SUMMING UP - Pamprotest P.A.M. Canvey Island People Against Methane, Say No To The New Canvey Island Terminal

The HSE was criticised at that time for seeming to adopt a too higher level of acceptable risk in their conclusions. However an important point stemming from the Canvey studies and in the 1992 Tolerance of Risk Document is that when several sites contribute to the risk born by an off site individual the aggregated fatality risk must be as low as reasonably practicable.

MAJOR HAZARDOUS INSTALLATIONS is the term given to the industrial sites that because of the nature and the quantity of the substances present have the potential that could cause serious harm to people on site and the surrounding area i.e. SOCIETAL RISK.

Liquefied Petroleum Gas (LPG) and Liquefied Natural Gas (LNG Storage)

Sites where highly flammable liquids are used stored and distributed.

The hazards presented by such installations can extend beyond their site boundaries and can impact on surrounding communities. The effects depend on the type of installation. These examples include the possible release of a cloud of toxic gas, fire or vapour cloud explosion from the flammable substances.

The introduction of COMAH has meant that in the past few years hazardous site operators have to provide to the HSE additional information about the potential effects of major accidents at their sites, and information about the likelihood of how the effects might be felt off site and consequently how much harm may be caused to people in the event of an incident.

The HSE should use the information it has been given to estimate the societal risk from sites such as CALOR GAS site.

The obvious weakness in this process is that the information provided by such installations cannot be understated and should be given as a worse case scenario.

This does not seem to be the case with the Calor Gas Company to date.

Societal risk differs from individual risk in that it has to take into account the total number of people who may be harmed at the same time by a single incident.

NOTE (The HSE have to use the information from site operators to make a fairly quick but approximate estimate of the societal risk levels) accordingly these estimates should be treated with some caution.

The level of societal risk from an installation is primarily determined by 3 factors.

1. The probability of an incident occurring at a major hazard site or other sites close by. (DOMINO EFFECT).

2. The nature of the incident

3. The density and location of the population working or living in or around the site. This is to include their vulnerability i.e. schools

H.I.D. Hazardous Installations Directorate in exercising their duties attaches more

Weight to consequences where a hazard has attributes which make it likely

that it will give rise to societal risk where there is potential for severe

Detriment, for example: an explosion in a built up area.

However gauging the extent of the societal risk caused by such a hazard is likely to be a major consideration when deciding if the costs of risk reduction are grossly disproportionate or not.

(SO THERE IS A LIMIT TO THE COST OF WHAT IS DEEMED TO BE

PRECAUTIONARY MEASURES)

It is accepted that developing criteria on tolerability of risk for hazards giving rise to societal concerns is difficult.

Hazards giving rise to such concerns often involve a wide range of events with an even wider range of possible outcomes.

How can you expect society to take the Risk that those using calculations and graphs in developing a criteria have got it right when the Hazardous Installations Directorate proposes that it would take an incident causing the death of 50 people or more in a single event before it should be regarded as being intolerable with the frequency estimated as being more than 1 in 5000 per annum.

This is unacceptable!

The combination of there being several issues contributing to the societal risk of Canvey Islanders ( the controls of which are inherently so difficult) promotes the feeling locally that it is not possible to find reasonable control measures or suitably achievable offsite emergency action plans that we can confidently and safely rely upon.

Consequently it is not possible to allay our concerns about these risks regardless of the control measures you may feel brings the societal risks down to as low as reasonably practicable.

We are not confident that the measures that this project provides for safety controls would always be observed.

We believe that we have been complacent about the risks that the Calor Gas Terminal has presented to us for a number of years, bearing in mind its age and condition.

We take this opportunity to express that we have grave doubts that the risk that this site poses should be entertained at all.

In light of the Buncefield incident our confidence in the provisions and processes in place for protecting people against such risks and the institutions responsible for setting out and enforcing safety systems and arrangements has been seriously damaged.

Resources ensuring that the HSE can carry out their duties competently have been cut back year after year.

Society is no longer confident that those responsible for these types of hazard controls are acting proactively in an effort to ensure that safety systems are being maintained and improved where necessary.

The reactive approach culminating in safety reports and lessons learnt gives no comfort to the victims of the issues being investigated.

