Endorsements

"probably the most prolific anti frack website in the UK"
- Ken Wilkinson - prominent pro-fracking activist and industry supporter (Yes we know , he doesn't know what "prolific" means does he)

Private Eye

Defend Localism!

Take the advice of Greg Clark, ex-Secretary of State for the Department for Communities and Local Government

Greg Clark

"Those who are prepared to organise to be more effective and more efficient should be able to reap substantially the rewards of that boldness ...

Take power now. Don’t let yourself, any longer, be ruled by someone else"

How many wells?

PNRAG Wells
Click the image from more information on Cuadrilla's plans for PEDL 165

Fracking Employment

From the Financial Times 16 October 2013

AMEC forecast just 15,900 to 24,300 nationwide - direct & indirect

Jobs would typically be short term, at between four and nine years

Only 17% of jobs so far have gone to local people

Rubbish!

Looking for misinformation, scaremongering, lies or stupidity?

It's all on this website (but only on this one post ) featuring the Reverend Mike Roberts.

(Oops - there's more! )

Here though is our favourite Reverend Roberts quote of all time - published in the Lancashire Evening Post on 5th August 2015

"If you dare oppose fracking you will get nastiness and harassment whether on social media, or face-to-face"

Yes you!

"Unless someone like you cares a whole awful lot, nothing's going to get better. It's not." - Dr Seuss

We are not for sale!

England is not for sale!

Wrongmove

Join the ever growing number of households who have signed up to the Wrongmove campaign!

Tell Cuadrilla and the Government that your house is "Not for Shale"

Wrongmove

Be a flea

"Many fleas make big dog move"
Japanese Proverb quoted by Jessica Ernst

No to Fracking

Love Lytham Say No to Fracking

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The Precautionary Principle

When an activity or occurrence raises threats of serious or irreversible harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.

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Please Police Me!

POLICING COSTS FOR PRESTON NEW ROAD MAY ALREADY HAVE TOPPED £10 MILLION

MUTUAL AID COSTS ARE ESTIMATED AT OVER £1 MILLION

FRACKING IN PRODUCTION COULD EAT UP HALF OF LANCASHIRE CONSTABULARY’S BUDGET FOR 20 YEARS

For some time now those supporting fracking have tried to turn the narrative away from the issues surrounding fracking and to present this battle as protesters versus police. Really nothing could be further from the truth.

As anyone who has been down to Preston New Road will know the vast majority of those they meet are decent, hard working or retired people, who continue to pay the council tax to enable the provision of policing services in the county. Some of us, however have become concerned about issues which have surfaced with the policing of the protest.

The most obvious one is the over-policing which has been evident throughout and this has some serious implications for the people of Lancashire as we continue to be asked to pay for an unsustainable policing operation which is, in effect, providing a free service for Cuadrilla.

Lancashire Police’s own public statements suggest that the cost of the policing operation, whilst being a considerable drain on the county’s finances, is still in manageable territory – just.


The cumulative total of £2.2 million is described as “Costs attributed to the policing operation for fracking“, but it is only on closer examination that we notice that it also states “The table below shows the additional costs related to policing the fracking operation. This includes overtime, unsocial hours payments, equipment, subsistence etc. These costs do not include the cost of those officers that are assigned to policing the site on a day-to-day basis.” [Our emphasis].

So what has the real cost of policing this operation been? To work this out we need to look at the cost to Lancashire Constabulary for the provision of Mutual Aid from other forces, which began on 10th July and will finish on 29th September, and also look at at the Full Economic Costs for Lancashire’s own policing operation . Fortunately information on these costs is readily available

Mutual Aid Data

Full Economic Costing

The information is for different years and from specific forces but it is recent enough and generally applicable enough to allow us to make a reasonable stab at the total costs incurred.

Cost of Mutual Aid Policing

Mutual aid policing is provided in PSUs – Police Support Units which comprise

  • 1 Inspector
  • 3 Sergeants
  • 18 Constables
  • 3 Constable Drivers

Throughout the Mutual Aid period it has been normal to see at least 6 vans from other forces at any one time so for this exercise we are going to assume that 2 PSU units (50 officers) have been deployed on average throughout the Mutual Aid period. This would be half of the daily presence of 100 officers reported in several reputable media outlets.

[The Times reported in April  “More than 100 officers a day are being sent to Cuadrilla’s site on Preston New Road near Blackpool to ensure that lorries delivering materials can pass protesters.” and in May the Blackpool Gazette reported  “The officer in charge of policing anti-fracking protests in Fylde has defended the number of police deployed. Lancashire Police has up to 100 officers deployed at the drilling site in Preston New Road every day, prompting criticism from some quarters of the resources being given over to the operation. Supt Richard Robertshaw admits the numbers required are a drain on resources.“]

When  paying for mutual aid the amount paid by Lancashire Constabulary is not the Full Economic Cost of each officer – instead they pay only for the basic pay, unsociable hours, other allowances and national insurance. The force providing Mutual Aid has to swallow up the rest (or rather their council tax payers and the national tax payers do, which is another reason why it is legitimate to regard this as not just a local but a national issue).

Taking the employable cost hourly rates for each grade and applying these to the number of days worked we can calculate that the daily cost of a single PSU unit would be £7,031, so 2 PSU units (50 officers) would cost just over £14,000 a day.

Over the 81 days of the Mutual Aid period this might have cost Lancashire Police £1,139,077 assuming our assumptions about the number of officers deployed and the police’s own data are correct.

Cost of Lancashire Constabulary’s Policing

When looking at the cost of Lancashire’s own officers we need to use a Full Economic Costing which takes into account not only the salaries and overheads uses in the calculation of Mutual Aid rates but also elements, which are not included in the Mutual Aid cost calculations like:

  • Competence
  • Bonus Payment
  • Subsistence
  • Rent / Housing Allowances
  • Healthcare Scheme

along with direct overheads in the form of

  • Overtime Premium
  • Uniforms
  • Insurance
  • Transport
  • Training
  • Call Handling
  • Communications
  • Infrastructure

and also indirect overheads allocated from the provision of other central services.

The impact of including these is to bring the cost of a Police Constable from a nominal £32.78 an hour under Mutual Aid to a more realistic £59.64 an hour under a Full Economic Cost model.

This means that by the end of this week (Friday 29th September 2017), on the reasonable assumption that 100 officers have been deployed each day, apart from during Mutual Aid when it would have been 50,  the cost to Lancashire Constabulary for their own officers since January 6th will have been be somewhere in the region of £10 million.

This would suggest that the total cumulative costs so far of facilitating Cuadrilla’s operation to Lancashire Constabulary are in the order of £11.2 million.

