Regulator minded to allow “substantial” changes at Horse Hill oil site

The Environment Agency is seeking public comments on its expected approval of a wide range of new operations at the Horse Hill oil site in Surrey.

Horse Hill oil site, 4 October 2021. Photo: Weald Action Group

The site operator, Horse Hill Developments Limited (HHDL), has applied to vary the site’s environmental permit, to allow water reinjection and more drilling, testing, well treatments and oil production.

A public consultation began today on the draft permit and runs until 31 March 2022.

The Environment Agency described the application as a “substantial variation” to the environmental permit. But it said it was minded to allow the changes. It said today:

“The Environment Agency are satisfied that the scope of the works proposed by the applicant and the resulting changes to the environmental permit will not give rise to pollution of groundwater or surface water receptors.

“Unless we receive information that leads us to alter the conditions in the draft permit, or to reject the application altogether, we will issue the permit in its current form.”

This is the third consultation on the proposed permit changes at Horse Hill. The first, in 2019, received nearly 500 responses. A second consultation in 2021 had 180 comments.

If approved, the permit changes would allow:

  • Drilling of four boreholes and repurposing of two boreholes for water reinjection
  • 90-day extended well tests, including flaring, for the additional wells
  • Production from additional wells
  • Reinjection of produced and clean treated surface water to support hydrocarbon production
  • Burning up to 10 tonnes of waste gas per day during production
  • Well treatments, including acid wash and use of solvents
  • Disposal of uncontaminated surface water from the well pad into a nearby stream during testing and production
  • Injectivity tests on two wells earmarked for water reinjection

Key issues


The decision document, which explains why the EA proposes to allow the changes, revealed disparities between HHDL’s permit and planning applications.

Surrey County Council granted planning permission in September 2019 to allow changes which included drilling four new hydrocarbon wells and one water reinjection well.

Today’s draft permit notice said HHDL planned two reinjection wells: a repurposed existing well (HH-2z) and one of the additional four new wells.

The council said this could indicate “a material change to the planning permission” and HHDL should ensure it contacts the planning authority.

The EA said:

“It is the responsibility of the operator to hold all necessary permissions to undertake the described activity.”


The EA said it needed to set conditions that must be met before HHDL could carry out some operations. The company must:

  • Notify the EA before it begins water reinjection
  • Confirm whether any changes to boreholes are needed for reinjection
  • Confirm whether there have been any changes to integrity of the HH-2z borehole
  • Provide at least three months of groundwater and surface water monitoring to establish a baseline and determine any changes from site operations

The EA has also said there should be limits on:

  • Disposal of waste gas from extended well testing and production
  • Reinjection of produced water
  • Emissions of nitrogen oxides, carbon monoxide and total volatile organic compounds

There should also be monthly monitoring of the feed gas to the flare, the EA said.

Air pollution

The UK Health Security Agency in its comments on the permit changes noted the levels of nitrogen dioxide and benzene may breach air quality standards at the site boundary during drilling.

The EA said it agreed with HHDL’s air quality modelling:

“Environmental standards for human health and critical levels or loads for ecological receptors are unlikely to be breached.”


Under the permit, gas produced along with any oil would be burned in a flare during well testing and production.

The EA agreed with HHDL’s conclusion that this was the best available technique for disposing of gas, which is regarded as a waste product. Flaring was the only “technically and commercially viable solution for disposal of gas”, HHDL said.

The site is expected to use two flares: one suitable for low flow volumes and one for up to 250,000 standard cubic feet of gas per day. HHDL will have to inform the EA if it uses the higher flow rate flare.

The company has also committed to revise its gas management plan if the wells generated enough gas to change the assessment on flaring.

Charlwood Parish Council, in an earlier response to the EA, said gas flaring should not be considered best available technique because of the expected volume and the additional effects of nearby Gatwick Airport.

The campaign group, Weald Action Group, said the gas management plan should include estimates of gas associated with oil production from the four new wells. It also said there was no justification for not using the gas to generate electricity for the site. Changes in government guidance soon may mean that flares may no longer be considered best available techniques, the group added.


