Leith Hill Action Group Newsletter 43
Stop the Leith Hill oil drilling!
Dear Supporters 

We wrote to you a few weeks ago in relation to a new planning application related to the original oil exploration application.  Many of you will have received a letter about this recently from Surrey County Council.  The new application essentially seeks to amend the planning application that the Planning Inspector approved following the Public Inquiry held last year.  It seeks permission for the erection of high security fencing all around the site and the addition of buildings at the entry to the site.  In all, the site area would be materially increased and it would now be visible from Coldharbour Lane.  Our newsletter let you know that we were awaiting a response from Surrey County Council before advising you on how best to respond to this application.  You can read that newsletter here

Details regarding the application can be found on the Mole Valley website.  Full details are in the “Documents” section of the linked page.  The Mole Valley reference is MO/2016/1563, although the Surrey County Council reference is SCC Ref 2016/0170.

I regret to tell you that SCC has still not responded to our request for further information.  However, time is running out for a response.  As such, we are asking you now to URGENTLY send your objections to the application to the council. 

Objections should be sent to Surrey County Council Planning Development Team; Planning & Development Group; County Hall; Kingston upon Thames; Surrey; KT1 2DY.

You can also email MWCD@surreycc.gov.uk

PLEASE DO THIS RIGHT AWAY!  The end date for the consultation is not as clear as it could be, but we are sure that responses by 28 October will be taken into consideration, so why not make sure you get in before that date?

Why We Believe The Way This Application Is Being Considered Is Wrong

This application is being considered by County Officers as not being what is known as “EIA development” (i.e. needing an Environmental Impact Assessment).  We believe this is fundamentally against national guidance.  The Planning Practice Guidance on EIA (“PPG”) states (paragraph 25) that:

 “An application should not be considered in isolation if, in reality, it is an integral part of a more substantial development… In such cases the need for EIA must be considered in the context of the whole development.”
 That suggests that a new Environmental Impact Assessment must be performed for the new development as a whole before this new application can be considered.  By not insisting on this, we believe the Council Officers are acting against this national guidance.
 In addition, the new application impacts the planning conditions insisted on by the Inspector following the Public Inquiry.  Despite this, the council officers are making decisions about applications to meet these planning conditions without taking the new application into account.  This is in contravention to the PPG, which states (paragraph 56):
 “If the likely effects of an application are not identified or identifiable at the time of the principal decision, an assessment must be undertaken at the subsequent stage.”
 Please Write to Object Now!
 We know that objections are treated most seriously when they have been individually written by you, based on which issues matter most to you personally.  As such, we never suggest a form letter that you might send.  However, when responding to the council, here are some things that might be important to you, which you might like to mention:
  1.  There is no need for this additional application.  The applicant seeks to justify it on the basis of a worsened “security environment” for onshore oil developments since the original application was submitted in 2008.  However, the EIA was entirely rewritten in the winter 2014/15.  Were any such changes not evident then?
  2.  The footprint of the development increases from 0.79 hectares to 1.01 hectares.  This is a 28% increase in the size of the development.  The original EIA is inadequate for such a change in development.  The Inspector may not have granted an application of such greatly increased size.   
  3.  The original application was at pains to point out that nothing would be visible from Coldharbour Lane.  That is no longer the case.  The original EIA is inadequate for such a change in development.  The Inspector may not have granted an application with such greatly increased visual impact to Coldharbour Lane.
  4.  The extension of the site now includes (in its southerly section) a steep downslope facing across the valley to Coldharbour Village.  More trees will now have to be felled for this.  The Inspector may not have granted an application with such a different impact on the EIA’s Viewpoint 1.
  5.  The extended site appears to cut off a customary right of way (along the western side of the development) established by more than 20 years of uncontested use.  The original EIA is inadequate for such a change in development.  The Inspector may not have granted an application that prevented public rights of way.
  6.  Changes to the lighting plan are required.  There is bound to be light present at the site entrance and at the southern extension.  The Inspector specifically stated in conditions that there should be no lights outside of 9am to 5pm.  The Inspector is therefore unlikely to have granted an application that required lighting outside of these hours.
  7.  How is the additional area to be surfaced?  If, for example, a 28% increase in quantities of stone is required, that could increase HGV movements by perhaps 150 or more.  The original EIA is inadequate for such a change in development.  The Inspector may not have granted an application with so many additional HGV movements.
  8.  As an application in its own right, it is industrialisation of green belt and AONB land with no purpose but security of private property.  As such, it is inappropriate development in the green belt with no very special circumstances and major development in the AONB with no public interest element to create exception circumstances.
 We know that letters of protest matter a lot, so please do write and let your views be heard.
 Patrick Nolan
 The Leith Hill Action Group