The residents of Canvey Island will not and do not intend to be the subject of such a report of things that have gone wrong causing a catastrophic result.

We do not intend to expose ourselves to any additional risks in order to satisfy the Government’s response to its future energy plans.

We feel sure that the rest of society and the Nation in general would not expect such a sacrifice of their behalf.

SHIPPING LNG AND THE PORT OF LONDON AUTHORITY

Within its responsibilities as a public trust the PLA must consider the needs and interests of all stakeholders from commercial ship and port operators through to leisure users, Local Authorities and residents along the river bank, as well as a responsibility to all its employees in their work places with particular issues to those that actually work on the river.

The PLA is responsible to 95 miles of the River Thames from Teddington Lock in the west of London to the outer estuary.

Throughout that area there are more than 70 different terminals for cargo ships including several top tier COMAH sites.

The PLA manage the various and differing types of hazards transported in huge quantities throughout its navigational responsibilities.

The Port of London Authorities (PLA) top priorities therefore is navigational safety security and environmental issues whilst providing the right support to commercial shipping operators so that they can achieve efficient turnarounds and avoid unnecessarily expensive delays to their vessels.

The Thames and its mooring facilities could justifiably be viewed as a top tier COMAH site in its own right.

The PLA is responsible for co-ordinating the needs of more than 30000 vessel movements per year within its jurisdiction. Consideration also has to be given to the increase that would be brought about by the new deep water port at the Shell Haven site.

There are proposed increased movements of petroleum products and of course consideration needs to be given to the LNG terminal at the Isle of Grain site when considering the hazardous nature of shipping on the Thames.

The PLA have invested heavily in technical advances to ensure safe movement of vessels on the Thames. This new system works around the clock to co-ordinate movements of commercial shipping on the river so ensuring navigational safety and efficiency.

This will be presented no doubt to reassure us that the PLA have complete management of the potential hazards from the various industrial by products. I am sure however, that the PLA would agree that having communications and visual display facilities of vessels through their advanced computer system does not mean THAT THEY HAVE FULL CONTROL OVER THESE VESSELS .

The PLA are well aware of the proposal for the Calor Gas site to be turned into an LNG facility as they have taken an active role being commissioned by the consortium behind this proposal in dealing with the natural environmental issues and we assume that they have taken risk assessments on behalf of their employees that identify the potential hazards and situations, presented by LNG shipping, receiving and vaporization facilities.

These risk assessments need to take in the worse case scenario hazards that may confront their employees with particular attention to the docking and mooring process of LNG vessels.

The risk assessment process should include emergency action plans and adequate protection facilities in the case of a spillage of LNG over water.

In the unlikely event of an LNG release from a carrier its contact with the water or any warmer substance such as air, would cause the LNG to evaporate very rapidly (vaporize) returning to its original gaseous state.

As the LNG vaporizes a vapour cloud, resembling ground fog will form under relatively calm atmospheric conditions.

The vapour cloud is initially heavier than air since it is so cold that it would cause skin burns.

As the LNG absorbs more heat it becomes lighter than air causing it to rise and travel with the wind.

LNG vapour clouds are flammable within the portion of the cloud where the concentration of natural gas is between five and fifteen percent by volume and mixture with air.

This will ignite when this proportion of vapour cloud comes into contact with an ignition source.

The PLA when considering and risk assessing for the safety of their personnel will have to include in their emergency action plan, detailing the actions to be taken for the events considered most likely to result in a significant release of LNG on water. Feasible situations as follows:-

1. An outbound vessel ha collided with an inbound LNG tanker.

2. An inbound LNG tanker collides with its terminal jetty and structure causing damage to the containment of LNG

3. A vessel colliding with an LNG tanker whilst on its moorings at the terminal

4. Grounding of a tanker whilst on its moorings due to low tide or silt back fill causing the vessel to list either onto or away from its moorings whilst connected to the transportation infrastructure (pipe-work under pressure)

For the inspectorate to be satisfied that societal risk will not be compromised by LNG tankers delivering their cargoes, the PLA safety procedures will have to be suitable for purpose and be appropriately audited to identify that review and revise procedures will been undertaken.

Security measures will also need to be clearly defined within the risk assessment to ensure that intentional spillage of LNG through terrorist activities can be limited to as little as possible.