The area around Horse Hill experienced a swarm of earthquakes between 1 April 2018 and 27 February 2019. The strongest, on 27 February 2019, measured 3.1ML and prompted more than 1,600 reports to the British Geological Survey (BGS). A report for the Oil & Gas Authority concluded that the earthquakes were not likely to have been caused by hydrocarbon operations.

Despite this, the EA received comments that changes at Horse Hill could lead to more earthquakes.

Charlwood Parish Council said precautionary measures should be applied following the earlier swarm.

The campaign group, Markwells Wood Watch, said the site’s geo-hazards assessment should have been updated to reflect the new operations, particularly reinjection.


HHDL wants to carry out treatments on the existing and new wells to improve their performance. These comprise:

  • Hydrochloric and acetic acids at concentrations up to 15% to remove damage to the wellbore
  • Xylene solvent treatment to remove paraffin precipitates to improve flow in production wells
  • Hot oil recirculation to remove waxy precipitates in production tubing and casing
  • Potassium chloride and ORCA B and CS-SAF-2 to remove filter cake that could build up in the near well bore area

The EA said well treatments would not to extend beyond 10cm of the wellbore and they met the “requirements of published guidance”.

Markwells Wood Watch said the application lacked a sufficient risk assessment for proposed well stimulation. Weald Action Group said pressures and quantities of acid should be recorded and reported to the EA.

Water disposal

The permit would allow HHDL to reinject produced and surface water into the Portland sandstone formation to a maximum depth of 762m.

The injection rate must be no more than 2.6 litres/second and no more than 80m3 in a day (eight or 12 hours).

The EA said gauges would be installed to ensure water reinjection did not exceed 90% of formation fracture pressure. Wellhead and annuli pressures to be monitored and logged hourly.

Markwells Wood Watch asked the EA for details of how much produced water would be reinjected and at what pressures.

The permit also allows HHDL to discharge clean surface water to Spencer’s Gill brook during well testing and production and when site was not operating

The permit would not allow discharge to the gill during drilling and any well workovers, the EA said. During these operations surface water will be collected by tanker and taken to a waste facility.

The EA said it was:

“satisfied that the controls … provide sufficient levels of protection to protect Spencer’s Gill and other receiving water bodies at distance from the site.”

But Weald Action Group said surface water should be sent to a treatment plant, rather than discharged into Spencer’s Gill.

Broadford Bridge Action Group Pollution Watch (BBAGPW), a campaign group based near a site run by a sister company, said there were risks to groundwater from pollution incidents or emissions.

HHDL proposes to install groundwater monitoring wells next to the wellpad to identify any deterioration in quality. But BBAGPW was concerned about the level of monitoring of surface collected water.

Carbon emissions

Charlwood Parish Council said all the site’s carbon emissions should be considered. These should include transport to and from the site for its lifespan, as well as emissions from processing and burning the produced oil and gas.


Concerns have been raised about the durability of the impermeable line under the Horse Hill site.

BBAGPW said the liner would not last for Horse Hill’s lifetime. The EA said the integrity of the liner would be tested every three years and remedial action would be taken if needed.

EA resources

Salfords and Sidlow Parish Council raised concerns about whether the EA had sufficient resources to monitor and enforce regulations.

The regulator responded:

“The Environment Agency undertake regular compliance checks at permitted facilities to ensure that conditions and limits within the permit are complied with.”


Broadford Bridge Action Group Pollution Watch said the permit variation application form had been filled in incorrectly and the geological and hydrogeological reports were inconsistent with information given by shareholding companies. The group also said there was not enough detail about formation thicknesses, dip, faulting and stresses to support the risk assessment.

39 replies »

  1. Is the Environmental Agency approving this development that MAY exceed the legal limited for NO2,
    while insisting that Greater Manchester MAY NOT exceed the legal limit for NO2 ?
    Grateful if the Environmental Agency or DEFRA can clear the air on this important point.

