A plan for lorry access to the Horse Hill oil site would threaten road safety and disturb local people, the Weald Action Group has complained.
The group, a network of campaigns opposed to operations at the site, described the plan as “unworkable” and “badly thought out”.
It said the plan, yet to be agreed by Surrey County Council, appeared not to restrict the hours that heavy goods vehicles (HGVs) could enter the site during 20 years of oil production and other operations.
UK Oil & Gas plc (UKOG), the main investor at Horse Hill, denied lorry access would be unrestricted.
Weald Action Group also said lorries accessing the site already swung over to the other carriageway. Fencing close to the edge of the road restricted the space available to other road users to take avoiding action, it said.
The traffic and transport management plan (TTMP) has been commissioned by the site operator, Horse Hill Developments Ltd (HHDL) It was a condition of the planning permission for oil production and extra wells at the site near Horley.
Vicki Elcoate, of Weald Action Group, said today:
“This plan is unworkable. Wide turns by HGVs on a narrow but fast rural road pose a risk to other road users. The long hours of operation, day and night, will cause noise and disturbance to residents, farm animals and wildlife.
“Residents fear a lack of monitoring and enforcement means the current poor situation will go on for years under this badly thought out plan”.
The planning permission was granted by Surrey County Council in September 2019. A local resident has launched a legal challenge to the consent.
The decision document formalising planning permission did not specify the hours that HGVs could enter and leave the site.
Condition 6 of the permission stated that no operations could take place outside hours of 8am-6.30pm Monday-Friday and 9am-1pm on Saturdays, with the exception of drilling, production, workovers, extended well tests and short-term testing.
Condition 8 required a transport and traffic management plan that would include HGV deliveries and hours of operation.
The plan, currently the subject of a public consultation, states that there will be no deliveries on Sundays or bank holidays. But it implies that deliveries would also be 24 hours a day during the exempted operations. It said:
“Although the site is expected to operate on a 24-hour basis during short-term drilling (i.e. workover) operations and during the production of oil, outside of these periods, materials delivered to and collected from the site would take place with the following hours consistent with condition No.6:
08:00 and 18:30 hours (Monday-Friday) and,
09:00 and 13:00 hours on Saturday.”
The total duration of the permission is 25 years (300 months).
Based on HHDL documents, the operations permitted to take place 24-hours-a-day account for more than 21 years (260 months) or more than 86% of the planning permission period.
The 24-hour operations comprise:
- workover of HH-1/1z and HH-2 wells – 1 month
- drilling four production wells and one water injection well – 15 months
- production of oil – 20 years or 240 months
- maintenance workovers (if necessary) – 1 month
- sidetrack drilling (if necessary) – 3 months
Weald Action Group said:
“The HGV movements should not follow the planning permission for the oil production but should be limited to the hours of daylight for reasons of safety and disturbance to neighbours throughout the permission period.
“The planning permission is long in terms of overall duration and in terms of daily impact. The HGV movements should not add to this burden and should be managed within restricted hours. The hours of daylight are easy to manage and enforce.”
UKOG told DrillOrDrop:
“We agree that the words “outside of these periods” in the TMP could possibly be misinterpreted. However, to be clear and per out Horse Hill planning application, there will be no HGVs coming in or our of the Horse Hill site other than between the following hours: 08:00 and 18:30 (Monday-Friday) and 09:00 and 13:00 hours on a Saturday.”
The plan said a swept path analysis showed that HGVs would no longer need to swing out on the opposite carriageway to enter the Horse Hill site.
But in its objection to the transport and traffic plan, Weald Action Group said the swept path analysis diagram was not drawn to scale and was misleading. It added:
“One of the fundamental flaws in the document is that it fails to demonstrate that HGVs entering the site can do so without crossing the centre of the road.
“Lorries currently entering the site are failing to do so safely. This is not a matter of drivers misjudging the situation but a reflection of how difficult the task is.”
Weald Action Group added:
“Large HGVs, for example cranes, or vehicles carrying drilling rigs are excluded from the assessment by the applicant, suggesting that these loads will not be required, but that appears to be contradictory to the nature of the planned operation.”
HHDL said any breaches of the swing-out rule would be reported to the site operator. But Weald Action Group said:
“It is unclear what action they will be able to take as a result.
“It should also be noted that fencing has been installed right up to the road edge on the other side of the road from the site entrance, which means cars suddenly caught up in a “swing out” incident have nowhere to go.”
HHDL has installed removable bollards across the site entrance. Eye witnesses have reported that security staff remove just the bolllards in front of the gates to allow HGVs to enter the site. This restricts the swept path in and means HGVs continue to have to swing on to the opposite side of the road.
Other road users
Weald Action Group also said the plan did not consider walkers, horse riders and cyclists.
“HGVs should not be allowed to overtake walkers, horse riders and cyclists between the A217 and the site entrance. This would be dangerous for drivers on the other side of the road as well as the walkers/cyclists.
“The TTMP fails to have regard to the fact that Horse Hill is on the Surrey Cycleway, which Surrey County Council promotes to cyclists.”
The cycleway is described as a route that uses quiet country roads and lanes and is well sign-posted. It is said to be suitable for people who have some experience of cycling on roads.
The plan proposed holding areas for HGVs delivering to the site and the use of police escorts.
Weald Action Group said HHDL should provide evidence that the operators of the proposed holding areas had given consent. Surrey County Council should check that police had agreed to providing escorts, the group said.
Compliance and commitments
Weald Action Group accused HHDL of not complying with conditions of previous planning consents on signage and HGV access hours.
The group also accused the current plan of making commitments without giving detail.
“The Plan touches on issues including car-sharing and shuttle buses to the site, surveys of the road condition, and creation of new parking spaces on-site, which would appear to necessitate the removal of woodland and mature trees. No details are supplied on any of these issues.”
- The public consultation on the transport and traffic management plan continues until 31 January 2020. Link to details
Updated 28/1/2020 with quote from UKOG and amendment to headline.