Risk assessments for the outcome of a large spillage of LNG over water can only be the subject of guesswork.

Currently the potential for an LNG cargo tank breech whether accidentally or intentionally is not fully understood, particularly with regard to the dynamics and dispersions of a large spill and its hazardous outcomes.

There are two primary reasons for this assumption, firstly the combination of current LNG ship designs and safety management practices have to an extent prevented observations from historical or empirical information on the consequences of a large spill of LNG.

Secondly the only experimental data on LNG and its dispersion over water to date deals with a relatively small amount of gas which does not reflect the possible outcome of an intentional or unintentional breech of containment.

The PLA within its risk assessment when considering the safety of its personnel would be wise to consider that an area such as Canvey Island which comes into contact with a large LNG spill would have dire consequences from the impact of thermal radiation creating a severe public safety and environmental hazard.

The nearby OIKOS (top tier COMAH site) should be of extreme concern as a consequence of its infrastructure being involved in such an impact would be catastrophic.

SIGNIFICANT ADVERSE IMPACT

The Calor Gas consortium’s website refers to the historical consideration that exists with their site, it having been DISCREETLY LOCATED as being a consideration as to why Canvey residents should accept their proposal.

It is difficult to comprehend how this proposed development by reason of the height scale and mass of the storage tanks could ever be considered as being DISCREET

Although the proposal, to make it sound acceptable offers us a lesser number of tanks that currently store LPG,

For economic reasons and constructional restrictions, in order to achieve the capacity that they desire, Calor Gas are asking us to accept storage facilities which have a height of 46.3 metres equal to 152 feet or over 15 storey, equivalent to 3 times the height of the existing tanks. The proposed tanks will have a diameter of 83.6 metres equal to 274 ft 3 in and again almost three times the width of the existing tanks. HARDLY DISCREET!

On the LNG website the question ‘How would the site look?’ is depicted by computer aided diagram which is at best misleading. These describe the storage tanks as being approximately 10 metres 32 ft 6in higher than the existing tanks.

In terms of the local impact of this proposal, it is considered that these new storage tanks, by reason of their size and appearance and over dominance, have a significant adverse impact to the residents of Canvey Island.

The consequences of this significant increase in scale will mean that this site as exists, will turn from a relatively low impact feature (discreetly located), which while visible over a long distance is a least capable of being screened with some degree of success by trees, into a substantial eyesore on the wider landscape.

It will be incapable of being successfully screened, giving Canvey Island the legacy of appearing as a highly industrialised site.

The structures will dominate not only the area immediately adjacent to the site but from long distant views of the entire Island, changing not only the character of the immediate area but also the perception of the Island from as far a field as Kent from where these 150ft monstrosities will be easily seen.

This is completely at odds with the current recessive development of the site, and is unacceptable in terms of impact not only to the appearance of the site but also to Canvey Island.

Statutory Instrument S.I. No. 476 of 2000

European Community (Control of Major Accidents Hazards involving Dangerous Substances)

Regulations 2000 SEVESO II Directive

Regulation 8 (2) requires an establishment such as Calor Gas Company to provide such evidence (including documentation) to prove that they have:

(a) Identified the major accident hazard.

(b) Taken all necessary measures to comply with these regulations.

Regulation 19 (1) (a) Information For The Safety of the Public

An Operator of an establishment shall inform persons (other than persons working at the establishment) who is likely to be habitually (we consider this to be the whole of Canvey Island) in the specified area of safety measures and the correct behaviour which should be adopted in the event of a major accident.

Regulation 19 (3) requires the operator shall ensure that the information referred to in paragraph 1 (a) “Information for the Safety of the Public” is supplied without such persons i.e. occupiers and residents having to request it, we believe that this has not been complied with.

We believe that there has never been sufficient assessment of the extent and severity of the consequences of a major accident involving LPG and now LNG with regards to the safety of the occupiers of Canvey Island and the surrounding area.

European legislation is fundamentally linked to the Control of Major Accidents Hazards Regulations (COMAH) which aims to prevent and limit the consequences to people and the environment of any accident which may occur at a COMAH site.

Regulation 10 Offsite Emergency Plan

The emergency plans objectives are detailed on page 50. They are of particular interest to this application with regard to Canvey Island.