    Robin Grayson FGS
    Geologist adviser to Liberal Democrats, Greater Manchester

    • We don’t have an “Environmental Agency” Robin so the answer is no. Perhaps you can advise the LibDems that it is the Environment Agency? How did the LibDems do last night?

  2. Issues concerning the moral acceptability of directing investment at FFs rather than renewables aside for the moment;
    if the Weald Action Group’s assertion that “flares may no longer be considered best available technique” has merit then no permissions should be issued until the better techniques are approved and available.
    The Markwells Wood Watch recommendations deserve to be taken seriously. If the proposed action changes then so should the protections change to reflect this.
    Acidification involves intentional pollution intended to be confined to a small area but without the degree of certainty concerning likely spread and leaching necessary to judge the risk.
    Concerning proposed discharge to Spencer’s Gill, this should be considered intentional pollution unless sources of discharge are monitored and degree of ‘clean-ness’ established and published.
    Liner integrity – prevention being better than cure – three years is too long a period in which potentially to permit pollution.
    EA capacity: well known now to be inadequate, notwithstanding bland statements to the contrary.

    • Except lots of investment into renewables, so there is no “rather than” and there has never been any reason why that should be the case. Indeed, there is considerable investment from monies generated from fossil fuel into renewables. Certainly the case in the UK and can be readily verified. I have previously posted references to some of it. Just more facts and truth, but that is what is needed, otherwise children in UK will be “educated” about what is not happening as well.

      • It’s very true, MFC.
        Children in the UK really are in a huge predicament, the education system is dire! Most 8 year old children asked where meat, cheese and milk come from:
        Answer the shop?!? a former Secretary of State for education, Knighted for services to ‘education’ no-less ever though he’s been sacked by two previous PM’s, lost his defence and education secretary jobs, criticised for having dinner with the ex-wife of a former minister of Putin for a donation to his party!
        Children are not support by current government understandings and they are the ones who will pick up the costs of this RUSH for renewables!
        Energy prices are HIGH, No amount of Wind Turbines have or will lower the cost of energy, they will just sustain a stop gap until the next energy source…

      • I discern repeated difficulty in/ determination not to comprehend. No one denies renewables are supported. To simplify, – again – they would be better supported were not so much money wasted in also supporting that which is causing the problem.

        • £11 billion of annual support plus another £2.5 billion to fill the gaps caused by the unreliability and instability they bring, all taken directly from consumers. Yet some believe that this is not enough and want the tax refunds from industries that have overpaid, to also be included.

        • I discern exactly that, 1720.

          Nope, they would not be better supported if fossil fuels were not. Fossil fuels raise the taxation that supports renewables massively, and then the fossil fuel companies themselves invest some of their “problem”-where?-oh yes, into renewables. Except, some would like that stripped from them and given to the consumers! Interesting, isn’t it, how the arithmetic continues to fail for the antis.? Windfall tax on N.Sea becomes a wind turbine tax-that is reality. And, of course, UK produced oil and gas produce more of that taxation benefit for UK.

          Look out, again, golden geese.

          • Produce the arithmetic, or are we back in your preferred territory of unsubstantiated assertions?

            • See my post of 10.20am and follow it, 1720. Fact and truth. Not to your understanding, but according to the OED. I will prefer that territory.

  3. Wonder what the EA is doing about the NO2 levels on the production of imported oil?

    Zilch, nothing.

    Or transport emissions from imported oil?

    Zilch, nothing.

    Great demonstration though that here in the UK local production under scrutiny to achieve good standards. Produce locally. Even jobs for UK geologists, to save them flying off around the world seeking their fortunes.

    Perhaps the difference between Manchester and HH, is another case of a Lib Dem attitude? Different policies in different areas. Wins locally sometimes, then fails nationally.

