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 PoliceA 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 https://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 instructionA 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 instructionA 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, PRESTONDescription 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 PoliceA 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.
