white phosphorus misadventures #25 A blazing ammo box

Further to many other stories concerning the military “use” of this dangerous evil chemical, this one from 27th May 1950 Evening News brings together some familiar pieces. “Unserviceable ammunition”- “boxes of 24 grenades”, and a “phosphorus peril” fire. If only there was a place where all of this crap could go central to AW’s factory…….. 😮

Of course we are talking AW bombs here, useless glass bottles manufactured in the millions by the pillocks from Oldbury just a few years earlier and never used for anything but demonstrations by the Home Guard and others.

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OPINION- Why we all must never be a silent witness to wildlife/environmental destruction

OPINION. 

So with perhaps the worst kept local secret that the BBC drama Silent Witness has been filming in and around Macdonald Close, I thought it only apt to spell out the real life investigative drama that has unfolded around Rattlechain, both at the lagoon and land adjacent off the former Duport’s Tip- over time two separate crime scenes for sure.

In terms of the deaths of dozens of birds this was a far from straightforward case, but I was a first hand witness and recorded the demise that would eventually catch out the killers.

Death of a Swan | What Lies Beneath Rattlechain Lagoon?

BE IN NO DOUBT, THIS WAS A CORPORATE WILDLIFE CRIME, but there was repetitive deniability from the company protected by the civil service and political actors who were part of the same network, much of it harping back to Albright and Wilson’s military and academic links. Dumping a a banned rat poison and calling it a “waste management licence” is a disgusting present to the future, buried and using the passage of time to then use that site to build houses on top of it. Just add 50 cm of topsoil, and Bob is your mother’s brother. The deniability is always there and written into policy platitudes that claim to care about human and environmental health but which is just a smokescreen for making money.

I have never “trusted the science” to give answers because the science is always bought, the scientists in this case were proven liars and deceitful at every turn. White phosphorus and its murderous past was never raised at any meetings we had with Albright and Wilson and then Rhodia, held in Oldbury , and when that chemical came to light, it then became a matter of how much the birds had in their body, rather than the real fact of how much of the lethal substance they had ingested, and that they should never have ingested any at all. Louisa Merryfield and Mary Wilson had tried to pull the wool over people’s eyes with the same toxic deception, but this was a company doing the same dirty trick. 

The birds were of course, the silent witness here. But I was not silent and knew they did not die from natural causes. Video evidence of their demise was supported by previous research and sites where the issue had occurred. In many ways we were lucky to ever find out the truth, but the truth is an agent of energy which cannot be bargained with or corrupted like officers from agencies supposed to be regulating looking the other way.

Albright and Wilson of course made a range of deadly chemicals as well as storing them on their site with many fatal consequences. Their glyphosate mix, a carcinogenic blend are all the things that Rachael Carson warned us about, just diluted as an alternative to something more potent that it replaced. AW had always played this game with red phosphorus replacing white in matches. Problem- reaction- solution. They were just manufacturing consent.

Silent Spring on the former Duport’s Tip.

How perverse that tonnes of waste could have been tipped across former agricultural land , toxic and undocumented for so long and then buried with the foundry sand dumping shysters making a mint out of that.

The axing of Millennium forest in 2025 and the more recent spraying event just continue this leitmotif of destruction and attack on nature.

Given the planning history and development pressure around this land, the concern is obvious: this looks like an attempt to chemically suppress or destroy ecological interest before it can properly inform planning, The Local Plan, SDS, LNRS, biodiversity net gain or development decisions.
To be blunt, this has the appearance of evidence destruction by herbicide.
And this is what Sandwell Council had to say as an accomplice in this act with an FOI request I put in seeking the claimed “ecological survey” that had supposedly been carried out prior to the tree clearance. 
“The developer is aware of the long-standing objections relating to the proposed use of land and asserts that objectors have sought to adversely harm their interests through the spreading of misinformation and inaccurate statements, relating to the potential development of the site, with particular emphasis on the ground conditions and ecological implications of the same.  It is felt that disclosure of the information at this point, prior to a firm decision to develop or prior to a planning application being submitted is premature. It is considered that sharing information prematurely could lead to speculation and discussion outside the formal planning processes, which would divert time and resources from ensuring a thorough and considered approach.  The disclosure would clearly cause adverse harm to the developer as it will result in the need for further rebuttals, when these matters should be dealt with at the appropriate stage i.e. through the planning application process or through an Examination in Public of the Local Plan.”

The loss of all that green space could not possibly result in the biodiversity net gain that the council love to talk abut on paper, but “adverse harm” to nature.

Who knows what case awaits for Dr Nikki Alexander and the gang in the programme and series 30 of the long running saga, but the area in question is a study of historic pathological wrongs , somehow mitigated by the flap of a butterflies wings or the growth of a rare plant. If we loose these areas then what future will there be to delight men’s eyes?

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Rattlechain Redevelopments Limited’s attack on nature and local residents

So I can say here, I am not surprised with what took place this week on land off Macdonald Close/Gladstone Drive put forward as a “strategic site” for housing in the long delayed Sandwell Local Plan.

Residents reported seeing a tractor on site spraying a glyphosate material indiscriminately over red list plants, beneficial invertebrates and the potential site of importance for nature conservation. Of course, part of this site is also designated as a SLINC, though as I have stated before, no one appears to be able to state why the area in question was designated when there is more of ecological value outside of this.

On confronting the driver, wearing no PPE, the supposed land owner claimed he was a “farmer” and could do what he liked and an environmental assessment had passed it all off. BULLSHIT.

On hearing this news, I instantly contacted Sandwell Council to see what was going on and what they knew. Multiple departments in this authority have now been approached by numerous people, as well as formal complaints to the HSE and The Environment Agency about the amateur and shambolic operation putting people’s health and safety at risk and that of their companion animals, as well as property that the spray was going in to.

LET US BE CLEAR HERE, THIS OPERATION, UNADVERTISED, PUT THE HEALTH AND SAFETY OF LOCAL RESIDENTS AND USERS OF THIS SITE AT PERSONAL RISK OF HARM. These are not the actions of a credible land owner or consultancy/operator. Video and pictorial evidence have been recorded for the authorities.