This compares with a total 2017/18 budget requirement for Lancashire Constabulary of £261,647,000 or about 4% of the annual total after just 9 months. This would suggest over 5% after a year.

If you would like to look at the data behind our calculations it can be found in this spreadsheet

And now we need to take a step back and remember – this is just one pad. If this industry ever takes root here we can expect at least 100 pads to be developed. At any one time we can probably expect 10 pads to be being developed, and as we have seen when this industry invades places where there is a strong community, like in a village, resistance increases, so it would be unreasonable for the police to expect not to have to deal with a similar level of protest at each and every site that is developed here in Lancashire.

So, my questions to Chief Inspector Keith Ogle and Police Commissioner Clive Grunshaw are as follows:

  • Are the Police ready to spend something in the region of 50% of their current budget over the next 20 years on facilitating Cuadrilla’s operations?
  • Do the Police feel that they can adequately perform the rest of their necessary functions in our society whilst so many resources are being directed towards policing Cuadrilla’s fracking operations?
  • What plans have the Police put in place to get finance from central Government for this massive drain on their resources which might allow them continue to perform the job that we all need them to do?

These are questions that our senior police officers really have to be asking themselves. Given the costs that would seem to have been incurred already we need the answers to them sooner rather than later.

The answer my friend …

New research by You Gov commissioned by climate change group 10:10 shows that on shore wind is vastly more popular than either of the government’s two pet projects (Small modular nuclear reactors or fracking)

Support for fracking is particularly low.

A very clear majority (61%) really don’t want a fracking site within 5 miles of their home while just 21% would be happy to have one.

 
Compare that to onshore wind, which the government keeps telling us nobody wants and which we must apparently feel free to oppose on a local level and the situation is reversed – 65% happy and 24% unhappy. If it’s community owned then it’s 69% happy and just 17% unhappy.

It is time that the government dropped it’s absurd opposition to renewable energy sources and bowed to the inevitable – who know it might even help their electoral prospects, and that’s something they seem to need all the help they can get with just now.

You can read more about the polling and access the data underlying it using this link.

And in the naked light I saw …

A week or so ago I met local music teacher Andy Severyn for a beer and out of the blue came an idea for a song about fracking.

A couple of days later Andy and I (but mostly Andy) had put together some great replacement lyrics for Don McLean’s haunting song “Starry Starry Night” and we put them together with some of the images that have most affected us over the last few months.

The result seemed quite good so we published it on Facebook and we’ve been overwhelmed by the response. In a few days it has been viewed by 10,000 people – maybe more. It has also been shared 450 times at the time of writing.

We’ve now added it to Vimeo for easier sharing.

Sorry Sorry Site from No Fracking on Vimeo.

10,000 people maybe more – hmm – that give us an idea for a follow up. Stay tuned!

In the meantime here is the image we’ve used as the main picture for the video – complete with fracking well

Minitrue

In George Orwell’s 1984, the main protagonist, Winston Smith, works at the Ministry of Truth, or “Minitrue”, as an editor.

He is responsible for historical revisionism; he rewrites records and alters photographs to conform to the state’s ever-changing version of history itself.

In 2017 he might have got a job editing the new Backing Fracking website.

If he did we could probably expect output like this:

Terms like “fracture growth” and “fracture propagation” are used to describe the extent of the network of cracks that are created. The maximum vertical reach has been calculated as 350 metres from a horizontal well, but it’s important to understand that these cracks are random, won’t all form in a vertical plane, and are very narrow indeed – they are certainly not going to be “fissures.”

Fracking for shale gas in the UK will take place at very significant depths – typically more than 2,000 metres. Groundwater aquifers are encountered at about 180 metres below the surface and so you can see that even if fractures can “grow” upwards 350 metres, there will be 1,650 metres of separation between the two (that’s 5 times the height of the Shard in London, Britain’s tallest building) and virtually no chance of any connectivity occurring.

Like all good lies this content contains some truth, but it is subtly bent out of shape. This when we read “The maximum vertical reach has been calculated as 350 metres from a horizontal well” we should not take that as fact. In reality a study by the ReFine group at the University of Durham actually concluded that:

“Mathematical analysis of the datasets indicates that the likelihood of a natural hydraulic fracture extending vertically more than 350 metres is about 33 per cent. For hydraulic fractures stimulated by shale gas fracking, the likelihood of them extending more than 350 m is less than 1 per cent.”

That is not the same thing as a calculated maximum at all. Given the many thousand fracturing stages which will take place just within Cuadrilla’s licence area we can expect several hundred to exceed this height.

They are correct that Cuadrilla’s fracture plan suggests that fracking will take place at depths greater than 2,000 metres, but whoever put this together obviously doesn’t know much about the local geology. The suggestion that “Groundwater aquifers are encountered at about 180 metres below the surface and so you can see that even if fractures can “grow” upwards 350 metres, there will be 1,650 metres of separation between the two” seems to be based on the assumption that the Sherwood aquifer has no depth of its own, even if you ignore the obvious issue with forgetting about their initial 180 metres, as they do there.

In fact as the BGS tell us:

The shallow aquifer is up to 40 m thick and is designated by the Environment Agency as a Secondary B aquifer. It is used for private drinking water supply, farms and golf course irrigation. In the area of the proposed shale–gas sites, this aquifer is underlain by a thick layer (up to 350 m) of a low–permeability mudstone, the Mercia Mudstone. Water moves slowly through this mudstone and it is not classed as an aquifer. Below this is the Sherwood Sandstone, which reaches a thickness of up to 750 m. The Sherwood Sandstone is classed by the Environment Agency as a Principal aquifer.”

So in fact the Sherwood Aquifer is not 180 metres below the surface but about 400 metres below it. The sandstone making up the Sherwood  Aquifer is up to 750 metres thick, giving a depth of its lowest level at about 1150 metres not the 180 metres being suggested by our astro-turfing pals in their story above.

Assuming a fracture height of 350 metres that would, of course, still give a tolerance of 500 metres for fracking at 2000 metres. If the 350 metres quoted really were a maximum rather than just a probability this would be fine wouldn’t it? However, as the Refine paper tells us:

The maximum reported height of an upward propagating hydraulic fracture from several thousand fracturing operations in the Marcellus, Barnett, Woodford, Eagle Ford and Niobrara shale (USA) is ∼588 m

How much can we depend on this data?