    • For NO2 air pollution, onshore UK there are several hundred NO2 Air Quality Management Areas AQMA.
      Each NO2 AQMA is designated by a local authority, the AQMA approved by DEFRA in coordination with the EA.
      Each NO2 AQMA is monitored by NO2 diffusion tubes at regular intervals, the diffusion tubes each submitted to an approved laboratory for calculations and results are published.
      The main purpose of most NO2 AQMAs is to monitor the long-term trends in the AQMA, and to use the data to justify Clean Air Zones and Traffic Management to reduce the NO2 levels, so that eventually the NO2 AQMAs can be extinguished one-by-one.
      Footprints of many of the NO2 AQMAs happen to cover refineries and oil depots as these are commonly point sources.
      Most of the NO2 diffusion tubes are positioned close to busy roads, whereby Traffic Engineers can then extrapolate the boundary of the AQMA to take account of the traffic flows, types of vehicles in the traffic flow, and the predicted NO2 levels,
      Additional NO2 diffusion tubes are positioned where necessary to help with the AQMA mapping.

      There are exceptions, notably the SO2 AQMA around Stanlow petrochemicals complex, where SO2 levels define the AQMA footprint:

      Nationally, it is now realised that NO2 hotspots often occur where dirty diesels have their engines running, notably at certain bus stops, and where diesel vehicles cluster outside schools.

      Liberal Democrats sometimes install additional NO2 diffusion tubes to help identify and report such hotspots.
      Greater Manchester Lib Dems have a novel very rapid method of identifying NO2 hotspots, and NO2 corridors along roads etc.
      This simply involves eyeballing of colourful orange/yellow lichens on tree trunks, twigs and/or fences and/or road signs; specifically the Gold Dust Lichen and – more reliably – the Sunburst Lichen (Xanthoria parietina) which incredibly feed on NO2 and/or ammonia in the air. They are NO2/ammonia junkies and slowly die without their regular fix. Find these lichens and there is an air quality problem of either NO2 and/or ammonia. In urban areas of Greater Manchester these lichens are free-of-charge tell-tale biomonitors of illegal levels of NO2 (or high ammonia). Often these are ‘urban canyons’ created by buildings facing each other across a road, thereby semi-trapping air flow and causing traffic-polluted air to linger for hours or even days.

      Robin Grayson FGS
      Liberal Democrats, Manchester

      • Very interesting Robin. Those dirty diesels congregating outside of fossil fuel sites might be an issue then. Wonder how the lichen is doing?


    No powers / no staff / they are mostly working from home, at least in the NW they are.

    “England’s Environment Agency has downgraded 93% of prosecutions for serious pollution over four years, despite recommendations from frontline staff for the perpetrators to face the highest sanction, a leaked report seen by the Guardian reveals.

    Between April 2016 and December 2020, investigators within the agency gathered evidence and prepared case files on 495 serious incidents, involving the worst type of pollution of rivers and coastal waters as well as serious waste crimes, according to the internal document.

    They recommended that the agency prosecute in all the cases. But the document shows that after intervention by managers just 35 cases were taken forward to prosecution, the rest being dealt with via a lower sanction such as a warning letter, or dropped all together and marked for no further action.

    Officers investigating the highest categories of waste pollution, including those perpetrated by individuals involved in serious organised crime, recommended prosecution in 386 cases. But only 4% of cases were pursued, while the rest were downgraded to a caution, enforcement notice or warning letter, or marked for no further action. The scale of dropped prosecutions was revealed as the government claimed it was engaged in a crackdown on waste criminals.

    When it came to investigation of serious pollution incidents in rivers and coastal waters, investigating officers said 109 cases should be prosecuted. These are likely to have involved breaches of permits by water companies leading to illegal discharges of raw sewage, as well as other serious water pollution. Only 21 cases, however, were pursued to a prosecution; just 19%.”

    • Curiously enough, I’ve been saying just that for several years now, haven’t I? That the EA, OGA and all the other so called “publicly responsible” organisations were being deliberately defunded, criminally understaffed, and interfered with by the various vested interests like the fossil fuel industry in order to disable them and to render them ineffective and irrelevant to the purpose they were supposed to serve.