All I will say at this stage is the agents of this land owner spoke a very different story at the local plan examination, and so it will be very interesting to see what shite they come out with to justify this reckless act of ecocide, pre-meditated , deliberate , but not particularly clever. Everyone knows what was on here, and that has been recorded by relevant experts in the field. Any ecologist undertaking a site survey after this writing a report for the Kelly family saying that there is nothing here gov, will be publicly and professionally trashed by their peers, and will never get any work again, and they will also be reported to their trade body to be struck off for making up false reports. THAT IS A PROMISE SO PUT YOUR NAME TO IT, RAT. 

No wonder they have hidden the reports they claim they undertook, which we still believe never existed.

As for local residents who have reported to me issues under COSSH after being exposed to the film of herbicide drifting into the gardens off site, Please report such matters to the HSE by filling put the form at this link.

Also raise this with the three ward councillors for Oldbury, who hopefully now in opposition will at least do more than pass it on to “pick up speed now.” Contact details below.

Councillor Suzanne Hartwell

c/o Business and Member Services, Sandwell Council House, Oldbury, Sandwell, B69 3DE

Work mobile: 07814 862 104

Work: suzanne_hartwell@sandwell.gov.uk

Councillor Rizwan Jalil

c/o Business and Member Services, Sandwell Council House, Freeth Street, Oldbury, Sandwell, B69 3DE

Work: rizwan_jalil@sandwell.gov.uk

Councillor Nagi Daya Singh

c/o Business and Member Services, Sandwell Council House, Freeth Street, Oldbury, Sandwell, B69 3DE

Work mobile: 07811 583 817

Work: nagi_dayasingh@sandwell.gov.uk

A better route is with Sarah Coombes MP, who I believe is genuinely interested in this site at this link.

 

REST ASSURED ALL IS BEING MONITORED AND RECORDED AS BEFORE.

#NOSURRENDER

 

 

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Opinion-Back to the canal grime future

On a recent canal journey, imagine my surprise on seeing an Alfred Matty boat complete with livery just passing the Gower Tip, almost as though it had got up to 88kph from the 1960’s.

David Wilson’s picture from the days of when this company delivered Albright and Wilson’s deadly cocktail to both Gower and Rattlechain tips was fresh in my mind when I took the picture above.

And of course Roy Martin’s time stamp smoking gun of a picture.

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On this occasion no pulling an open boat load of toxic cargo.

As another coincidence of the time continuum, I also happened to see the below as part of a facebook reel from an old MACE news film shared on the Gongoozler Crew page. This dates from 1971.

This particular Matty boat was called “The Governor”, and I believe is still around though thankfully not transporting any toxic waste.

 

A study undertaken around this period, Autumn 1970, by Laurence Braithwaite entitled “The use of urban canals” from The University of Birmingham Centre for Urban and Regional Studies was a forward thinking piece on the “full potential of canals in urban areas”. The then state of the canals was looked at on the BCN network, and of interest to myself issues of pollution at this key time.

On page 18 he notes

“On one notorious case in the area the BWB Annual Report for 1969 says:

“On the BCN pollution entering the canal from a chemical works on an arm not in the Board’s ownership has created unpleasant conditions affecting the canal over some distance from the point of entry. Strong joint action by the board and the river authority resulted in action by the company and conditions should steadily improve; it is understood that the process giving rise to the particular circumstances has now ceased”

Though not named, they are of course referring to Albright and Wilson and the Houghton Chemical arm. Though slated to cease tipping by Matty boats in 1969 when white phosphorus was no longer produced at Oldbury, we know from Paul Bartlett’s first hand account that it continued into the 1970’s for some years after this, still dumping toxic waste via the toxic trail. Quite frankly, I do find it rather hypocritical of this board in that they were fully complicit in the dumping of toxic waste to land and water at this same time with their own tips, as well as their involvement with rattlechain itself.

OPINION

As for the opinion piece on this, I am so glad this commercial trade is dead, buried unfortunately in shallow graves of water and land around us of course and never, never, never coming back.

At present, the canals on the BCN are entering a terrible state of disrepair, fly tipping and overgrowth similar to the abandonment of the 60’s/ early 70’s as seen in some of the MACE films and highlighted in the Braithwaite study. There have been major pollution issues caused by industry and in many cases fuckwit pleasure boaters whose spread is now saturating the canal system to the point of overload.

It is shocking that no competency test or a “driving licence” is required to operate a narrow boat around the canals. This should be mandatory, and so should the enforcement of unregistered boats which are also getting more frequent- especially clapped out cruiser boats that appear to have a nasty habit of sinking. One incident recently I saw down the Delph Locks involved a boat whose operatives had not a bloody clue as to how locks work, resulting in flooding of a lock and cascading a downpour down a walkway. And then there are the fuckwits who trap birds in locks and squash them. There appears to me to be a middleclass arrogance of some boat owners who could not care less abut the waterways, rather their own polluting water snail pumping out bilge on their retired carefree way and occasionally flogging some handmade tat. Diesel boats must be phased out- I am sick and tired of this type of pollution causing damage to wildlife. They are a thing of yesterday and should not be a part of the future.

The CRT, now a charity, and a distant memory of the terrible former British Waterways do their best to some degree with volunteer help, but it is run by a board whose CEO is on six  figures. Some have called for the Government to fund the waterways, but I am not one of them. The CRT  has to get its own house in order and get those running the show to take a massive pay cut.

There are numerous serious leaks in key aqueduct locations over roads and rail bridges in the area, which appear to have been forgotten and potentially await disaster. These type of issues should be being put first and money not spent funding restoration pipedreams of long abandoned and lost canals.

Finally if the CRT want to encourage more people to use the canals safely, it needs to put back the canal bike barriers to stop the masked up thieves and drug dealers now using the network as a means of getting from a-b to avoid detection. Its policy of removing these is dreamt up by office based idiots , no doubt with a sustrans bent, without a clue as to what is going on. They live in blind stupidity.

Where will the canal system be in another 30 years? I dread to think.

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The Sandwell Plan strikes again

LORD GIVE ME STRENGTH!

