20 July 2017
Stop the Leith Hill oil drilling!
Hello to all our supporters.
We did not expect to have to be writing to you again so soon. Unfortunately, however, Surrey County Council have acted even more outrageously than indicated in Newsletter 51. This has forced us to urgently update you all.
We said in our last Newsletter that we expected a further round of consultation on a revised Traffic Management Scheme (TMS”), and that the matter would not go to Surrey County Council’s (“SCC”’s) Planning & Regulatory Committee before September. Well, SCC have different ideas: Consultees (like LHAG) and individuals who have already submitted written comment on the May version (but not the public in general) have been advised that the new document (Revision 9) is available on the SCC website.
SCC have told us that they intend to take the TMS at the P&R Committee on August 2nd. That means an unusually short 14-day consultation period ending on July 31st and the abandonment of any pretence that SCC’s officers will pay any attention to what consultees and the public say: they will make their recommendation (to approve, of course) in their report to the Committee a week before the Committee meeting – and 5 days before the end of the already short “consultation”.
SCC have sought to explain away this drastic shortening of the consultation period (it was 28 days for the previous version) by saying that it is the minimum allowed under their “Statement of Community Involvement” and the changes are only minor. In fact, the only material change in the new version is that there will now be no HGV movements on Saturday mornings during the drilling period. A good thing? Not entirely: it further concentrates those movements, meaning that, during the drilling period 4 HGV movements per hour will be necessary. 75% of these movements will be of vehicles between 40 and 51 feet long, and 50% of them will also be over 9 feet wide and over 14 feet high. These vehicles can only travel one at a time.
But the most outrageous thing about this attempt to smuggle things through is the fact that none of the concerns that we and other consultees have raised about what is missing from the TMS has been addressed.
The information in the TMS about the numbers of HGV movements is at best ambiguous and at worst misleading. We believe the true number is approximately 1,650. Hardly surprising, then, that in 8 years no attempt has been made to calculate average journey times for site traffic or for other traffic wanting to use Coldharbour Lane. In fact, no analysis or modelling of the proposed scheme has been carried out. The Inspector said, in effect, “I cannot see how this scheme can work; do it again”. Two years later we are presented with the same scheme. It won’t work. SCC must require Europa to pay for an independent and open modelling exercise to be carried out to assess the viability and impacts of the scheme. Without that, SCC has no basis on which to wave it through. Unless, and until, that independent analysis can demonstrate to the contrary, we believe that:
- Coldharbour Lane will be effectively closed to non-site traffic for the duration of the development;
- Whether it is formally closed or just subject to long and unpredictable delays, the knock-on consequences for traffic on the alternative routes between Coldharbour and Dorking will be chaoticchaotic – and expensive. (The ability of those alternative routes to cope with increased traffic has not been assessed either by Europa or Surrey Highways);
- Lives will be put at risk as emergency services either wait for massive site vehicles to negotiate the length of the Lane or meet other traffic on the narrower and longer alternative routes. (The TMS simply says that site traffic will be stopped from entering the Lane; not much good if they are already in the way up or down);
- People living on the Lane will be trapped in their homes. (The TMS calls on such residents to “co-operate” with one of the Traffic Controllers, who may be a mile or more away. Those controllers will communicate with each other by radio – because there is no mobile phone service on much of the Lane. So how do the residents communicate with them?);
- The bus service between Coldharbour and Dorking will cease;
- Cyclists and horse-riders will be at risk. (Europa’s assessment of the risk to equestrians is that it is zero, because equestrian users of Coldharbour Lane do not exist!)
None of these impacts have been addressed in this TMS.
We have not listed all of the issues here; and you may have your own concerns which we have not thought of. Please let Surrey County Council (and anyone and everyone else) know that you object to this matter coming before the Planning & Regulatory Committee until these issues have been addressed and the necessary assessments made. Unless, and until, this is done, the members of that Committee have no basis on which to make any decision but a refusal. However, our worry is that they will not refuse it, but instead just nod it through.
This could all be seen as everyday incompetence were it not for how horribly predictable it was, and the fact that we identified the problem of a lack of time well in advance. On 11 May 2016, there was a large meeting involving Surrey County Council planning officers, members of the Surrey County Council planning committee, Europa’s senior management and representatives from their planning team and LHAG. Minutes from that meeting are quoted below:
“... [LHAG] raised concerns that Europa’s proposed timetable is unrealistic and queried why submissions that are likely to take longest to agree and carry out (such as the Traffic Management Scheme, Ecology Management Plan) are being left to the end of the submission timetable. [LHAG] expressed doubt about sufficient time being given for the necessary parties to properly be consulted.”
Given how much warning we provided to both Europa and Surrey County Council about the importance of providing enough time for the consultation on the TMS, it is simply inexcusable that we are now in a position in which they are trying to rush it through without proper scrutiny.
Capel Parish Council, as a consultee, have echoed our concerns in a letter to the County Council, and have also criticised the way that the consultation on this latest version of the TMS is being rushed through. We call on Mole Valley District Council to do the same. Our County Councillor, Hazel Watson, continues to be active in her support for our aims and we ask others to also listen to the voices of their constituents.