Well Refine also state that:

Mathematical methods for estimating hydraulic fracturing height are simplistic (Fisher and Warpinski, 2011) and it is generally accepted that we cannot yet accurately predict fracture propagation behaviour in detail

So things wouldn’t seem to be quite so clear cut as our Backing Fracking chums would like to make out, as in fact the separation distance between the end of a fracture and the aquifer at Preston New Road might be nearer 250 metres than the 1650 metres claimed by them, and nobody is really sure if the 588 metres really is the maximum fracture height we should expect.

250 metres clearance for a fracture at 2000 metres, with an observed maximum fracture height (so far) of 588 metres, might still be a reasonable margin of course (if those mathematical prediction methods do turn out to be more reliable than ReFine suggest) , but this is rather less than 1 times the height of the Shard in London and about 7 times less than Backing Fracking’s “reassuring” maths is trying to tell us. Oops!

This begs the question why Backing Fracking are being so misleading. Is it incompetence or is it a wilful intention to exaggerate and misinform?

[And according to their own page , shouldn’t they be called “Backing Frac’ing” as they tell us the word “fracking” is “really known in the industry” as “frac’ing”. 😂]

PS – do we detect a little irascibility with Aunty in their closing “Fracking certainly isn’t the controversial technique that the BBC and others would like you to think it is.”?  And we still think it is by the way.

PPS – it seems they follow everything we write here as shortly after I published this they put this sniffy Tweet on Twitter

(The inset is my reply LOL – 2 years ago they hadn’t banned me but when I didn’t post for a while they were telling each other they had. Then I argued a point with them and got banned properly. Oddly my life was not much diminished.)

Uncomfortably Number

As we reported in our last post the Backing Fracking astroturf group’s new website isn’t exactly a reliable source of information.

Today we read their latest blog post in which they state:

You have to commend the PR boys for that “per fracking stage” don’t you. How about when you add up the 45 stages?

And “apparently” boys? Er no – it really has. It’s in Cuadrilla’s own Hydraulic Fracture Plan which they submitted to the Oil & Gas Authority and Environment Agency for review in July 2017. Didn’t you know?


The comparison shown with Elswick confirms what we have said all along – it used just 163m3 of water compared to the 34,000 m3 that this test well will use.

But in their FAQ it clearly stated “Even the longest horizontal wells are unlikely to use more than 27,000 cubic metres each

See it’s here:


Now for your mental gymnastics this morning I want you to multiply 45 x 763 and express the result as a percentage of 27,000.

That’ll be 34,000 and 127% then.

Yes indeed, boys and girls, just a week after launching the site, and by their own admission their FAQ information underestimates the reality by 27%. (And of course underestimates their water per person comparison by a factor of 1000 as we saw before.)

I’d say that was either totally incompetent or intentionally misleading, but they have been very careful to state “Backing Fracking is a residents collective, and operates as an unincorporated association to campaign in support of shale gas extraction in the UK” in the footer of each page.

By operating at arms length like this the industry PR team clearly believes it can say what it likes and avoid any censure from the Advertising Standards Authority. Clever isn’t it, but about as underhand as we have come to expect from this industry?

If you want a good laugh take a look at their FAQs and in particular this one


When you’ve stopped laughing have a read of our various exposés of their fakery – starting here.

“Nation shall speak rubbish unto nation”

Well it finally happened!

Industry astroturfers Backing Fracking have at long last created their own website, 2 years after collecting over £1100 for the purpose. On each page of the site they repeat the claim that “Backing Fracking is a residents collective

We imagine that Backing Fracking must subconsciously referring to the halcyon days of the Soviet workers’ collectives and Stalin’s first 5 year plan.


Sadly collectivisation created a large-scale famine in the Soviet Union in which many millions died and civil resistance was common. We confidently expect fracking in Lancashire to be equally well received by the local proletariat.

We do of course know more than a little about exactly who these “residents” really are. See our previous investigation here.

But come on guys! Did you really expect people to be so naive as to believe that a few anonymous local residents would get together and pay a large monthly subscription to Nationbuilder – the  social campaign management web site, which has been described as “the mercenary software that powered Trump and Brexit”.

I mean that’s not the sort of thing that we might expect from an astroturfing group at all is it? 😂

[The use of Nationbuilder by major political campaigns, and questions about it’s role as a data controller are discussed here]

I wonder how much it would cost Backing Fracking if just a few people from each of the hundreds of anti-fracking groups in the UK signed up to their subscription based model. It could get very messy for them indeed!

So what is the content like? Well it’s the usual mix of straw men, half truths and misdirections that we have come to expect from the industry’s most vocal and rabid mouthpiece, although they do seem to be making an effort to sanitise their image away from the ugly macho posturing which characterises their Facebook feed these days.

However, it seems that their attention to detail gets lost in their frantic need to persuade. Take this as an example.


Now, even they admit on the same website that :

180 people using 150 litres a day would use just 27,000 litres. It would take 180 THOUSAND people to use 27,000 cubic metres in a day.

Who knows, perhaps the same person was hired to put the content together as did the site at “Lancashire For Shale” who announced that there were only 2281 cubic feet of gas in “the area”.

Given that we use about 3,000,000,000,000 cubic feet of gas a year in the UK that would keep us going for at least 0.2 seconds.

For what this massive PR exercise must be costing them you’d really think they’d pay a bit more attention to detail wouldn’t you?

Proud of Froud

We are so impressed by Trina Froud’s letter in this week’s Lytham St Annes Express that we thought we’d reproduce it in full here. She speaks for many of us who are frustrated by the portrayal of events by Lancashire Police and their failure to deal with Cuadrilla’s security team in a professional manner. Here it is :


Dear Sir,

Dismayed by the recent Natural Environmental Research Council (NERC) announcement (of £8 million to begin research into the environmental effects of fracking), and disturbed by the reports of policing at the Preston New Road site, this particular ‘guinea pig’ decided to visit Cuadrilla’s site to see it first-hand.

While there, a lock-on occurred, it was over very quickly and was ‘successful’ despite the attempts to prevent it by Cuadrilla security guards and police. The police wear yellow hi-viz jackets and the private security wear orange, so both stood out in the activity.

It was clear to me that the security guards were assaulting the protesters, while the police that I saw, were on the outside edge of the group doing little.

I subsequently spoke to a police officer to suggest that the police should have been controlling and removing the aggressive security men, in order to calm the situation, rather than moving away some of the observers.

His argument was that it was the duty of the security to come to the aid/defence of the police, that security are trained in handling such situations, and it is different in the centre of the melee … oh and that he would ‘Never say Never’ when I doubted that he would thump someone.

Having now watched filming from within the centre of that group, my opinion has not changed; the security men were at the heart of the action and were assaulting the protesters. I do not accept that men employed to guard a site should be out on the public highway at all, let alone assaulting the general public.