      However, if you look at the executive branch of government however, who are not directly responsible to the public, but only serve their political masters, all those executive branches are fully funded and are being given entirely undemocratic powers of acting outside the constitution of the Crown and of Great Britain and their supposed responsibility to the public of Great Britain and the Crown.

      That effectively takes what little power of influence of the government that is left to us, and throws it in the waste bin of dictatorial government power over everyone and everything.

      One example of that, is that there is a bill going through consultation (up to 8th March 2022) in order to proceed through parliament to “redefine” the Human Rights legislation. The purpose of which will be to enable the government to dictate what few rights or no rights any person or organisation will be allowed to have by diktat. Whereas the present Great Britain signatory rights of the Human rights Act does not specifically define individual rights in law, but makes all Human Rights inalienable. Inalienable in law term is collectively given as “in-a-lien-able” = beyond lien or tort) under law, in other words, that your Human Rights are a given regardless of circumstances or changes in law or any other form of governmentally attempted interference or modification of yours and everyone else’s Human Rights.

      Looking at your post Paul, it’s not clear if you are saying that you agree with the disempowerment of the Environment Agency and the other “alphabet soup” of abbreviations, initials and acronyms for governmental agencies such as the OGA and so on. Or whether you are regretting the disempowerment of such publicly accountable organisations and the effect that has on preventing the public from being properly represented and empowered to act within the Great Britain constitution, however that is interpreted?

      Perhaps you could explain how you feel about the reduction of representation of the public in governmental matters at all?

      [Text added at poster’s request]

        • Hmm. My comments would be that if a consultation is to take place, how will any diktat occur? A diktat would occur if no consultation was conducted, or the results were ignored. The last bit would be speculation currently.

          “The purpose of which” is one individual’s opinion, so good job there will be consultation. Perhaps the many who will take part in the consultation will achieve a different purpose, but there will still be unhappy individuals. That is what democracy achieves. However, it usually achieves less unhappy people than the alternatives.

          Is the current situation so perfect in regard to Human Rights? All Human Rights are not inalienable in UK currently, so perhaps there is room for improvement.

          • The result of a consultation is a body of opinion which the government can accept/reject/ignore and which, attributed or not, could be used as a specious justification for subsequent diktats – eg.“Having consulted, the government has decreed that…..” There is no necessary link, indeed many of us who respond to consultations are of the opinion that the relevant decision has already been taken, the consultation merely a sop to public opinion. To the gullible, the purpose of a consultation is always to discover what we, the people, think in order to be able to act in conformity with the democratic wish as expressed.
            Whether the result achieved by democracy is “ less (sic) unhappy people than the alternatives” Is a matter of personal opinion and not really susceptible to proof.
            To believe that HMG in rewriting the Human Rights Act for a Britain so outstanding in its respect for the rights of others as to, for example, consider using the navy to repulse assault by invading small boats packed with asylum seekers, is not seeking merely to distance itself from the EU in order to get Brexit done and assert a spurious sovereignty is a matter for an individual inhabiting cloud cuckoo land. To imagine that the diktats following consultation will constitute, in limiting the scope and application of the current Act, a real improvement for humanity over what we have already, is really to bid farewell to reason and therefore rational discourse. It remains of course a personal opinion (or not).

            • As I stated, some will be unhappy.

              However, I have seen on this site a certain 1720 repeatedly advise others to contribute to consultations to try and influence opinion and policy decisions. So, a sop or not? Or just mixed messages? Certainly a contradiction.

              Susceptible to proof? Yes, it is. There are countries who do not enjoy democracy. Proof can be found in those countries very easily. I would suggest the people of Ukraine are not too happy that their democracy is being crushed currently, imperfect though it might be. Could they influence Human Rights in their own country? Yes. Would they be able to under Russian control? Nope. Which would make them more happy?

              And, no, the navy is not being considered for anything of the sort. It is being considered to act as control and support for other agencies.

              So, in my opinion, more people would be happy if they knew what was actually going on within a democracy. Not all, but it would help.