Local Authority is required to prepare an emergency plan (Off-site) in respect of establishments such as this.

However they cannot complete this task without obtaining the necessary information from the operators. This information would not normally be the entire safety report.

The operator is obliged to provide information which is relevant to preparing the Off-site Emergency Plan, such as details of accident consequences which should include information about the potential effects of a major accident at their sites, their likelihood, how far the effects might be felt, and how much harm might be caused to people in the event of such an incident.

Paragraph 260 identifies the issues of DOMINO sites.

These are sites where the likelihood or consequences of a major accident may be increased because of the location and proximity of other COMAH establishments with their associated dangerous substances.

This situation with regard to the Calor Gas Site needs special consideration in terms of emergency planning, and the testing of the Off-site response.

It is worth noting here that the situation of Canvey Island where it’s occupants evacuation would be a logistical nightmare, that the comment within this section

AT SOME ESTABLISHMENTS IMPACTS MAY BE TOO MANY AND VARIED FOR DEDICATED ARRANGEMENTS TO BE MADE IN ADVANCE FOR EVERY SCENARIO may well indicate that it isn’t possible to provide Canvey Island with a suitable and sufficient Off-site emergency plan for a vapour cloud explosion and therefore we should not be put to this risk at all.

In the case of the above off-site plans should go as far as arranging for sampling and analysis in order to assess actual impact in bringing together key stakeholders and resources to agree priorities for community clean-up and restoration. AN AFTER EVENT PROCESS.

Paragraph 252 deals with remedial measures which include removing dead animals. If this proposal is accepted and there is such an event as a vapour cloud explosion, or an event which would normally cause evacuation of a large area you would need to add, as part of the remedial action the removal of HUMAN REMAINS.

It has been quoted by the HSE that some establishments are reluctant to provide a worse case scenario because this information would have to be made available to the public.

Guidance For Local Authorities for Dealing with Requests under the Freedom of Information Act

This document states that consideration of withholding information on the grounds of National Security is not intended to interfere with Companies complying with their legal obligation under relevant regulatory regimes to inform their employees and where required members of the public of actions to be taken in the event of an emergency situation.

It states that it is Government policy to inform the public of the robust measures that are in place to avoid or minimise the risk of incidents at Major Hazardous sites.

There is however a significant needs to maintain national security and public safety by minimising the risk of a successful attack on these sites.

This means that each request for information has to be considered on its merit, and the appropriateness of applying exemptions will depend on specific requests and the nature of the information.

Should the details to be taken in the event of an incident that affects individuals on an off-site basis not be readily available, then this would imply that it is being withheld on the GROUNDS OF NATIONAL SECURITY.

When dealing with National Security we deal with the threat of a terrorist attack extensively on pages 16 to 24 on our main proof of evidence. We also provide a 160 page document to emphasise this issue.

There are two reasons why a terrorist would be interested in attacking an LNG tanker or LNG terminal such as that proposed by the Calor Gas Consortium for Canvey Island, both of which fit the modus operandi undertaken by Al Qaeda, For example :-

1. The potential to bring substantial damages to the energy infrastructure by creating the domino effect type disaster, not only on Canvey Island but all along the Thames estuary. Thus blighting the energy industry for years.

2. High civilian casualties especially in highly populated areas such as the Thames Estuary and in particular the dense population of 40,000 people close to the Calor Gas site presented as a target on Canvey Island.

The types of information which it may be appropriate to withhold include

1 Detailed description of the site such as the precise location of storage tanks

2 Actual volumes of materials stored

3 Detailed information about pipelines and associated storage systems

4 Details of safety measures on site

5 Safety equipment and emergency response equipment

Unfortunately this information is already readily available on the Calor LNG website, linked the fact that it is well known that Canvey Island has not the infrastructure that would support a successful emergency evacuation for the forty to fifty thousand occupants, making this an extremely attractive and easy target for terrorism.

The Calor Gas Community Safety and Emergency Plans Document (revised March 2005)

This document does not promote confidence to the residents and occupants of Canvey Island for the following reasons

Section 9.19 Public Warning Provisions

There is no public warning system for Canvey Island although it is noted that the on-site siren can be heard off-site although the distance is quite limited.

