will be used to supply the concrete for each element. The Pyford Brook plant is Plant B, and the Weeford Plant is Plant C. Plant C will supply those elements closer to that site. The route plans (rainbow maps) also include references to some of these assets and indicate the limited number of site entry and exit points along this section.