              I have yet to see any Act that could not be improved. A lot of people are well remunerated to do so continuously. Why should the Human Rights Act be an exception?

              • Your penultimate paragraph makes sense, and I heartily agree, the rest is glorious non sequitur, if not gobbledygook. Your fourth paragraph is an attempt to rewrite history by carefully manipulating the sense of the original. Lot of that about these days. We know this was considered by Patel.
                I won’t analyse your modus operandi any further, having frequently done so, but do get out of the habit of imagining that a simple contradiction will suffice to persuade or convince.

                • Ahh, now it is becoming apparent who the “we” are. Sorry, 1720 but you have not been listening to the debate about that subject, that has been available in real time for people to watch and listen to, including the “we’s”. It was made very clear the navy had “platforms” that were unsuitable for direct action in the Channel, ie. they were too high out of the water. But, what they could do was control and organize those agencies who had “platforms” suitable to the task. I happen to believe that having some control and organization to save lives may be an improvement.
                  I leave it to others to manipulate history. (HMG did campaign for UK to stay in the EU.) Your modus operandi is crystal clear. Get caught out regarding facts and then try and imply others are not factually correct as a screen, even contradicting the definition of fact to do so, and hoping that your past statements will be covered up. Not alone, but there are better ways to operate.
                  [Edited by moderator]

            • Precisely so Iaith1720, what few people understand, is that there is a fundamental difference between “Rights” and “Regulations” or a “Bill of Rights” which is what is intended to be done by this redefining of the Human rights Act.

              As I said, the present Human Rights Act allows for the inalienable rights of every person in any situation, regardless of any other law or statute that seeks to alter, modify, or limit the Human Rights Act or any other freedom of movement, thought, speech, action and protest. No one needs to declare their Human Rights, since it is enshrined in the very foundation of The Law of The Land, the Crown and the legal system. Therefore, the Human Rights cannot be questioned, you simply have them as a right of life itself.

              However, when a Bill of Rights is intended to overturn the inalienable rights of everyone in the Human Rights Act, A Bill of Rights seeks to precisely define the entire definition of Human Rights and that can only result in the limitation and to place the Human Rights of everyone in very restricted parameters.

              The Police, Crime, Sentencing and Courts Bill last minute changes are an interesting example of the attempts to severely limit the rights of protest on the back of simplifying certain sections that had evolved since the perfectly reasonable laws that already defined the law within the Human Rights Act. You may recall how that was claimed to be merely tidying up the present laws, but turned out to be entirely the opposite in its wording and added clauses to the point of a Draconian restriction of all rights of thought, speech, action and protest.

              It is well known that the increasingly centralised power originating from the corporations and paymasters amongst the executive branches of government do not want the inalienable freedoms of their constituents. Since that will interfere and limit the power and control of centralised government.

              As soon as a Bill of Rights becomes law, then every aspect of life of the constituents becomes subject to any change in limiting or entirely removing the rights to freedom of movement, thought, speech, action and protest if those changes are seen to be Draconian and to limit any freedom of anyone or any organisation to act within the law.

              So, does anyone prefer to have the inalienable freedoms of Human Rights, or a delimited manufactured Bill of Rights that can be changed, further restricted and interfered with or even done away with altogether at any time by the present, and any future government?

              • Just to pull that back to the subject matter of: “Regulator minded to allow “substantial” changes at Horse Hill oil site” and the fact that the Environment Agency and the Oil and Gas Authority.

                By deliberately restricting these government agencies’ ability to carry out their intended function through defunding, understaffing and organisationally compromising their ability to act in any way at all. That is another way of allowing the centralised executive branches to take more and more power away from publicly accountable agencies that were previously intended to protect the public from unscrupulous actions of government, private corporations, organisations or individuals.

                There are signs that there are more executive branches being put into place that are intended to merge all these publicly accountable agencies into centralised executive branches of multiple remit agencies. Those will be only accountable to central government and the Prime Minister. The public then being left to suffer what has been decided without their permission. Or input into or accountability under any remaining Human Rights Act or “Bill of Rights”.