15.1 identifies public consultation distance of 900 meters but the assessment for explosion effects is for 2km This takes into the hazard area much greater residential and associated facilities such as schools shops old peoples homes and public buildings for which no off-site provisions have been made.

15.2 Prior Public Information.

Calor Gas declares that they send out approximately every three years public information letters to persons residing in the Public Information zone and beyond.

There is no evidence of this ever having been carried out. We will be providing evidence to substantiate our statements.

15.3 Potential Accident Scenario

When information was requested about this issue from the local authority it was withheld on the grounds of NATIONAL SECURITY

15.4 Potential impact to Persons Off-site

Again when information was requested it was withheld on the grounds of NATIONAL SECURITY

15.5 Impact to Adjoining Industry

We are told it is anticipated that off-site areas which could be affected by thermal radiation generated in a fire includes parts of the adjacent industrial site to the West. (This is the COMAH site OIKOS which would have a serious DOMINO effect. This has not been accounted for in this safety plan.) The sewage works to the East and the farmland to the North.

This fails to identify other areas that would be affected such as the Football Club, housing, and environmental issues.

16.1 When will this plan be activated?

This plan will be activated in the event of a major incident at the Gas Terminal which has escalated off-site. Such an incident is likely to result in public warnings being issued and emergency evacuation of residential and industrial premises.

The evacuation process in this document only provides for the evacuation to other parts of the Island.

We would suggest that for an incident of an LPG escape to have escalated to the extent of 2km this would result in a VAPOUR CLOUD EXPLOSION, and remaining on the Island may then not be appropriate.

A study carried out in 1972 that surveyed the previous 42 years produced a list of no fewer than 108 incidents on “Unconfined Vapour Clouds” which had occurred, costing 386 lives, those incidents have increased at a significant rate from 4 in one decade to over 65 in one decade (this equates to an increase of 1,500 per cent in Unconfined Vapour Cloud incidents)

OTHER DOCUMENTS DEALING WITH MAJOR INCIDENTS

Essex Resilience Forum Document COPE (Combined Operational Procedure for Essex)

Updated October 2006

These are reactive documents only dealing with the aftermath of the consequences of a disastrous incident!!!

NATIONAL INTEREST

One of the main questions that have been posed is, What is in it for the Calor Gas Company?

Could it be that the existing site has passed it’s sell by date and is in need of regeneration in the very near future?

The proposition of a new large LPG storage tank with the associated infrastructure offered as part of the deal that allowed LNG storage and new pipe lines as part of this site too good to pass up.

The next question would be ‘What’s in it for Centrica and the remainder of the consortium?’

The publication ‘Our Energy Challenge’ Ofgem’s response April 2006 page 46

Item 1.27 and 1.28 gives us some indication as to the answer to this question.

1.27 states that the value that the energy market places on these facilities (being LNG storage facilities) which provide high levels of deliverability on a few occasions per year, is apparent from the level of interest shown by the market participants in LNG storage capacity auctions.

For the past 3 years all of the available LNG capacity has been sold at each of these facilities. In addition the amount that the market is willing to pay for this capacity has increased year on year and in a more recent auction the capacity was over subscribed

1.28 In response to high gas prices a number of new LNG storage facilities are planned or under construction. The Canvey Calor Gas site being one of them, which is shown as expected to come on stream in the Ofgem response by 2010.

In November 2005 the government ordered an enquiry into whether there was going to be enough gas to keep

Britain

going in the Winter of that year.

There was concern that the

would run short of its gas supply in the event of a prolonged cold snap.

Spot prices in the wholesale gas market virtually doubled within a few weeks as traders feared that there would not be sufficient capacity to meet demand.

Reports were commissioned to look into the possibility for large industry and power stations to cut their gas consumption to safeguard domestic supplies.

A further report would examine as to what effects on the economy would be as a consequence of a reduction in output.

In its Winter outlook report the National Grid forecast that the UK should be able to withstand the kind of Siberian Winter experienced every 50 years or so, but in that case it said that the country’s 1,750 largest industrial users and gas fired power stations would need to halve their gas consumption.

Enquiries revealed that a number of factors caused a surge in gas prices over the previous weeks. Firstly operators had begun to draw supplies from Centrica’s Rough gas storage facility in the North Sea unusually early. This facility holds enough gas to supply one tenth of the country’s needs for three months.

