BACKGROUND
It was noticed that the site permit on the main gates had changed numbers implying that there had been a transfer of some kind to another holdings company. A breach of the causeway path had taken place in early 2026 and after reporting this to the regulator, we also wondered what recent visits they had made to the site.
WHAT DID WE ASK AND WHAT DID THEY KNOW & DISCUSSION?
“The Environmental Permitting (England & Wales) Regulations 2016. Please confirm if this permit number EPR/LB3306US is a transfer of permit EPR/JB3909LT issued to Solvay Solutions UK limited on 10/3/21.
Please provide a copy of the new permit and its transfer history and the current site operator.”
The EA responded with a zip file, and in order of chronology, we start with the useless SL31 licence with its 33 conditions originally passed in January 1978. This of course was in the Albright and Wilson era, and for the vast majority of its existence, the lagoon served that company and its white phosphorus contaminated waste. Though redacted in this version, the county waste disposal officer was the useless cretin Ken Harvey.
permit issue – Licence to dispose of waste 1978_Redacted
Nothing new about this, and I have broken down the licence conditions HERE a long time ago. Note conditions 10 and 13 however with regards to the current permit breach and flooded causeway path, as I pointed out in the last post. Hopefully, someone in the EA may remember that this permit is actually still in force. Ahem. 😳
Another PDF shows another historic document , the discharge consent to the Birmingham Mainline Canal, transferred several times, again nothing new here, and I have looked at this document before in another FOI request HERE.
03 Mod to consent 6.5.93 (8) with metals and outlet map_Redacted
PERMIT COMPANY TRANSFER HISTORY.
This is where it gets interesting with some new information. The Environmental Permitting Regulations number changed only in 2013, several years after Rhodia had taken over from Albright and Wilson. I find this remiss of the EA in that I believe legally, they or Rhodia should have transferred the licence to Rhodia from day one,, especially given that Rhodia were still actually disposing of waste under this very permit! Why the need to transfer the discharge consent to the canal to Rhodia many years before this?
Permit number EPR/AB3003XX
issued to:
Rhodia UK Limited (“the operator”)
The tie up for the EA may be convenient for them, but it shows poor regulation, arriving at the 2013 cover up works.
NB NONE OF THE CONDITIONS IN THE ORIGINAL LICENCE SL31 WERE DELETED AND THE CONDITION 10 AND 13 WERE NOT AMMENDED EITHER BY THIS NEW PERMIT NUMBER.
The EA missed the transfer PDF as to what happened next, but they previously provided me with that which can be viewed below.
I looked at this in 2021 after seeing the change in site notice HERE.
NB, “The number of the new permit granted to Solvay Solutions UK Limited is
EPR/JB3909LT “
And so to the first missing link and the changes noted to the EPR numbers that subsequently appeared after this time.
Note that the operator “Rhodia UK limited” became “Solvay Solutions UK limited”
Unbeknownst to me, as no updated ID board ever materialised, I believe in another breach of permit regards the site ID board, the permit was transferred again to “Oldbury Energy Solutions (UK) Ltd” in August 2022. This company is a joke non entity of convenience. It cropped up in The Sandwell Local Plan and I had never heard of them, and those who mentioned this name including Sandwell Council were wrong.
This explains the change of EPR number to EPR/LB3306US), but does not explain why this number was not changed when the switch occurred yet again in September 2024 back to “Rhodia Limited”.
THUS WE HAVE GONE BACK IN TIME TO 2014 AGAIN JUST DROPPING THE “UK”.
Permit number EPR/LB3306US
to
Rhodia Limited (“the operator”)
The EA also provided the separate permit transfer of the discharge to the canal, and we see the same company bullshit change with this permit also.
Permit Transfer Notice Issued 25072024 – permit to discharge water from Rattlechain_Redacted
Permit number
T/08/22375/T
A series of transfer deceptions
Further missing links are provided by the following.
“Please state how often environment agency officers visit or monitor this site and a copy of the most recent visit observations from June 2025-February 2026.”
There is much to break down here, as well as the too frankly lazy and relaxed “regulation” of this hazardous waste site, which reads very much like that at WH keys before that went tits up!
From this we learn the EA last visited the site- “most recent” on 23/6/2025 and were there for 1 hour and 12 minutes- so now 7 months ago. Of course at this time the water levels were nowhere at the height they are now.
What is revealed here by the monitoring sheet is a simple tick box exercise which does not really add up to much at all, and certainly not a very good understanding of the historic permit/licence or interrogation of the conditions of said document.
The assessment of each box is pathetic, with most of the fields not assessed at all.
Of course no breaches when they are hardly even assessing anything
We then get an action point which appears to suggest that they had previously visited the site in 2024 over one year ago. They had requested monitoring results for 2023!
“Action on previous CAR reference 40803/0505513 dated 16.05.2024
Action: Provide full set of laboratory validated data and report for April and October 2023 monitoring data. Due date: 14.06.2024.
This was fully completed and discussed at meetings with site managers
23.07.2024
The site had last been inspected on 16/05/2024 (EPR Compliance assessment report ID: 40803/0505513) as part of a routine inspection.”
The causal nature of this, the lack of recent up to date real time monitoring lead me to conclude that the EA are not regulating this site at all, but are just letting things unravel as the site operators see fit. Is it good enough they turn up once a year and fail to do any of their own tests to validate results which could be made up? HOW DO THEY EXPECT MEMBERS OF THE PUBLIC TO FEEL CONFIDENT IN THIS REGULATION ON THE SOFT?
“We walked the perimeter of the lagoon and the causeway accompanied by the TCM of Oldbury Energy Solutions Ltd. The Director told us that a security guard patrols the site on Saturdays and Sundays. Site inspections are carried out monthly and monitoring visits are carried out every six months (in April and October). If the water in either of the lagoons gets too high then it is pumped to the canal in accordance with discharge consent.”
This answers who the individual I encountered in the car was, but as for “security guard”, I would state that I saw no formal SIA badge or anything at all to identify this man as such in a formal sense.
The EA then provide a killer mention of the permit, though are unable to actually quote that this is regulation 10 and 13 themselves as they should. Obviously, something has gone very wrong with pumping high water to the canal of late eh?
Other than advising them to add an EA display notice, which they then did, there is little here to fill anyone with confidence that the Environment Agency are monitoring or regulating this site in a good way, and that is I am afraid the way it has always been since their creation in 1997.