The police were not under threat, and reinforcements arrived quickly, I counted 50 men on the ground and 16 marked vehicles soon afterwards. I was dismayed by the security guards, the lack of effective police action, and the subsequent refusal of the police officer to acknowledge my concern.

However as I write this, on 31st July, I see that the police are present in great strength, vastly outnumbering the protesters. I am certain that police are trained to far higher standards than security guards, and yet today they themselves are behaving aggressively in an unrestrained fashion. It is no wonder that friends, who have lived here all their lives, and always respected the police, feel shocked and betrayed.

The consequences of Cuadrilla’s operation will outlast the obvious ones of traffic and noise – trust in the independence of the police, once lost, is not going to be regained.

Yours,

T Froud
Lytham


 

DECC Wave 22 shows support for Fracking crashing to a new low

Today the government belatedly posted the results of its BEIS wave research. This is a series of polls which has been asking questions about energy on a quarterly basis since March 2012 and about shale gas specifically since Wave 8 in December 2013.

Today’s results show support for fracking crashing to a new low of 16% (split as support 14% and strongly support down to 2% – both record lows) whilst opposition is growing and is now up to a record high of 33% (split as strongly oppose 13% and oppose 20%).

Support for fracking has declined by almost 25% over the last 12 months (21% down to 16%).

The % of people neither supporting nor opposing remained fairly constant at 49%. This figure has hovered around 50% since the polling began.

The trend is evident as opposition can be seen to be bearing down on support and crushing it – this industry continues to lose support day by day in spite of efforts to alternately buy local support and to beat local opposition to the floor using the sledgehammer of legal injunctions.

It is clear that their attempts to demonise protest are backfiring and that this industry has about as much chance of getting a social licence as I have of winning the lottery (spoiler alert: I never buy tickets).

Interestingly many those that expressed an opinion in favour of fracking cited jobs, lower bills and using less fossil fuels as reasons. These arguments are pushed by the fracking PR machine but are almost totally without substance, so as people are made aware of the truth we should see a further decline in support as the scales fall from people’s eyes.

By far the largest (and growing) reason for support was “Loss/destruction of natural environment” – up from 55% last year to 68% this year, so we can expect a PR push from Cuadrilla telling us how green fracking is and how it won’t industrialise the country side (second spoiler alert: It isn’t and it will)

 

 

More Fools’ Gold

So following on from yesterday’s post we have further evidence of how our “gold standard regulation” works.

Yesterday morning the A583 was closed at about 7:15 to allow a convoy of trucks to enter the site.

The trucks passed protesters at the entrance to the site at 7:27.

This was reported as a breach to Andrew Mullaney, Head of Planning at Lancashire County Council, because (as those who read yesterday’s post about the “gold standard” but ever-changing traffic management plan  will know) Cuadrilla are not allowed to bring HGVs onto site before 07:30.

2.3 Operational Hours
HGVs will only be permitted to enter or leave the Site between specified hours as set out in condition 19 of the planning permission granted on 6 October 2016.These hours are summarised as follows:

Delivery or removal of materials, and works associated with the delivery and removal of plant and equipment – 07:30-18:30 Monday to Friday (except public holidays), 08:30-12:00 on Saturdays (except public holidays);and

Essential repairs to plant equipment used on site may require HGV movements outside of these hours.

The co-ordinated planning of the arrival of vehicles as set out in Section 3.6 will ensure that vehicles do not arrive at the site outside of the permitted hours.

Now, you may be puzzled as to why I am allowing myself to get exercised about a 3 minute breach here. Well, it is not the extent or the impact of the breach which is important here. It is the reaction of the Head of Planning at Lancashire County Council.

Yesterday, according to those present,  Mr Mullaney was made aware of the breach and supporting evidence was provided in the form of a live stream on Facebook which show a timestamp for the beginning of the stream as 07:22. At 4 minutes and 28 seconds into the stream we see the first lorry pass, so it is evident that the latest this could be is 07:27.

So, let’s just walk through this. Mr Mullaney is made aware of a breach. Mr Mullaney is provided with what at first sight, at least, looks like clear evidence of a minor breach. Mr Mullaney is provided with a site log by Cuadrilla which appears to record something at odds with the evidence provided – i.e. that they hid the fact that the trucks entered the site a few minutes early in their log.  That is the issue, and not the actual extent of the breach.

In our world of of gold standard regulation Mr Mullaney’s first reaction is now of course to wonder if Cuadrilla being allowed to mark their own homework is such a good idea. Mr Mullaney is now rightly concerned that this could be evidence that Cuadrilla are potentially falsifying records, albeit in a relatively minor way in this instance. Mr Mullaney is an intelligent man and realises that this could be proved or disproved with a quick call to his contact at Lancashire Police to get a time stamp from one of the officers’ bodycam recordings. Mr Mullaney calls his friends in the police, finds that their evidence supports that of the livestreamer and calls Cuadrilla in for a stiff talking to about the accuracy of their records.

Sorry. That’s not what happened at all.

Here is Mr Mullaney’s reaction?

Given the fact that Lancashire County Council are conspicuous by their absence on the site (unless you count their ridiculous temporary camps on the grass verge of course), you might think Mr Mullaney would be glad that citizens are actually monitoring the breaches of the regulations he is supposed to be enforcing, but it would seem that he has a similarly glib and blinkered attitude towards breaches at the leader of his council.

Yesterday local businessman Mark Mills delivered a petition signed by 4400 people to LCC. The response he got from Geoff Driver was so dismissive that you have to wonder if maybe Mr Diver’s attention could be on other more pressing matters?

Hi Mr Mills
Thank you for your e-mail. The Council is aware of the breach of the Condition and has written to Cuadrilla. Any action the Council takes must be proportionate to the breach so you can be assured we will not be ordering Cuadrilla to remove the equipment.
Regards
Geoff Driver

Mr Mills was as unimpressed as you might expect

Mr Driver

That is not proportionate.

For example, if I built a house without regard to the planning conditions, the Council could (would) order me to take it down. Therefore, the removal of equipment brought onto site outside of the planning conditions imposed is proportionate and required by 4,000 local people who have taken the time and trouble to support your enforcement of those conditions.

Cuadrilla was given very specific conditionality in its permission to operate and as a local resident, I rely upon you, the Council, to enforce their obligations and for peaceful enjoyment of my home. Their movement of vehicles out of hours and accessing the site from the Kirkham M55 exit is against two conditions. As Cuadrilla are already in breach, having never operated a wheel wash, which has caused dirt from the site to be carried to the road, I would request you detail to me by return when your enforcement officers have been to site, given the number of complaints you have received from me and others.