Secondly shipments of LNG heading towards the Isle of Grain terminal had been diverted to the USA and

Spain

where they had attracted higher prices.

Thirdly there were technical problems (now resolved) that halved the capacity of the gas pipeline between Bacton on the east coast and Zeebrugge in

Belgium

which is used to import gas from the continent.

Clearly these sets of circumstances and the knowledge that the North Sea supply is diminishing has prompted the government to look at the storage of LNG as a solution to securing the Country’s supply.

Centrica Storage Ltd own and manage the largest off shore platform at Rough and its Easington terminal. Rough is a significant provider of seasonal swing capacity, allowing gas suppliers to support varying levels of demand permitting producers to convert cheap Summer gas into more valuable Winter gas thus maintaining the nations supply at a profit. The question then is why more storage facilities are not provided offshore in installations such as the Rough Platform safely away from societal risk?

SADLY the vulnerability of this option became apparent when in February 2006 an incident on the Bravo platform in Centrica’s Rough Field installation involving a fire, left 2 persons injured, causing the gas platform to be partially evacuated and a complete shutdown of this major gas supply.

London Reuters reported 16^th February 2006 that the gas prices had jumped 50 percent on news of the Rough Storage shutdown, thus increasing the value of the gas stored in the tanks at installations such as the one proposed at Canvey Island. This again artificially manipulated the value of stored gas causing the consumer an increase in the price they would have to pay.

Is it in the Nations interest to allow energy suppliers the power to control gas prices in this way? Despite what controls Ofgem may impose.

Is the Canvey proposal only a money making venture where the Calor Gas consortium cannot lose?

WHY IS IT IN THE NATIONAL INTEREST FOR THE CANVEY STORAGE PROVISIONS TO GO AHEAD?

‘Our Energy Challenge’ Ofgem’s response document shows the number of existing installations on tables 1.3 UK Import Projects 1.4 Future LNG Import Facilities and 1.7 Future Storage Projects a combination of all these should be more than adequate storage for the country’s requirements for the foreseeable future without the inclusion of this Canvey Island terminal, thus avoiding additional societal risk to the Canvey Island residents over and above those with which they already have to contend.

At the LNG presentation held at the Paddocks January 2006.

We were told by the Canvey LNG partners that they had submitted their detailed planning application together with an environmental assessment to Castle Point Borough council in January 2006 and that they were confident that the proposal would be approved having received feedback from the Government that this development was very much in the national interest.

When asked would you appeal if this proposal was not given planning permission they said yes and subsequently duly did so on the last day for appeals to be submitted. (Showing not best integrity to the people of Canvey Island) having falsely given some of them the impression that this issue had been resolved and their anxiety was no longer valid.

They believed the comment by the LNG consortium that they constantly state in all their communications that they would not progress with any development on this site that would increase the risk to the local community.

This statement of course highlighted the fact that there is a risk at this site that had gone unrecognised by the community for some time.

The consortium did not explain that their confidence of success for this project was founded upon Governmental intervention, this being substantiated by the inclusion of the Canvey Island Calor Gas project being in the initial stages of development in the document Our Energy Challenge table 1.4 future LNG imports Ofgem’s response April 2006 way before the decision was rejected at the Castle Point planning sessions.

It is clear in the DTI document Offshore Natural Gas Storage and Liquefied Natural Gas Import Facilities that the government are clearly concerned that they need to encourage gas suppliers to make investments to secure our energy supplies.

In the DTI document Meeting the Energy Challenge a white paper on energy May 2007 chapter 8 planning at page 255 talks of their concerns about uncertainty created by the planning process and although they list examples that may hold up the planning processes they do not consider societal risk to be an issue but notes that extensive delays can create a climate of uncertainty which often makes it difficult to secure capital or continue financing a project that may be delayed, in other words a financial issue rather than a societal need.

It is noted on the footnote of page 255 of the above document that there are other projects that have been refused by their local authorities for whatever reasons.

Although we would note that this would give the government and appropriate departments serious cause for concern about their projected impact on gas supply infrastructures and projects we must emphasise most vigorously that the Canvey Island issue should be assessed in its own merit and not be dragged along with the governments strategy for future gas supplies.

