Balcombe Primary School Consultation Responses


Balcombe Primary School has raised concerns regarding the February 2014 Planning Application and April 2017 Environmental Permit Consultation as follows:


Response to Cuadrilla Balcombe - Enviornmental Permit Consultation - April 2017

Re: Cuadrilla Balcombe Permit Variation and Basic Surrender

In response to the Application from Cuadrilla Balcombe Limited at their Lower Stumble Hydrocarbon Exploration Site, this letter outlines the reservations and additional information that the Board of Governors are requesting to ensure the safety of the children and staff of Balcombe school.  By way of background, Balcombe School is a Church of England Primary School located in the village of Balcombe, approximately 1 kilometre from the exploration site and situated directly on the main road through the village (B2036).  We have approximately 145 pupils in attendance daily and employ over 25 staff.  We are responding to the consultation as part of our safeguarding obligations for the pupils and staff.

We would like to focus on two issues, 1) the issue of transportation of waste materials by Heavy Goods Vehicles on the B2036 which is adjacent to the school and 2) the emission of waste gases into the atmosphere.  In terms of the transportation of waste material, the school is located on a junction whereby the front of the school is also the intersection for traffic joining the B2036 from Haywards Heath (ie a major commuter route for travel north to join the A23/M23). 

The Waste Management Plan refers to an Environmental Risk Assessment (Section 7.0) submitted with the application that states that waste material will be transported via an EA authorised haulage company (Risk Assessment Table Balcombe Exploration Pad HSE–Permit-Bal-003, Page 61 Risk “Transportation of waste materials/liquids) and that a travel plan will be utilised.  However there is no description of the travel plan nor of the routes the vehicles are expected to take. If these vehicles are not routed to the south of Balcombe, they will pass directly adjacent to the school, where there is an open, outside educational area in the front of the school for two classrooms of children, separated from the 

roadway by a rail fence and a pavement.  The classrooms themselves are only approximately 5 metres from the roadside.

In addition, there is no indication that any of the HGV movements will occur outside of school hours.  Therefore it must be assumed that the majority, if not all, of these movements will occur while the school is attended by pupils and staff.  Further, there is no explicit mention of the management or monitoring to be established for the transport of the waste from the site to such a facility, nor does the application provide any detail of the emergency procedures in the event of accident or spill.

Alternatively, the HGV movements could be redirected south on the B2036 to connect with the B2115, which passes to the north of Cuckfield (a route that avoids significantly built up areas and populated buildings such as schools).  Given the proximity of the school, and that outdoor areas which will be used by the children are located at the front of the school, next to the B2036, the Governors have the following questions and concerns:

  • What are the detailed management and monitoring controls over transport of materials to the site and from the site to the external processing facility, including any speed restrictions?
  • Is it confirmed that the HGV movements includes return journeys and will the HGVs be escorted by vehicles equipped to deal with emergencies?
  • Will the travel plans preclude transport of materials through Balcombe on the B2036 during periods when children and staff are in attendance at the school, or alternatively redirect the transport to occur south of Balcombe on the B2036 by connecting with the A23 via the B2115?
  • What are the emergency procedures in place for a spill that occurs next to a heavily occupied location, such as the school?
  • Has either the Applicant conducted a risk assessment to explicitly consider the risks associated with contact with materials being transported should a spill occur, and if so, can it shared with the school leadership?
  • In respect of the venting/flaring of waste gases into the atmosphere, there are several references in the Risk Assessment Table to the flaring of gas.  It appears that the mitigation centres around the short period of activity and the use of flaring the emission gases.  There is no requirement to monitor all gases that may be released during the test, nor is there any requirement to independently monitor gas emissions in and around the school.  The Governors are concerned that the absence of such monitoring of gas emissions that could impact the school creates a substantial risk to the children and staff. 

    The Governors would request clarification on the gas emissions monitoring process and how it has been specifically adapted to reduce the risk to the children and staff in attendance at the school.

    Conclusion

    In conclusion, we would request that assurance be provided in respect of the above questions before the application is granted and that, if it is to be granted, it is done so in a way that:

    1. stipulates that HGV movements do not occur past the school during periods when the children and staff are in attendance, either by placing constraints on the timing of movements or by altering the route to avoid Balcombe Primary School, and 

    2. requires specific, independent assessment and monitoring of the gas emissions in respect of potential risk to the children and staff of the school.