SANDWELL PLAN 2          Image result for pink panther gif

So when does a “plan” just remain a plan without ever being put into action?

Imagine my surprise to receive the recent email below from Sandwell Council planning policy. The SLP was of course a culmination of nearly a decade of time wasting bollocks that began life as “The Black Country Core Strategy”, then evolved into the “The Black Country Plan”. When Dudley Council shafted this, Sandwell and the other authorities began their own local plans, much of it copy and pasted, and this led to many errors which the inspector picked up on in her examination, of which I took part.

Sandwell had claimed that undertaking the plan at this time under the December 2023 NPPF would be more advantageous as this version of planning policy was more favourable and less stringent in holding local authorities to account on housing targets set by Government. SMBC are over 14,000 down which makes this plan look ridiculous and is impossible to deliver.

I think the council, under then Labour control, expected this plan to go through quickly, but did not bank on the inspector doing a diligent job and looking through it with a fine tooth comb. We are still awaiting the outcome of this, after SMBC had submitted their modified plan.

So here is the email below, and just when you thought it was safe to go back into the water, a sequel is already in the pipeline!

“Dear Consultee,

Current Sandwell Local Plan (SLP) – currently in Examination

An update on where we are with the current draft Sandwell Local Plan.  We recently consulted on the Main Modifications and all responses have been forwarded to the Planning Inspector and we await her findings on the examination of the plan and her final report.  We will update our website https://www.sandwell.gov.uk/planning/sandwell-local-plan when we have further information.  We are hoping to adopt this plan, subject to being found sound in summer / autumn this year.  Even though we are awaiting the final report from the Planning Inspector and it is not adopted, due to government regulations we have been instructed that we have to start work on a new local plan. We will still continue to adopt the current SLP and at the same time continue to progress work on the new plan (Sandwell Local Plan 2 (2026- 2044), once this is adopted this will replace SLP.

New Sandwell Local Plan – Sandwell Local Plan 2 (2026-2044)

 We are pleased to let you know that we are about to begin work on the next Sandwell Local Plan 2 (2026 – 2044).”

So let me get this straight, without even getting the inspectors decision, a bit like waiting for GTA 6, SMBC are going to bypass this by adding another 3 years, carrying out the whole exercise again and achieving what- another fucking “plan”, the son of Sandwell Plan.

I raised these issues and had the following reply.

“The government introduced new regulations (including The Town and Country Planning Regulations 2026). The reforms aim to speed up the process, mandate a universal 30-month limit for plan creation, and ensure comprehensive, up-to-date local plan coverage to meet housing targets and boost community participation. In Sandwell work will formal work will commence on the next local plan in July with an adoption date in 2029. Yes, there will be an examination in public before the adoption of the plan.”

This “plan” has been going on now for longer than the First and Second World Wars combined, and has more to it than Operation Overlord and Sea lion with this crazy Government of wankers, another chief Onanist incoming shortly, demanding targets for redistributing dinghy filth from France outwards from the south. THEY ARE NOT WELCOME HERE! 

But the tax payers continue to prop up this rambling pile of shite and the council are even hiring someone to join the team to rewrite what has already been rewritten several times before.

Stand by your plan Tammy? “Most improved council” LOL

Maybe that should be the neigh team. 😛 

Sandwell planning is about to drop another “new improved” load

 

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The Environment Agency admit making mistake about Rattlechain Lagoon- THIS IS SERIOUS!

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Rattlechain Lagoon has always been Licenced to spill

“I appreciate you taking the time to follow up, and I want to sincerely
apologise for the error in the information we provided to you on that date.”
I have come to expect serious failings in the way that this hazardous waste landfill site has been regulated over the years and how unsafe the whole issue was, but this one has surprised even me!
It is interesting how just one FOI request opens up a pathway that leads to others, and how that journey reveals things that were previously hidden from public view or scrutiny. So was the case with THIS request and the change of permit number.    
In response to this I contacted the EA about future development concerns and monitoring of the site by the EA, and also one Suzanne Ward, who has been in this organisation in a senior position for many years, including during the 2013 works undertaken at the site. Principally she was the boss of Dave Whitford, who undertook much of the liaison with Rhodia and the individuals Tom Dutton, HSE Director and John Moorhouse, “Site redevelopment manager” from that company. She now has the title “Place Manager – West Midlands Combined Authority, Warwickshire, and Worcestershire.”
 
Though I did not specify this as a new FOI request, questions I had asked within were treated as such, and the response to this is interesting in itself, which I will save for another day. 
Other observations I made- some were conveniently totally ignored, whilst others were answered. Specifically, as well as providing background to the site history, I mentioned the then ongoing permit breach of the causeway path and how this had happened before. This is a little lengthy, as you may expect by now from me 😆 , but the detail IS important to note. 
  • Over time, and with the EA  supposedly regulating this site under the  SL31 licence passed in 1978Condition 10 of the licence required AW and later Rhodia to not allow water to rise above the so called “clean side” lagoon, this is specifically mentioned, as well as Condition 13 requiring the lagoons to be operated to the satisfaction of the regulator.
  • THE SMALER LAGOON WAS NEVER “CLEAN” HOWEVER BEFORE THIS LICENCE, AS I HAVE PROVEN ABOVE. This was an Albright and Wilson invention, and the waste that had already gone in here was still there. No set levels of p4 being able to be discharged back into the canal were set, and regulators had no test method to test samples of canal water for the same chemical as proven by an FOI request
  • No samples of the fake “clean side” lagoon were taken by the Cremer and Warner report in 1991, with AW able to bluff their way with the lie of the “clean side”. NO ONE QUESTIONED THIS LIE. 
  • Only with the dodgy “human health risk assessment” hastily arranged by Rhodia as a pr exercise following confirmed systemic exposure to birds being poisoned by P4 did they test sediment from the fake “clean side”, confirming the presence of P4 as you would expect-at levels higher than the so called “dirty side”. You would also expect this given that the historic production of p4 at the site contained higher concentrations of white phosphorus.
  • The scandal of this is that the EA were happy to believe a lie that had been operating for decades because no one questioned historic operations sanctioned by the useless licence.
  • When it came to the phoney “cover up works” of 2013, Rhodia claimed that they had sucked out the silt from the fake “clean side” that was never clean, and discharged it into the larger “dirty side” lagoon, placing a cap above this supposed now solidified waste.   This magicians trick does not wash however given that excess water was not pumped from the fake “clean side” smaller lagoon any more, and not by the new pier they installed at the end of this pool when they removed the pump pipe that ran along the causeway path. Instead, their operatives set up a pump from the larger lagoon, using a piece of the pontoon they had removed that was used to discharge the waste. THIS MAKES NO SENSE, but it does when you consider that the so called “clean side” has basically been operating as an attenuation pond since capping, discharging phosphine gas into this side from the capped larger lagoon.
  • In 2016, I specifically asked an FOI request of the EA about this operation, following the fact that contractors had also been witnessed dumping aluminium sulphate, (acidic substance) into the smaller lagoon to lower the PH. The consent to canal limits specify ph between 5 and 9. 
 