              • Oh, I prefer to have a system where those elected by the majority can put forward the policies they offered to get elected by the majority and then allow consultation whilst they enact. If the majority find that unacceptable, they can then decide to change the situation after a few years. Until then, the majority will get what they voted for and some will be unhappy. That is life-still with rights of thought, speech, action and protest. So, again, buyer beware. There is no intention of a Draconian restriction of all rights.

                But that is the sort of rhetoric produced when some are unhappy. It is their right to state it, others have a right to think it is not correct.

                However, have a good weekend. Looks as if the sun will be shining, and the spring flowers will be springing. In a world with many problems, there is something still to be happy about.

                • On the contrary, there is every indication of a draconian restriction of all rights. To quote from the Good Law Project – “ The very purpose of the right to protest is to enable people to register their profound unhappiness or strength of feeling in a way which compels the state to respond. To legislate so that right cannot have any impact is to legislate it out of meaningful existence.”
                  But you prefer a system in which some, the majority, choose – choose all or nothing – and then, having chosen sit back and wait while their rights, but more importantly perhaps the rights of those who have not so chosen, are trampled over.
                  This is the sort of rhetoric produced when those, the non- apathetic who can think, declare themselves freely.
                  To curtail and limit this right to protest and compel the state to respond, the intention of the Bill of Rights, is to pave the way for a system which plans permanent rule for itself,for a system that will make it impossible to “change the system after a few years”. “The price of freedom is eternal vigilance.” (Churchill) This government’s administrative boundary changes will facilitate perpetual rule.
                  Wake up, lift your eyes from your courgette plot and look at the world around you, where “The only reliable, durable and perpetual guarantor of independence is profit.” (James Murdoch) and the only regulator is the market. Look at what is happening in Putin’s Russia. Do I need to spell this out for you?

                • Well, 1720, the statement from the Good Law Project would support suicide bombers, so unless you are in agreement with that, there are obviously controls that need to be exerted to protect the rights of others.

                  You really ought to consider what words may mean to a few, and what they mean to the many. What they mean to the many usually dictates the legislation, plus what they then think about organizations like the Good Law Project who make such silly statements.

                  There is no way that UK legislation can not be amended as time goes by. This Government is intending to amend legislation, another one will do the same. The legislation is always possible to amend, otherwise there would be no need for elections. That is how new Governments get elected, by offering new legislation. New, New, Labour may learn that one day. I have “enjoyed” many UK Governments during my time. I was happy about some legislation, unhappy about some other legislation. Goodness, I have even protested about some legislation, then some years later looked back, and thought that it was pretty sensible legislation.

                  By the way, my courgette plot will remove profit from the system! Another contradiction offered by yourself. Arithmetic is assisted if plus and minus are sorted. Today, I plant my celeriac, which will remove more profit from the system. And, by transferring production to a local source, cut down on transport emissions. (Thanks for that opportunity.)

                  I can see why you find so much to protest about when you are unable to separate your wish to make a point from fact. Perhaps it is your sort of protest that needs some legislating? “We” could always have a protest to protect the OED!

                • PS:

                  The boundary changes you refer to are decided by an independent body, and are long overdue, to reflect changes in population within areas so that a vote in one area is equal value to one in another. All very democratic, and done on a regular basis to keep democracy as fair as it can be.

                  If the system has constituencies, then those should be regularly up-dated to make sure they continue to reflect equal opportunities within the voting system.

                  Yes, those who have had an advantage because that has been long overdue, will be unhappy. Those who were unhappy because they had a disadvantage will now be happier. Such is life. Lib Dems will still be unhappy when they see how many votes they get and how few seats, compared to the SNP, but taking into account how little time the Lib Dems spend in the HoC, then it may not get a lot of sympathy.

              • I disagree “with the disempowerment of the Environment Agency”. This should not be happening. The EA should have more power, or at least, existing powers should be utilised as designed, and they should prosecute all cases which are warranted, not just a few that management and or political stooges let through. All river / sea pollution incidents should be pursued and prosecuted. I do not agree with light touch enforcement by any entity, warning letters, reprimands, do better next time etc etc. This applies to the EA / HSE / NE / the Police.