For you information, I am dissatisfied with your glib and short response to over 4,000 local people’s desire to see Lancashire County Council enforce its planning conditions and am similarly worried that your lack of action will embolden Cuadrilla to deliberately breach further conditions with regards to safety, for example.

Kind regards

Mark

Meanwhile the paint continues to peel off the gold veneer exposing the dud currency beneath it.

Fools’ Gold

We, the residents of the Fylde, have been assured by our MP, Mark Menzies, that the most stringent regulations would have to be in place if shale gas exploration were to go ahead. He has referred continually to the need for “gold standard” regulations.

We are now, if Cuadrilla are to be believed, just weeks away from the first drill bit tearing into the ground at Preston New Road, but the last week has seen this illusion of gold standard regulation exposed as the toothless sham we all knew it to be as planning conditions are routinely amended to suit the applicant by the council or breached with the collusion of Lancashire Constabulary.

Let’s take a brief look at how we got to be in a position where a nightclub doorman in an orange jacket can cock a snook at our planning system and a government minister.

First of all let’s look at what planning conditions are actually for. Here is what the Department for Communities and Local Government said back in 2014.

Why are conditions imposed on a planning permission?

When used properly, conditions can enhance the quality of development and enable development proposals to proceed where it would otherwise have been necessary to refuse planning permission, by mitigating the adverse effects of the development. The objectives of planning are best served when the power to attach conditions to a planning permission is exercised in a way that is clearly seen to be fair, reasonable and practicable. It is important to ensure that conditions are tailored to tackle specific problems, rather than standardised or used to impose broad unnecessary controls.

It would seem to be reasonable to assume therefore that a six week long inquiry such as we saw last year at Blackpool Football club would result in conditions being applied which were “fair, reasonable and practicable“, and which it would therefore be reasonable to expect to be properly implemented and enforced by whatever statutory body was charged with them.

The Inspector, Wendy Mckay, in her report when referring to the traffic management plan at Roseacre Wood wrote :

The TMP would be secured by planning condition. Mr Stevens accepted that TMPs are a standard planning tool. … if there was any evidence of drivers breaching the TMP in any respect, the Appellant would take this up with the contractor and, if proven, could and would take steps under the relevant contracts; (iv) enforcement: planning enforcement is virtually always retrospective. But given the monitoring condition, any breach could be acted on very promptly by the Council.

It is abundantly clear therefore that Ms Mckay’s recommendation for approval at PNR was based on an assumption that “any breach” of a TMP would be “acted on very promptly by the Council“.

So what is the reality?

We have witnessed serial breaches of planning conditions and particularly of the Traffic Management Plan since work on the site commenced last January. Some are ongoing like the failure to properly implement an approved wheel washing system which was clearly specified in the Traffic Management Plan and the Construction Method Statement but which has never been implemented. We can’t find any published revision to the plan which would legitimise this in any way. Others are individual breaches like unjustified access using right turns and access outside approved hours. This is interesting because although the Traffic Management Plan does now make provision for amendment to the left in left out “depending on the obstruction or threat to HGV safety and/ or public safety travelling along the A583“, it did not in its original versions (until February this year) and it does not specify who should make this decision. The new elements in this clause have clearly been interpolated to make Cuadrilla’s life easier and to minimise the impact of protest. (See the end of this article for a comparison of what was originally  intended and how it has been amended, apparently exclusively to the applicant’s advantage several times since)

3.7
Obstructions
Cuadrilla will work closely with the Police and Highway Authorities to prevent the obstruction of routes into and out of the Site via all practical measures. The primary route into site is left in left out travelling in the direction from J4 of M55, however this is subject to change depending on the obstruction or threat to HGV safety and/ or public safety travelling along the A583

Yesterday I witnessed such a right turn breach (in circumstances which did not obviously meet any of the mitigating conditions under clause 3.7.1 of Version 11 of the Traffic Management Plan) and questioned the police about it. I was told that “their solicitor” had authorised it. When questioned further the Superintendent in charge said “their” meant Cuadrilla’s.  A second superintendent questioned by me admitted that he had been totally unaware of the impending delivery from the wrong direction into the site until it happened. It would therefore appear that the Police and LCC are content to let Cuadrilla themselves decide when it is appropriate for the agreed Traffic Management Plan to be overridden.

The Police clearly have no problem with this either as we saw last Thursday with the out of hours delivery of parts of Cuadrilla’s rig, using a “right in” route, which again did not obviously meet any conditions which would have allowed it to come in from the right at 4:30 in the morning.

As regards the hours, the Traffic Management Plan is very clear:

2.3 Operational Hours
HGVs will only be permitted to enter or leave the Site between specified hours as set out in condition 19 of the planning permission granted on 6 October 2016.These hours are summarised as follows:

Delivery or removal of materials, and works associated with the delivery and removal of plant and equipment – 07:30-18:30 Monday to Friday (except public holidays), 08:30-12:00 on Saturdays (except public holidays);and

Essential repairs to plant equipment used on site may require HGV movements outside of these hours.

The co-ordinated planning of the arrival of vehicles as set out in Section 3.6 will ensure that vehicles do not arrive at the site outside of the permitted hours.

The only exception listed is for “essential repairs to plant equipment“. This would clearly not include first delivery of plant, and yet Cuadrilla appear to have been given permission by the police to deliver outside these hours. Cuadrilla claim they consulted with the Police. The Police claim they were told by Cuadrilla what they were going to to do. LCC appear to have had no knowledge and wring their hands ineffectually and threaten to send a letter, whilst we, the public, look on open-mouthed at such a shambolic and ineffectual regulatory regime that our invisible MP has the brass neck to describe as “gold standard” (or if he doesn’t believe it is he is strangely silent given his insistence that gold standard regulations are required before the drill hits the dirt).

Of course if Cuadrilla find this restriction a little onerous in future they can use the incredible bad drafting of the TMP which also includes a clause 3.5 which states

3.5 Delivery Hours
It is proposed that planned HGV movements will only be permitted to enter or leave the Site between the hours of 07:30-18:30 Mondays to Fridays (except public holidays) and 08:30-12:00 on Saturdays (except public holidays) unless agreed otherwise with LCC.

Oh look – “unless agreed otherwise with LCC”. Perhaps they should have bothered to have a little chat before getting the rig delivered – but then again why waste time following regulations when you know the Council will not take any meaningful action against you anyway?