“Why are Rhodia/Solvay pumping water from the large lagoon instead of the smaller one? “
The EA stated
“They are pumping from the larger lagoon as the ammonia levels are lower in the larger lagoon than the smaller lagoon according to testing conducted by the operator. “
What explanation there is for this given the claim they removed all the waste material from the phoney “clean side” smaller lagoon is of course a valid question which somehow refutes the claim of waste removal really happened at all. 
Given that water has now flowed over from one side into another, how convenient that when it came to turning on the pump again, was this water tested BEFORE they started to pump water again, and also from the canal? 
There have been many historic breaches of the causeway path, even when waste was still being discharged by AW and Rhodia, as formal records show from an FOI request as well as our direct observations over 30 years.
  •  I raised the recent breach of the causeway with the EA 
  • I informed them that I knew the permit of this site underwent a transfer number in 2021 when Solvay officially took over Rhodia, as I looked at HERE.
  • This new permit under the Environmental Permitting Regulations 2016 was numbered EPR/JB3909LT.
  • I questioned what company are actually in control of the site and the integrity of a remote monitoring operation from Kent.
  • The pump was turned back on after I reported the matter to the EA, but only after this but only discharged back to the canal again for a couple of days, though what ph levels now exist on the breached lagoons is open to question. The path remains fully breached in clear breach of the permit. 
I MADE IT CLEAR THAT I HAD  REPORTED THIS MATTER THREE TIMES VIA THE HOTLINE NUMBER. 
The EA gave me the following reply where they tried to tell me about the history of this site and its phoney remediation. 😆 
My reply below.
“In respect of this response, I have to state that you are factually totally wrong concerning the subsidiary lagoon being lined. THIS DID NOT HAPPEN. Only the larger lagoon was capped with a geotextile. The smaller lagoon was never capped. I have proof of this, so I suggest your staff get their facts right. I documented this, have video evidence and the following should be of interest to you. 
Specifically, here is what your former colleague DAVE WHITFORD STATED IN WRITING – environment management regards these works. He approved them, as did others. 
Therefore, I do suggest that you correct your untrue statements here, or I will escalate this matter further! 
The lagoon was once ONE pit, where dumping took place before licensing. The fact that white phosphorus was found in the smaller lagoon where you allowed this to take place shows the lack of historic insight that the EA have on this matter. Waste from this lagoon was pumped into the larger lagoon, but this smaller lagoon was not capped.
 
This is therefore NOT a “minor breach”.  On obtaining your monitoring records of this site in the time since the 2013 works took place, barely any site visits have been made by EA staff to confirm results being fed to you.
There have been substantially delayed reporting of results by the site operators and where white phosphorus was being found in ground water, which I would suggest why they failed to give them to you promptly, and now this; a clear failure of understanding by your current staff to realise what actually took place.
It is clear to see how operator self monitoring has benefitted no one but industry for all of that time, and how the EA have been corrupted by this approach. I have been a witness to all of this since the 1990’s evidenced through the bird deaths I recorded and can document and back up everything that I state. 
 
No remediation of the Eastern and Western sides of the lagoon has ever taken place. These were not capped or even touched during the works of 2013. The embankments were as they remain- contaminated. 
You therefore fundamentally fail to have risk assessed this site and have failed to regulate it properly in that time. 
Please therefore respond to this email and admit you have given me information which is evidentially not correct or true. “
With this in mind, the EA corrected this, bizarrely even asking Rhodia what they should have known all along. 
“Thank you for your email of 15 April 2026 regarding our response to your enquiry on
15 April 2026. I appreciate you taking the time to follow up, and I want to sincerely
apologise for the error in the information we provided to you on that date.
After reviewing the matter in more detail, we identified that the mistake arose from a
misinterpretation of earlier internal and external correspondence. It was initially
thought the geomembrane covered the two pools that make up the lagoon.
Thank you for highlighting this and prompting further investigation. Our investigation has confirmed that the geomembrane covers only the larger of the two pools.
At the time of the installation, the smaller overflow pool was cleaned up sufficiently to
allow ongoing water collection and discharge to the canal. The causeway which
divides the two pools acts as a filter between them.
This information has been confirmed internally with specialist staff and with the site
Operator.
Yours sincerely,
Beth Robertson
EPR Waste – Team Leader
West Midlands Area”
CONCLUSION
  • The EA originally tried to fob me off with bullshit. Many people asking questions about this site and other historic landfills are no doubt reliant on information that they would expect to be accurate and clear, and yet the EA were not informed by the facts of the case at all.
  • This is serious as this operation was done in recent times and on their watch. There are no excuses as far as I am concerned about not understanding “historic” communications. 
  • In planning terms, and as a statutory consultee, the EA would make “expert” comments in regards to planning applications where a local authority would expect them to provide guidance on the status of contaminated sites. If the EA had made this lie in such correspondence with Sandwell Council it would have been parroted by the planning officer without the slightest challenge or scrutiny of the facts. THE EA WERE WRONG, AND BADLY WRONG HERE. 
  • Equally Part IIA of the Environmental Protection Act 1990 depends on factual information being obtained. RHODIA HAVE NOT REMEDIATED THIS SITE. 
Furthermore the National Planning Policy Framework (version Dec 2023) of which the current Sandwell Local Plan  was examined has this to say about regulated sites and contamination at paragraph 194. 
“SHOULD ASSUME ” IS A VERY WISHY WASHY WAY OF LOOKING AT THINGS- BUT THIS SUMS UP THE ENVIRONMENT AGENCY’S APPROACH TO HISTORIC LANDFILL SITES. 
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“Save our small blue butterfly” campaign kicks off

Butterfly Gif - GIFcen
Animated Soccer Ball GIFs | Tenor
A recent joint press release was put out by The West Midands Butterfly and Moth Society and The Friends of Sheepwash Local Nature Reserve in defence of the wildlife habitat under threat from The Sandwell Local Plan. 