    Yours sincerely

    On behalf of the Governors

    Balcombe CE (C) Primary School


    Response to Planning Application WSCC/005/14/BA

    15 February 2014

    Strategic Planning
    West Sussex County Council
    County Hall
    Chichester
    West Sussex
    P019 1RH

    Dear Sirs,

    Re: Planning Application WSCC/005/14/BA
    Temporary permission for exploration and appraisal comprising the flow testing and monitoring of the existing hydrocarbon lateral borehole along with site security fencing, the provision of an enclosed testing flare and site restoration.

    In Response to the Planning Application from Cuadrilla Balcombe Limited at their Lower Stumble Hydrocarbon Exploration site, this letter outlines the reservations and additional information that the Board of Governors are requesting to ensure the safety of the children and staff of Balcombe school. By way of background, Balcombe school is a Church of England Primary School located in the village of Balcombe, approximately 1 kilometre from the exploration site and situated on the main road through the villa (B2036). We have approximately 140 pupils in attendance daily and employ over 25 staff. We are responding to the consultation as part of our safeguarding obligations for the pupils and staff.

    We would like to focus on the issue of transportation of materials by Heavy Good Vehicles on the B2036 which is adjacent to the school. In additional, in front of the school is also the intersection for traffic joining the B2036 from Haywards Heath (ie a major commuter route for travel north to join the A23/M23).

    The application (Secion 3,4, page 10) explicitly staes that "All heavy goods vehicles associated with the proposed development will access the sire via Junction 10a of the M23 motorway, and not from the South via Cuckfield". Further, it also states (Section 5.2.3, page 27) that "This application is not accompanied by a Transport Assessment, since the likely traffic movements associated with it are not likely to be significant and will, where possible, avoid peak traffic flow periods. The site benefits from good highway access and visibility from the B2036, and HGVs will be routed so that they access the site from the north, thereby avoiding the village of Cuckfield to the south".

    This will entail at least 210 HGV movement past the school, with 69 movements (appendix B - Testing Operations and Transport Loads) occurring during the Flow Test stage which entails transport of waster, including hydrochloric acid. These 69 movements are scheduled to occur over a 14 day period (Table 3.3, page 9). Each of these will pass directly adjacent to the school, where there is an open, outside educational area in the front of the school for two classrooms of children, separated from the roadway by a rail fence and a pavement. The classrooms themselves are only approximately 5 metres from the roadside.

    There is no indication that any of the HGV movements will occur outside of school hours. Therefore it must be assumed that the majority, if not all, of these movements will occur while the school is attended by pupils and staff. Further, the application goes on to state (Section 4.5, page 19) that "All waste materials, including wastewater and fluids,.. from the exploration well testing operations would be removed by licensed operations and disposed of at an authorised waste treatment facilities that are permitted to accept and treat the waste.". However, there is no explicit mention of the management or monitoring to be established for the transport of waste from the site to such a facility, nor does the application provide any detail of the emergency procedures in the event of accident or spill.

    Alternatively, the HGV movement could be redirected south on the B2036 to connect with the B2115, which passes to the north of Cuckfield (a route that avoids significantly built up areas and populated building such as schools). Given the proximity of the school, and that outdoor areas which will be used by the children are located at the from of the school, next to the B2036, the Governors have the following questions and concerns:

    • What are the detailed management and monitoring controls over transport of materials to the site and from the site to the external processing facility, including any speed restrictions?
    • Is it confirmed that the 210 HGV movements includes return journeys and will the HGVs be escorted by vehicles equipped to deal with emergencies?
    • Will the travel plans preclude transport of materials through Balcombe on the B2036 during periods when children and staff are in attendance at the school, or alternatively redirect the transport to occur south of Balcombe on the B2036 by connecting with the A23 via the B2115?
    • What are the emergency procedures in place for a spill that occurs next to a heavily occupied location, such as the school?
    • In the absence of a Transport Assessment, has either the Applicant or the appropriate West Sussex Council authorities conducted a risk assessment to explicitly consider the risks associated with contact with materials being transported should a spill, occur, and if so, can it be shared with the school leadership?

    Conclusion

    In conclusion, we would request that assurance be provided in respect of the above questions before the planning application is granted and that, if it is to be granted, it is done so in a way that stipulates that HGV movements do not occur past the schol during periods when the children and staff are in attendancem either by placing constraints on the timing of mvoements or by altering the route to avoid Balcombe Primary Schoo.

    Thank you for your consideration of these matters.

    Your sincerely
    Chair of Governors
    Balcombe CE (C) Primary School