But it gets worse – if you look at the current version of the Traffic Management Plan it says

3.7.1 Risk Assessment

The primary route is left in left out however in circumstances which dictate that an alternative turn into site is required (right turn entry or exit) this will be for occasions which include:

1) Blocked entrance preventing a left turn into site
2) Threat of an obstacle confirmed by the Police
3) Police instruction
4) Loads or Abnormal Loads which require a right turn under controlled conditions by the Police

A dynamic threat risk assessment will be conducted by Cuadrilla’s security team in consultation with the Police. The primary objectives of the dynamic threat risk assessment is to reduce and prevent disruption to the A583, maintain safety of motorised and non-motorised users of the highway. If the dynamic threat risk assessment identifies any of those key objectives could be compromised an alternative route towards Site will be assessed as a potential solution.

Cuadrilla will consult with the Police and inform Lancashire County Council Highways and Planning departments that a deviation from the preferred agreed route to either right in right out, right in left out or left in right out or a combination of the options as a temporary approach

What does this mean? Well as the Community Liaison Group discovered last night it seems that a group of night club doormen dressed in orange high vis have the authority to override the conditions imposed by the original traffic management plan, and scrutinised by a Planning Inspector and a Government Minister,  if they assess the situation as warranting it. We have already seen that the Police will simply jump when told to by Cuadrilla so this effectively means that the Traffic Management Plan is not worth the paper it is written on. As Matthew Wright asked on “The Wright Stuff” on Friday morning when discussing this matter “I guess critics will argue that if you break regs those .. if you you break regs on planning what other rules and regs might get broken?”. Do you know, I think young Mathew may be right there. We will and do argue precisely that.

But there is more. This “dynamic threat risk assessment” was not mentioned in the original Traffic Management Plan – it only found its way into the document via a revision made in February after Cuadrilla became aware of the scale of opposition that they were encountering

Assuming that Lancashire County Council has agreed the amendments to the plan, then it would appear that they have amended it to give Cuadrilla’s nightclub bouncers in orange jumpsuits the right, which they did not have at the start, to override the conditions previously agreed, at their own discretion (given that in practice the Police merely seem to rubber stamp anything that Cuadrilla tell them they intend to do). There have been several further amendments to 3.7.1 made since.

Yesterday a petition signed by 4100 people was handed in to LCC – it called for the council to “Enforce Planning Conditions in Lancashire”. It might as well have called for the council to mount a expedition to Mars. Our council would appear to have neither the ability nor the appetite to protect its citizens. Far from “mitigating the adverse effects of the development” as intended our planning system appears to be being used to give Cuadrilla carte blanche to operate in the way most convenient to themselves with the collusion of both the police and the council’s planning department.

If this is gold standard regulation in operation then God help us if they do start to drill because LCC and the Police certainly won’t.


If you want another hollow laugh Clause 4.1 of the Traffic Management plan (Version 11 now) says that Cuadrilla must display it on their website

“4.1 Communication

The TMP will be made publicly available on the Cuadrilla website.”

Cuadrilla’s website currently only displays Version 7 – if they are very unlucky LCC may write them a stiff letter for displaying a Traffic Management Plan 4 versions behind the current one. But we sympathise as we find it almost impossible to keep up too.


We would like to make it clear that Andrew Mullaney, Head of Planning at LCC has written to an enquirer that

The Refraktion article contains a number of fundamental inaccuracies, and we were not asked to comment on its accuracy before publication.

We have accordingly written back to him thus

I understand that you believe that the article at http://www.refracktion.com/index.php/fools-gold/ contains “ a number of fundamental inaccuracies” and that you have complained that you were not asked to comment before publication.

It is my intention to present information as factually as possible so I would like to give you the opportunity to provide details of these perceived inaccuracies so that they can be corrected and to add a reasonable comment if you wish.

I will add a holding comment to the article.

and will update this article if he responds.


 

 

 

For those who are interested in the minutiae here are the relevant amendments to section 3.7 and 3.8 of the Transport Management Plan since operations began so you can see how they have been changed to facilitate Cuadrilla’s operations

Version 6 – 15th December 2016

3.7 Obstructions

Cuadrilla will work closely with the police and highway authorities to prevent the obstruction of routes into and out of the Site via all practical measures.

In the event that the route or access to the Site is temporarily obstructed, any vehicles bound for the Site will be contacted via the means set out in Section 2.1. Those vehicles that have not commenced their journey will be advised to remain at their origin until further notice. Vehicles that are already on the route to the Site will be advised on what action to take dependent upon their location and journey origin. All vehicles will be advised not to stop at the Site access and to divert to an appropriate waiting place until further instruction is received. The Site location and proposed routeing is such that vehicles that have already reached the A583 will be able to continue past the Site in order to rejoin the M55 at Junction 3 (via the A585).

From this point they may be advised to return to their origin (if this is local or if the obstruction is likely to remain in place for some time). In the event of a more temporary obstruction, alternative short-term HGV parking is available in a number of locations. This includes a long public lay-by on the A583 to the east of Kirkham, less than 10 minutes’ drive of the site. Alternatively, motorway services at Charnock Richard and Lancaster on the M6 are within approximately 30 minutes’ drive of the site.

Version 7 – 24th February 2017

3.7 Obstructions

Cuadrilla will work closely with the Police and Highway Authorities to prevent the obstruction of routes into and out of the Site via all practical measures. The primary route into site is left in left out travelling in the direction from J4 of M55, however this is subject to change depending on the obstruction or threat to HGV safety and/ or public safety travelling along the A583.

3.7.1 Risk Assessment

A dynamic threat risk assessment will be conducted by Cuadrilla’s security team in consultation with the Police. The primary objectives of the dynamic threat risk assessment is to reduce disruption to the A583, maintain public safety by other highway users and Cuadrilla’s HGV delivery drivers.

If the dynamic threat risk assessment identifies any of those key objectives could be compromised an alternative route towards Site will be assessed as a potential solution. Cuadrilla will consult with the Police and inform Lancashire County Council Highways and Planning departments that a deviation from the primary route to either right in right out, right in left out or left in right out or a combination of the options as a temporary approach. This could vary hourly or daily. The purpose of consulting the Police on the assessment is to ensure that highway safety is maintained with a change in route. The section 278 design and construction allows for a safe right turn into and out of site. A previous safety audit in section 8.6 of Appendix R1 Transport Assessment (ES Arup 2014) has been enhanced with the construction of a central refuge island. The assessment accounted for both left and right turns in and out of site.