“Conservationists are alarmed by proposals to build 500 houses in Oldbury on a former landfill tip which is home to the Small Blue butterfly and many other valuable insects and plants. The former Rattlechain Tip site in Tividale is a wildlife haven which, despite the threatened status of many of the unique insects and wildflowers that occur there, has been included in Sandwell’s housing plans as a ‘strategic’ site. The Small Blue is Britain’s smallest butterfly and is generally found on limestone grassland in southern Britain, where it lays its eggs on Kidney Vetch. Much of its traditional habitat has been destroyed by agricultural change and other pressures over the years, making its presence on former industrial land at Rattlechain incredibly important.

Volunteers from West Midlands Butterfly and Moth Society (WM-BAMS) and the Friends of Sheepwash Nature Reserve, alongside other local residents, visited the site over the Spring bank holiday weekend and were delighted to count almost 40 Small Blue butterflies, together with other butterfly species including the uncommon Green Hairstreak.

Several unusual plants were found as well, including Tower Mustard at its only known site in Birmingham and the Black Country and with few known locations nationally. Other notable plants include Narrow-leaved Everlasting-pea, Common Cudweed and Narrow-leaved Bird’s-foot Trefoil.

Mike Williams of WM-BAMS said, ‘The value of sites like Rattlechain for both wildlife and people cannot be over-estimated. So few green spaces like this now survive in built up urban areas that they are almost unique and provide vital sanctuaries for wildlife, as well as places that people can access for exercise and their well-being. The fact that the Small Blue is flourishing here makes it even more special, as it is the only site for this butterfly in all of Birmingham and the Black Country. The nearest places it can still be seen are in the Cotswolds and a small area in central Warwickshire’.

Ian Carroll from the Friends of Sheepwash Local Nature Reserve, who spoke in defence of the site at last year’s public enquiry, said, ‘I find it amazing that Sandwell Council would want to sanction housing on such heavily contaminated land, as well as the linked white-phosphorus-containing Rattlechain Lagoon, which would cost millions to restore over many years and would not meet local housing need. It would be so much better for the environment and taxpayers’ pockets if, at minimum cost, the area could become a new local nature reserve and its important butterflies and wild flowers be conserved for everyone to enjoy.’

Small Blue at Rattlechain Tip on 20 May 2025 (Mike Poulton)

WM-BAMS will be running an information stall at Dudley Zoo’s Festival of Change on 5-6 June, where people will be able to find out more about this site and how they can help to conserve it. Volunteers associated with the site will be present on Saturday 6 June.

This happened and was well received by the many people that we spoke to. A good piece was also written by The Dudley News.

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Guest Blog- Paul Dunn- Rattlechain Tip: Nature’s Quiet Resurgence in the Black Country

This is a cracking piece by local butterfly and moth expert Paul Dunn, which I am very happy to share here with his permission. He has been instrumental with others in raising the profile and status of this elusive rare butterfly off the chain and surrounding Temple Way open space. I would like to thank him for his time, and I have added a few evidential links from this website and credited pictures to complement and illustrate  the story.

Rattlechain Tip: Nature’s Quiet Resurgence in the Black Country by Paul Dunn. 

Across the United Kingdom there are places dismissed as wasteland – forgotten corners, visited mostly by daily dog walkers, yet rarely granted a second glance by other passing commuters. And yet, it is often here, in the most unlikely of settings, that nature reveals its extraordinary resilience. Few sites demonstrate this more clearly than the site known as ‘Rattlechain Tip’, tucked quietly into the heart of the Black Country.

Situated in the West Midlands, the grid reference SO97691 91144 leads the visitor to its main entrance at the end of Macdonald Close. What now appears as a raised, scrub-covered mound was once a thriving clay pit, forming part of the historic Rattlechain brickworks. Following the Second World War, the pit slipped into disuse and, over subsequent decades, was progressively infilled – first with industrial and hazardous waste, then with a variety of putrescible waste material. Finally, it was sealed beneath a thick cap of black foundry casting sand and clinker. Notably, no true topsoil seems ever to have been added. The volume of waste was such that it rose well above the quarry’s original rim, reshaping the landscape entirely.

At the end of the 1990s, after a complete clearance of encroaching vegetation, an attempt was made to soften this industrial scar by planting a variety of young trees. But the substrate was unforgiving. Most failed to thrive, remaining stunted or dying outright. And so, largely abandoned once more, Rattlechain was left to its own devices.

The main site covers more than 24 acres and lies beside another former quarry – known as the Rattlechain Lagoon – a permanent body of water that has become home to a rich assembly of aquatic birds.
Over time, the land was allowed to settle, and in doing so, it offered nature the rare opportunity it needs: space, patience, and neglect.

Slowly, almost imperceptibly at first, life returned. A remarkable community of grasses, herbs, shrubs, and trees began to establish itself upon this low-nutrient, artificial ground. Today, more than 140 plant species have been recorded here – an impressive tally by any measure. Among  them are Bee Orchid and its wasp-patterned variant trollii, Pyramidal and Common Spotted Orchids, Narrow-leaved Everlasting Pea, Tower Mustard, Lucerne, Wild Mignonette, Fennel, Blue Fleabane, Trefoils and Kidney Vetch. Together they form a mosaic of colour and form, unexpected in such an urban setting.