The planning issues in particular SOCIETAL RISK being at the forefront of the decision process. This is an historical issue that has confronted the residents of Canvey Island for some considerable time and it is the collective risk from various hazards that cannot be discounted.

Item 8.4 of the above document refers to the governments improvements to the planning system in recent years both from decisions taken by local authorities and those taken by central government with regard to land use planning.

8.5 of this document refers to planning being consistently one of the top 6 concerns for inward investors in the U.K .

The Barker Review document on page 76 puts a case for a new decision making body to determine applications for major infrastructure in the context of the governments strategic priorities thereby removing the need for ministers to be involved at the end of the decision making process. WE FULLY SUPPORT THIS NOTION for the following reasons:-

Even where National need was clearly established, local circumstances might indicate that the cost of granting planning permission outweighed the benefits. In that case the commission would have the powers to refuse the application it was determining.

The residents of Canvey Island feel that any decision that is made to this issue should be made by an independent planning commission and not by the Secretary of State. Any decision to this application should be deferred until the following have been implemented

The Barker Review Delivering Major Projects in the case for a new decision making body i.e. Independent Planning Commission lists a reason for support for this notion on page 77 as REMOVING SUGESTIONS OF BIAS.

It suggests that by taking ministers out of the decision making process would also remove from the planning process any suggestion of bias and unfairness for example there could be concerns about particular political interests or high profile interest groups influencing decision making under the current system from which an independent planning commission would be comparatively free.

We fully support this notion in light of the Secretary of States decision detailed on the letter 10^th May 2007 that stated that the appeal was to have been decided by an Inspector.

The Secretary of State considers that they should determine the appeal. The letter stated that Secretary of State hereby directs that they shall determine this appeal instead of an appointed person.

This means that instead of a decision, the Inspector will prepare a report, which will be forwarded to the appropriate decision making branch.

This issue in the view of the residents of Canvey Island has always given concern. There being a suggestion of bias resulting from the numerous discussions and consultations between the government departments and the power suppliers.

The Barker Review resolves many issues for the Islands residents and should be given due consideration for governmental approval and used as an example of fair play for this application

The Buncefield Major Incident Investigations board in their initial report published on the 13.07.06 identified 4 principal work streams that would form the basis of their continuing work and developing recommendations (not legal requirement) in due course.

The fact that this process is necessary at all gives credence to the PERCEPTION OF SOCIETAL RISK. The existing process of self regulation through risk assessment policed by the HSE via the COMAH regulations failed drastically, in this case fortuitously without fatalities, but having a huge impact on local residents, businesses and communities further a field.

THIS WAS SURELEY A WAKE-UP CALL WE CANNOT TAKE THE RISK, HOWEVER TOLERABLE THAT SUCH AN INCIDENT FROM A COMAH SITE COULD EVER HAPPEN ON CANVEY ISLAND. WE MAY NOT HAVE THE SAME GOOD FORTUNE.

The Buncefield board state that their report should be carefully considered by all those with a responsibility for COMAH sites with a potential for violent explosions or large complicated fires.

As a community we get little if any comfort from recommendations on emergency preparedness for response to the recovery from incidents and it is clearly recognised that however much preventative standards are improved

It is essential therefore to have in place effective emergency arrangements in the event of such an incident occurring.

LET’S STOP RIGHT THERE SURELY THE BEST SOLUTION TO THIS IS NOT TO PRESENT THE RISK IN THE FIRST PLACE.

In health and safety there are risk controls required to be undertaken by all companies. They are guided by HSE RISK CONTROL HIERARCHY and these are listed as follows :-

This elementary process seeks to find levels of protection and safe systems in order to eliminate and reduce the risks.

There can be no guarantees that any process can be reduced so low as to be eliminated other than removing the hazard completely.

There is no Government Safe Siting Policy for sites such as top tier COMAH establishments.

This factor makes it extremely difficult without government guidelines to state a case where societal risk can be prioritised.

This would give credence to the general opinion that to refuse the planning permission of the Calor Gas Proposal would eliminate the risk to the society that it threatens.

REFUSE THIS PLANNING PERMISION TO THE “CALOR GAS CONSORTIUM” AND YOU WILL REMOVE A MAJOR HAZARD COMPLETELY THAT THREATENS THIS COMMUNITY