A series of rendezvous point will be identified prior to each operational day to safely hold HGV’s before making the final journey to Site. The rendezvous point will be selected daily based on the suitability of holding HGV’s, number of HGV’s scheduled for delivery and the distance from the site. The purpose of the rendezvous point is to control the movement of all vehicles in a co-ordinated manner with Cuadrilla’s security and the Police. This is to minimise disruption to the A583 and ensure vehicles travel to Site in accordance with the prevailing route at the specific time.

Those vehicles that have not commenced their final leg of the journey from the rendezvous point will be advised to remain at their holding point until further notice if an obstruction is identified. Vehicles that are already on the route to the Site will be advised on what action to take dependent upon their location by Cuadrilla’s security team or Police

Version 8 – 27 March 2017

3.7.1 Risk Assessment

A dynamic threat risk assessment will be conducted by Cuadrilla’s security team in consultation with the Police. The primary objectives of the dynamic threat risk assessment is to reduce and prevent disruption to the A583, maintain safety of other highway users and Cuadrilla’s HGV delivery drivers.

If the dynamic threat risk assessment identifies any of those key objectives could be compromised an alternative route towards Site will be assessed as a potential solution. Cuadrilla will consult with the Police and inform Lancashire County Council Highways and Planning departments that a deviation from the preferred route to either right in right out, right in left out or left in right out or a combination of the options as a temporary approach. This could vary hourly or daily. The purpose of consulting the Police on the assessment is to ensure that disruption is minimised and highway safety is maintained. To mitigate the impact from a potential right turn into site the section 278 design and construction allows for a safe right turn into and out of site. A previous safety audit in section 8.6 of Appendix R1 Transport Assessment (ES Arup 2014) has been enhanced with the construction of a central refuge island. The assessment accounted for both left and right turns in and out of site. Further to the above the A583 on approach to site is subject to a proposed advisory descending speed limit from 50mph to 30mph and finally 20mph outside the site entrance enabling a safe right turn manoeuvre.

A series of rendezvous point will be identified prior to each operational day to safely hold HGV’s before making the final journey to Site. The rendezvous point will be selected daily based on the suitability of holding HGV’s, number of HGV’s scheduled for delivery and the distance from the site. The purpose of the rendezvous point is to control the movement of all vehicles in a co-ordinated manner with Cuadrilla’s security and the Police. This is to minimise disruption to the A583 and ensure vehicles travel to Site in accordance with the prevailing route at the specific time.

Those vehicles that have not commenced their final leg of the journey from the rendezvous point will be advised to remain at their holding point until further notice if an obstruction is identified. Vehicles that are already on the route to the Site will be advised on what action to take dependent upon their location by Cuadrilla’s security team or Police

Version 9 – 15 May 2017

3.7.1 Risk Assessment

The primary route is left in left out however in circumstances which dictate that an alternative turn into site is required (right turn entry or exit) this will be for occasions which include:

1) Blocked entrance preventing a left turn into site
2) Threat of an obstacle
3) Police instruction

A dynamic threat risk assessment will be conducted by Cuadrilla’s security team in consultation with the Police. The primary objectives of the dynamic threat risk assessment is to reduce and prevent disruption to the A583, maintain safety of other highway users and Cuadrilla’s HGV delivery drivers.

If the dynamic threat risk assessment identifies any of those key objectives could be compromised an alternative route towards Site will be assessed as a potential solution. Cuadrilla will consult with the Police and inform Lancashire County Council Highways and Planning departments that a deviation from the preferred route to either right in right out, right in left out or left in right out or a combination of the options as a temporary approach. This could vary hourly or daily.

The purpose of consulting the Police on the assessment is to ensure that disruption is minimised and highway safety is maintained. To mitigate the impact from a potential right turn into site the section 278 design and construction allows for a safe right turn into and out of site. A previous safety audit in section 8.6 of Appendix R1 Transport Assessment (ES Arup 2014) has been enhanced with the construction of a central refuge island. The assessment accounted for both left and right turns in and out of site.

Further to the above the A583 on approach to site is subject to descending speed limit from 50mph to 30mph and finally 20mph outside the site entrance. A series of rendezvous point will be identified prior to each operational day to safely hold HGV’s before making the final journey to Site. The rendezvous point will be selected daily based on the suitability of holding HGV’s, number of HGV’s scheduled for delivery and the distance from the site. The purpose of the rendezvous point is to control the movement of all vehicles in a co-ordinated manner with Cuadrilla’s security and the Police. This is to minimise disruption to the A583 and ensure vehicles travel to Site in accordance with the prevailing route at the specific time.

Those vehicles that have not commenced their final leg of the journey from the rendezvous point will be advised to remain at their holding point until further notice if an obstruction is identified. Vehicles that are already on the route to the Site will be advised on what action to take dependent upon their location by Cuadrilla’s security team or Police.

Version 10 – Also 15 May 2017 – Significantly shortened to remove holding point instruction

3.7.1 Risk Assessment

The primary route is left in left out however in circumstances which dictate that an alternative turn into site is required (right turn entry or exit) this will be for occasions which include:

1) Blocked entrance preventing a left turn into site
2) Threat of an obstacle confirmed by the Police
3) Police instruction

A dynamic threat risk assessment will be conducted by Cuadrilla’s security team in consultation with the Police. The primary objectives of the dynamic threat risk assessment is to reduce and prevent disruption to the A583, maintain safety of motorised and non-motorised users of the highway.

If the dynamic threat risk assessment identifies any of those key objectives could be compromised an alternative route towards Site will be assessed as a potential solution. Cuadrilla will consult with the Police and inform Lancashire County Council Highways and Planning departments that a deviation from the preferred agreed route to either right in right out, right in left out or left in right out or a combination of the options as a temporary approach.

In case the above changes do not give Cuadrilla quite enough flexibility it seem that LCC have bent over backwards to ensure that the next version gives them the ability to totally ignore the right in right out provisions of the plan agreed before operations began. We are genuinely puzzled by this proposal as LCC would appear to have granted almost all of the powers proposed to  Cuadrilla some time ago back in February.

DEVELOPMENT MANAGEMENT
APPLICATION REF: LCC/2014/0096/1
APPLICATION FOR THE AMENDMENT OF THE TRAFFIC MANAGEMENT PLAN APPROVED UNDER THE REQUIREMENTS OF CONDITION 11 OF PLANNING PERMISSION LCC/2014/0096
LOCATION: AGRICULTURAL LAND THAT FORMS PART OF PLUMPTON HALL FARM TO WEST OF THE FARM BUILDINGS, NORTH OF PRESTON NEW ROAD, OFF PRESTON NEW ROAD, LITTLE PLUMPTON, PRESTON

Description of development and condition

Condition 11 of the planning permission for the Preston New Road Exploration Site requires the development to be undertaken in accordance with an approved traffic management plan.