Bee on kidney vetch May 2026. I. Carroll

With plants came insects, and with insects came birds. Much of this diversity remains
undocumented – beetles, flies, moths, spiders and more await discovery – but their abundance is unmistakable. Butterflies, however, have been more closely observed, and the figures are striking. As plant diversity increased, so too did butterfly numbers. Over the past decade, Rattlechain has supported 27 of Britain’s 59 butterfly species – almost 46% of the national total – earning it quiet recognition as an urban refuge of considerable importance.

Beyond the boundaries of Rattlechain, however, the outlook for both plant and butterfly is far more troubling. Since the early 1980s, the distribution of Kidney Vetch across the UK has declined by approximately 43%. This steady erosion of habitat has placed Britain’s smallest blue’ butterfly firmly on the conservation priority list, as once-reliable sites disappear beneath development and changing land use.

Against this backdrop, Rattlechain’s value becomes unmistakably clear. It represents the only confirmed breeding site for the Small Blue butterfly Cupido minimus, within the innermost reaches of the West Midlands – the nearest alternative lying more than thirty miles away.

Small blue on kidney vetch. I Carroll

Here, an unassuming patch of undisturbed ground supports a species whose survival depends entirely on the presence of a single, increasingly rare plant. What persists does so not through careful design, but by chance – an accident of history and neglect. And for that very reason, its future now rests upon something altogether more deliberate: thoughtful, informed stewardship.

This was the situation until January 2025.

On a grey, fog-laden day, without warning or consultation, heavy machinery arrived. With no known conservation oversight, ecological surveys, or biodiversity records in place, bulldozers started to strip the surface of the site. Established trees and bushes were chainsawed and uprooted; the ground was aggressively scarified, removing much of the vegetation built up over two decades.
Within the space of a couple of weeks, a vital wildlife corridor – linking Sheepwash Nature
Reserve, beyond the canal to the north – appeared to have be lost.

Macdonald Close January 2025

At first glance, the destruction seemed absolute.
Yet nature, as ever, had other plans.

While the disturbance did eliminate many invasive species such as Buddleia and Sea Buckthorn, it also triggered an unexpected resurgence. From the newly exposed ground emerged thousands of Kidney Vetch plants – one of the rarer and declining species in the Black Country and the wider West Midlands. This modest plant is of profound importance, for it is the sole larval foodplant of the Small Blue butterfly, one of Britain’s rarest and most delicate species.

As far back as 2016, Small Blue butterflies had been observed at Rattlechain, particularly in the north-eastern section of the site. There, in a shallow depression known as The Hollow, Kidney Vetch flourished, painting the slopes yellow in summer. Over the following years, the plant steadily expanded, climbing the sides of the hollow and spreading towards the main entrance from Macdonald Close. The butterflies followed.

Initially confined to just a few areas, the Small Blue population began to disperse more widely by 2021.
By 2024, regular counts across the site ranged between 30 and 50 individuals – an extraordinary success story unfolding quietly amid the urban sprawl.

In June 2025, as vegetation tentatively began to recover, a visit was made to the site alongside Mike Williams from Butterfly Conservation (West Midlands). The aim was simple: to confirm whether the Small Blue had survived the devastation. What followed exceeded all expectations.
More than 20 individuals were recorded, and Mr Williams observed females actively laying eggs on the remaining, sparsely flowering, Kidney Vetch. Against all odds, the future looked promising.

Now, as the site enters a new year, Rattlechain is once again in recovery. Dormant seeds are germinating in profusion, vegetation is returning, and the landscape is healing. While a dramatic increase in Small Blue numbers is unlikely during the 2026 season, the outlook beyond is encouraging. Provided no further damaging intervention occurs, both Kidney Vetch and its remarkable butterfly are poised to expand significantly in 2027.
Rattlechain Tip stands as a quiet testament to nature’s resilience – a reminder that even the most unlikely places, given time and tolerance, can become sanctuaries of extraordinary life.

For the people who live alongside it, Rattlechain may appear unremarkable at first glance. Yet beneath its grasses and wildflowers lies a story of quiet significance – one that belongs as much to the Black Country as it does to the butterfly itself. As the site continues its slow recovery, it offers an opportunity: to recognise the extraordinary value of overlooked places and to ensure that this unique site for the Small Blue butterfly, within the very heart of the West Midlands, is allowed not merely to survive, but to endure.

Butterfly and moth enthusiasts proclaim an important message

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Albright’s toxic archives #55 Phosphorus furnace blast

Just another example from the 7th August Smethwick News Telephone about the dangers that this site posed to the surrounding public. Their “made in Oldbury” propaganda hid things like this from public view except when loud explosions, fires and of course at this time, “smells” became impossible to ignore.

This one would have made front page headlines today if it had happened, but with just a few lines of copy here, one must appreciate that this was a frequent occurrence associated with this site. Our old friend white phosphorus is at play here, and at this time, the furnace known as “old smokey” to staff was still polluting the air around Langley with a deathly noose like grip.

Always these articles read as “heroic” action, instead of asking the serious questions such as WHY did it happen, and should it be allowed to continue just so one company could continue to make money whilst putting people under grave risk of harm?

All of that contaminated sand would have gone somewhere of course, and that place obviously was by boat waste delivered to a certain marl hole they were in full operation of disposing into at this time.

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Environment Agency MIA! Another revealing Rattlechain lagoon FOI request

Rattlechain lagoon EPR compliance assessment reports

BR7P51 Aerial view of white phosphorus chemical waste disposal in Rattlechain Lagoon, St John’s Lane, Tividale, Sandwell, England, Britain, Uk

Hot on the heels of a revealing FOI request to the Environment Agency, another I put in following that one has sparked more questions about this supposedly “closed” hazardous waste landfill site, and in particular the performance of the supposed body regulating and monitoring it to protect the public and environmental health and safety. So to say once again here, it underlines my experience and opinion of the environment agency as being a joke of a quango who serve only polluting business and who are increasingly paving the way for housing developers on dangerous sites such as this.

This is a long but necessary forensic investigation into the interactions between regulator and the supposedly “regulated”. 