                • Yes, then I agree with you disagreeing. Sorry for the misunderstanding. I thought you meant that you disagree with me, for saying that the Environment Agency is being disempowered. But you didnt. Thanks for clearing that up. I also agree with the objection to the disempowerment of the Environment Agency.

                  [Text amended at poster’s request]

        • Ref. Martin’s response early this morning in which he casts doubt upon my assertion that Patel considered using the navy to repulse asylum seekers, the truth can be found anywhere with a bit of googling, an aid with which he is familiar, Take this from LBC Jan 18 (but passim) –
          “The Royal Navy has rejected the Home Secretary’s plans to “push back” migrants trying to reach the UK by crossing the Channel.
          Priti Patel’s plans to tackle the number of boats crossing the Channel were facing renewed criticism today.
          The Ministry of Defence (MoD) is to take over command of the operation from the Border Force, in a move signed off by the Prime Minister.
          But according to the Times, the Royal Navy has rejected the plans amid concerns that they are illegal and could lead to the death of more migrants.
          Instead they will continue to ensure that people making the journey will arrive at shore safely”
          Remember my assertion, that Patel has “considered” using the navy in this way.
          Martin’s attempts to discredit my posts by using my points against me whilst deliberately misconstruing or representing them is mendacious and tiresome. This applies also to an egregious unwillingness to address the main points rather than nit-picking the minor points thus trying to divert attention from the main points. The examples of this in the current international climate are very worrying and should not go unremarked.
          I think it important not to address the other slurs and fabrications.

          • “Take over command “.

            Your own words, 1720, from LBC. “They will ensure people arrive safely”. Times.

            Indeed they will. They will also be able to identify people setting out on the journey and risking their lives and be able to co-ordinate Border Force and French authorities to intercept.

            All very sensible and long overdue. I have no problem with that, you seem to. Perhaps you think by trying to divert into a snow flake defence avoids your inflammatory use of the word “repulse”. The whole reason behind trying to prevent this route of illegal migration is that it is funding criminals and extremely dangerous to those using the route, with recent deaths demonstrating that fact. It is also restricting the opportunities for those who wish to come to this country legally, who would then be cleared for security reasons and the potential introduction of Covid variants, and then be rapidly integrated into UK society.

            [Edited by moderator]

            • To use your own words “bless!” Gullibility has no bounds. Try reading my post again and mug up on a few facts which might certainly save me a lot of time.
              The plan was to use the Navy to repulse – (nothing inflammatory about the word apart from the repulsive plan) – the refugees who use this method precisely because legal methods of arrival do not in fact exist for most of them, not because they prefer a boat trip. Fortunately the Navy, moral compass intact, refused Patel’s plans. Keep up with these arguments, Martin; it’s good to be able to understand the underlying ignorance when confronted by your other authoritative statements and incomprehensible assertions – take for example the third sentence of your final paragraph. How does one “divert into a snowflake” to avoid a word?
              I’ve had enough of this. Post away.

  5. Hi Paul, thanks for your important contribution.

    The government has indeed stripped the Environmental Agency EA of most of their staff, and therefore illegal discharges of untreated raw sewage and pesticides etc by the water companies is generally ignored by the hard-pressed EA staff in the North-West, and likewise the dumping operations of waste criminals across the region.

    Regarding the EA and air pollution, the task of monitoring the NO2 air quality management areas (AQMA) in NW England is “devolved” to the relatively large pool of highway engineers of the local authorities.

    Robin Grayson FGS
    Liberal Democrats, Manchester

  6. Do you have any inside information on the future transformation of the erstwhile publicly accountable agencies such as the Environment Agency, Robin and Paul?

    And what is the Liberal democrat position on the changes to the Human Rights Act and the formation of the delimitations of a new “Bill of Rights” consultation coming to an end on 8th March 2022?

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