The traffic management plan was approved under the requirements of this condition on 4th January 2017.
As a result of experience on site since the development commenced, an amendment to the approved TMP is now proposed (version 11)

Applicants Proposal’s

The original TMP proposed that all traffic would access the site from junction 4 of the M55 and leave towards junction 3 so that there would be a left in, left out operation at the site access. The site operator is proposing that this would still be the main means of access but that there would also be a more flexible mode of operation so that HGV’s would be able to access the site from junction 3 and leave towards junction 4 in certain circumstances. The operator is proposing that the choice of route would be based upon a risk assessment undertaken on a day to day basis. The revised TMP also contains provisions in respect of local depots or facilities supplying the site – such sites will access the primary road network as soon as reasonably practicable.

All other elements of the TMP would remain as currently approved.

Consultations

LCC Highways (Development Control): No objection. The TMP should be specific about the circumstances when alternative routeings will be permitted which should be with the agreement of the police.

Preston New Road Action Group: Do not consider that the TMP should be amended. The existing TMP is unambiguous in its language and the revised TMP will lead to confusion as other road users will be expecting HGVs to turn left into the site and left out of the site and employment of other movements will increase the risk of accidents. PNRAG consider that the increased flexibility would mean that it would be very difficult to demonstrate that the TMP had ever been breached. PNRAG consider that the revised TMP will allow the HGV routeing to be amended without the approval of LCC.

County Councillor Liz Oades: CC Oades has written to the County Council on 23 April 2017 expressing concern about the prospect of large numbers of HGVs travelling along the A583 and the A585. The TMP has been breached on many occasions which has resulted in convoys of lorries travelling through Kirkham and Wesham.

Assessment of application

Condition 11 of the planning permission for the Preston New Road Exploration site requires the submission of a traffic management plan covering the routeing of HGVs to and from the site. The traffic management plan was approved on 4th January 2017 and requires all HGVs to access the site via junction 4 and leave towards junction 3 so that HGVs only make left in, left out manoeuvres onto the A583 from the site access.

In the main, since the development commenced the routeing controls within the TMP have been complied with. However, due to protestor activity and any other incidents that may close part of the routes between the site and motorway, the operator is requesting more flexibility so that they have the ability to route HGV’s to the site from junction 3 or out of the site towards junction 4. The operator proposes to undertake a continual risk assessment in consultation with the police that will allow HGVs to access the site via alternative means should the normal access routes not be available or if there is a risk that protestor activity would result in closure of the road (that risk being confirmed by the Police).

The original EIA included a study of the junction with the A583 and concluded that the junction would be safe for all manoeuvres including turning right into the access and turning right out of the access. After hearing evidence, the Planning Inspector concluded after the Public Inquiry that she was satisfied that the proposal would not have a significant adverse impact on highway safety. Therefore it is considered that there is no highway safety reason why the access should be limited to left in, left out. As the speed limit along this section of road has now been reduced to 30 / 20 mph, the risks to highway safety are actually lower than when assessed during the planning application and appeal. The changes to the agreed routeing arrangements must therefore be considered in that context.

The changes to the TMP proposed by the operator would allow the choice of access route to the site to be changed taking account of risk. This would reduce the incidence of the A583 being closed and would therefore minimise delay and disruption to other road users. There is also some additional detail relating to when the site is being supplied from local depots or other facilities – in these circumstances, the supplier will seek to access the primary road networks as soon as reasonable practicable.

It is considered that a left in, left out is still the safest method of operation for the access and which should therefore be used whenever possible. The revised TMP provides for this mode of operation to be the case. The applicant is proposing that any deviation from the normal routeting is only utilised when the site access is blocked, or the road is closed, or there is a threat of closure confirmed by the Police. This would provide the necessary control such that the alternative routeing is only utilised when the preferred route is unavailable or where there is a risk that vehicles would be subject to protestor activity which could give rise to health and safety implications.
The changes to the TMP would not increase the number of HGV movements associated with the development. Departure from the normal routeing arrangements may result in small increase in HGV movements on the A585 (if vehicles access and leave the site via junction3) but such numbers need to be considered in the context of the overall traffic levels on that road. Even if a significant number of site vehicles departed from the agreed routeing, the effect on overall traffic numbers on the A585 would be small.

The revised TMP will not require LCC to grant approval every time an HGV wishes to depart from the normal routeing. However, the decision to depart from the normal routing would be agreed with the police and the County Council then informed via the regular returns that are made relating to HGV movements. This is considered acceptable and would ensure that any movements are undertaken in a safe manner.

The provisions regarding local suppliers are considered acceptable. During the life of the project there may be some local suppliers who are not situated on the primary road network. The revised TMP provides for them to access the site by gaining access to the primary road network as soon as reasonably practicable. This is considered acceptable.
The comment from CC Oades relating to convoys of lorries passing through Kirkham and Wesham is noted. It is understood that this took place when stone was being imported to construct the drilling pad and this manner of operation would not be a regular occurrence during development or restoration of the site.
The amendments to the TMP are therefore considered to be acceptable.

Recommendation:

That the amendment to the approved Traffic Management Plan ref Issue 11 dated 12th June 2017 be approved.

The TMP currently in force therefore has this condition

Version 11 – Also dated 15 May 2017 in version control but dated as 15th June on LCC website and presumably the one referred to as dated 12th June above

3.7.1 Risk Assessment

The primary route is left in left out however in circumstances which dictate that an alternative turn into site is required (right turn entry or exit) this will be for occasions which include:

1) Blocked entrance preventing a left turn into site
2) Threat of an obstacle confirmed by the Police
3) Police instruction
4) Loads or Abnormal Loads which require a right turn under controlled conditions by the Police

A dynamic threat risk assessment will be conducted by Cuadrilla’s security team in consultation with the Police. The primary objectives of the dynamic threat risk assessment is to reduce and prevent disruption to the A583, maintain safety of motorised and non-motorised users of the highway. If the dynamic threat risk assessment identifies any of those key objectives could be compromised an alternative route towards Site will be assessed as a potential solution.

Cuadrilla will consult with the Police and inform Lancashire County Council Highways and Planning departments that a deviation from the preferred agreed route to either right in right out, right in left out or left in right out or a combination of the options as a temporary approach

The latest version also contains a new Clause 3.8

3.8 Local Supply

Suppliers using local depots or facilities to supply the Site will route vehicles as soon as reasonably practicable onto the primary road network.

Which seems open to just about any interpretation you wish, but presumably gives local suppliers the right to approach and leave the site however they wish.

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