The Environmental Permitting Regulations (England & Wales) 2016 generate site visits where compliance assessment reports are completed by the EA visiting officers. As was seen by the last request where the EA visited in June 2025, this was a bit of a sham tick box exercise and almost one of apology asking the site permit holders for information about self monitoring. So I wondered what other CAR forms the EA had in relation to their monitoring of the original permit still in force?

The new request I put in was as follows, and it is the last part of this which is the shocker-I.E 12 years of monitoring the chain.

“Please provide a copy of all EPR compliance assessment reports held for this site and visits made by EA officers since 12/12/2013 When the agency initiated variation to incorporate ‘closure report’ & remove right to accept waste for disposal. NB the number of inspection visits made by EA officers to the site in the last 13 years.”

The EA responded with just 5 forms, including the one already supplied from last year! I could not believe this and so I followed up with a clarification which they unfortunately treated as a new request, though no reason was cited as to why they had not provided all of the forms to start with!  Together this produced just  9 EPR compliance assessment reports supplied for this site in 12 years, though it is apparent that not all of these were actual physical site inspections.

30/10/14,

27/4/15,

27/6/18,

9/7/21

25/3/22

31/12/23,

16/5/24,

23/7/24

and 23/6/25.

Let’s look at each one in turn in order of chronology, and then explore the apparent shocking lack of monitoring for certain periods between 2014 and 2023.

30/10/2014

This for context was nearly one year after the 2013 cover up works where contractors had removed traces of the former waste disposal operation pipes, placed a geotextile membrane over the larger lagoon, allegedly sucked out waste containing white phosphorus from the supposed “clean side” lagoon but crucially left that uncapped, installed a new pumping pier, and a perimeter track around the North and South of the site.

This CAR form appears to be a little more robust than the later site visits with “site security and signage” being assessed. It was however a 15 minute visit! 

Straight away, we get a permit breach condition 23. Here is the wording of that condition from the original SL31 licence.

Requires name of site, site operator and the regulator details.

We have of course seen this before when Barratt Homes defrauded people out of money by marketing houses on Callaghan and Wilson Drives at a time when this board was conspicuous by its absence. There is evidence of these historic breaches supplied by the EA themselves. Some reports state “NO ID BOARD” as being present on the site entrance. Condition 31 was essentially linked to condition 23 when it was issued but as both of these signs had to be displayed on the site entrance they count as two separate breaches.

See for example in 1997 when the EA were first tasked with dealing with this site in their creation.

scan0022

“OUT OF DATE” AND NO EA INFORMATION

Of course, this leads to instant deceit of the status of this site, its contents and the ability of the public to contact relevant authorities. We are not sure if Rhodia fulfilled rectifying this breach in a timely manner, or if the EA bothered to come back to check!

27/4/15

This extended visit of 55 minutes involved the three named EA officers.

It is revealed that this meeting was to discuss the discharge consent to the canal, following the installation of the new pumping apparatus following the 2013 works.

Though the name is redacted, I can tell you for certain that the health and safety manager on this little soiree was “Dr” Tom Dutton, he of the “small amounts” of white phosphorus in the lake and serial bullshitter on behalf of this grotesque frog polluter company outfit. I can only speculate as to the horseshit that fell from those lips that day regards his potted view of the history of this notorious site. He was after all in the role as Albright and Wilson when toxic waste was still being discharged, and an accessory to the cover up of this substance poisoning birds. The “risk” his pathetic company employed at this site did not extend to inviting me on to said site or informing anyone of the properties of white phosphorus present and on birds.

Just to be clear here, I do hope this twat did not lie to the officers about not covering the smaller lagoon, THAT POOL WAS NEVER CAPPED, AND HE SHOULD HAVE MADE THAT FUNDAMENTALLY CLEAR TO THEM, AND ALSO THEY SHOULD HAVE KNOWN THAT. 

The mystery of the alkaline smaller lagoon is something the EA here should have investigated, and not just speculated on from this joker. The matter of using the larger lagoon to pump excess water is a matter I looked at around this time, querying this with the EA, and I discussed this in THIS POST where they actually make reference to this meeting. 

27/6/18

This is not an assessment or site visit in any form. Quite honestly, without the EA doing any testing of their own, they are happy to swallow the bullshit fed to them on the basis that off site “locally” the area is “poor”. I’m afraid that this “poor” standard of regulation is one which I have become accustomed to “locally” with this quango. 😛

9/7/21

This site visit of 45 minutes appears to be the first in six years!

Incredibly, the agency have only just appeared to notice that site licence SL31 had in fact gone the way of the dodo several years earlier at their approval with the new numbering, though the licence conditions were still in place.

In June of 2021, I had noticed that the SL31 sign had been removed, and you can read that observation HERE, which ties in perfectly now with this report. The condition 31 is of course the identity board, and its removal a breach.

I further noted a couple of months later in THIS POST , that the new number had been added, and it is clear that my reporting of this had led to this “immediate site inspection”. . 😆 Perhaps if they paid me, I could save some car miles for them from Frankley to keep an eye on this place. 😛

Removing the link to SL31 removes the only history of the site worth knowing

This report refers to monitoring for 2020 and looks forward to a future full site visit.

25/3/22

This report, an “unannounced visit” of 20 minutes , is a direct follow up to the previous visit and ties in by mentioning that form number.

It was however only conducted from the outside as no access had been granted. We have seen this same issue played out in inspections of water company sites which I will mention further on in this post. The visit noted that the new ID board had been added.

Unfortunately this unannounced visit is pretty useless given that the officer requires them to supply dates when they would be available to receive a visit to get in through the locked gates!

The permit discharge to the canal is also mentioned as it stood at that time- linking it to the parent company that chose not to put its own name on the site ID board!

The pictures are of interest and are shown below. It is odd that EA officers do not appear to take any photographic evidence in inclusion with the previous forms where site licence breaches were observed.

How strange that Rhodia claimed the main entrance board was faded, and yet this one never got replaced.

31/12/2023

This in fact was not a visit to the site at all, but as explained, as failure of the now titled “Oldbury Energy Solutions Ltd” to supply monitoring data for 2023 as required. On this point, I would also point out that at no time whatsoever was the site notice board ever rectified to provide the details of this made up company where the permit was actually transferred to them by the EA! It just shows how shite the EA really are in that they failed to pick up on this, and evidently that was due to them not even bothering to visit the site themselves to check on compliance!

The schedule 3 condition 34 was added by them as a modification in relation to the closure of the site for waste.

I looked in detail at the mentioned HSE procedure P44 in this post. 

The category variables are explained below. To me this is all rather random and subjective. “Significant” and “major” are open to interpretation, but when the EA are not even doing testing themselves to independently verify anything being given to them due to operator self monitoring, they have even less clue as to assess anything. The difference in scores between the different bands are also rather random and do not really make much sense as to how this methodology was devised. A permit breach is a permit breach, and should not happen. This system appears to be widening the goal posts and making some conditions more important than others, which was not something devised when the conditions were first made.

There is no reason given as to why the agency allowed them a further 3 months to submit a report that should already have been submitted. How as a regulator are they in a position to judge a category breach when they have not even validated results they have not been supplied with? 

16/5/24

This visit by two EA officers was an actual site visit lasting 1 hour and three minutes. They appear to have been accompanied by a Trinity Street body, no doubt well versed in bullshit like all of their predecessors and a crucial job component.

Unfortunately, this was a limited assessment and so it comes as no surprise that they were not found to be in breach of the licence/permit.

What is incredible is the statement concerning the absent monitoring results that were asked for in the previous year. Despite this, the company had failed to provide all of the information, and taken together with the statement “phosphorus” had been written by hand, it strongly suggests that the results had been hurriedly made up.

They had had three months to submit this data, far too generous in my opinion and why if the tests and results had actually been done? The absence of borehole data is also telling, they are hiding results, and the EA are in the dark as to what is really going on with the chemistry and monitoring of the site. 

Incredibly, the EA officers give them another 3 months to provide this, when perhaps a visit to Trinity Street and waiting outside for them to be given would have been more in order. Where were the results, as it implies that they did not have them to start with , or were covering up the real story? Why is no inference given here by the EA, and why the rather apologetic pussyfooting around with demanding results, or finding the in serious breach? More relevant, as they were there, why did the officers not do the fucking tests themselves? Perhaps if they had, and then asked for the supposed results, we could see here how operator self monitoring is a bogus fraud suited for industry liars and their environmental consultants to conjure up bullshit fraud lying data to satisfy the weak assessment policy of the EA.

The hazardous waste sign was displayed, but no mention of which company were now actually on the permit given the previous site visit and name change, and also the discrepancy of the fact that they state Rhodia limited, then state that the director from “Oldbury Energy Solutions” was their chaperone. We learn here the claim that a “security guard” visits at weekends, and that site inspections are carried out once a month, with monitoring results every six months. And yet no real time data to show, or explanation as to why they had failed to give the EA the results for 2023.

Two boreholes are mentioned which can be identified in the locations on the map below. RC101 is located nearest to the homes in Callaghan Drive. You would think that this is a crucial monitoring point right, for the safety of those within feet residents? Borehole BC6 is located adjacent to the Duport’s Tip now owned by “Rattlechain redevelopments limited” who want to infill this lagoon, and no doubt blend in their offsite releases into the buried waste of another former company to hide the slimy tracks of the former foundry sand dumping tax dodgers from “Jersey”. 

Incredibly, these bastards then ask for a change in the permit by trying to extend the time taken to submit ERM’s highly questionable results to them. Instead of within one month for both April and October , they wanted to submit just one set of results by April of the following  year, just in time for their next made up results to be initiated! Maybe enough time for the white phosphorus to dissolve for ERM to confabulate a set of more bullshit?

They also raise the issue of permit transfer, which we now know took place at a later date.

23/7/24

This CAR form was again not a site visit but appears to be a review of the outstanding delayed monitoring results previously mentioned. There are some stark observations here which disgrace both this company and the EA themselves as to how far operator self monitoring is an utter fraud.

emailed late after deadline!

Despite the time extension, the site operators even failed to submit the results for the extended deadline as well! 

At this point of course it is wondered what had happened with monitoring for April 2024? It is revealed that a 146 page report had been submitted but that this appears to have been a partial exercise given the reported facts of the case. NB. I have asked for this report in another FOI request. 

The context of the groundwater borehole monitoring results makes it useful to again show where these locations are.

White phosphorus is found in four of the five locations, including RC102 and SA1101 at the canal.  It is found at BH3S towards John’s lane, and also the newest borehole installed at BH5A also near to the canal and the edge of the Duport’s tip land. This to me suggests the potential that off site migration of this toxic chemical is a distinct possibility, and not previously considered by the EA or anyone else. The levels are not the issue here, and of course we had that bullshit with Rhodia and levels found in the systemically poisoned birds when they had purposefully attempted to delay testing so the p4 levels would have been lower. It is rather suspicious that these results suddenly show up after the claimed 12 years of no p4, and further evidence that the delay of getting results to the EA had been entirely deliberate based upon these findings.

Alkalinity, chloride levels and ammonium at the closest point to the adjacent land- ie the foundry sand dump the owners want to tip into the lagoon, is noted to be rising.

All five groundwater points, including those nearest to Callaghan Drive show elevated heavy toxic metal concentrations, (Environmental Quality Standards). Not considered at least by the EA crucially is if these points are discharging via a pathway to surface water- i.e The River Tame ultimately via Johns Lane.

The EA state that further white phosphorus testing should be undertaken to establish the detected increase. On this point I would state that the EA themselves should have done their own testing to ensure that the results that this company have been providing for years were not being made up all along! They also ask the monitoring to be upped to four times a year to establish a clear trend. 

As for rising alkalinity, the EA fail to consider phosphine gas. They mention “white phosphate”, and on this point I am unclear as to whether they mean white phosphorus!

Quarterly monitoring required

Surface water testing is largely subjective, as one result could differ from another depending on which point they had sampled. It is interesting however that the two lagoons appear to have different issues, and that of course as we know, water pumped to the mainline canal is being done so from the larger lagoon, as the EA are also aware.

I would hope that no white phosphorus would be found in surface water, as that would fuck up their much heralded capping exercise would it not! We know that the white phosphorus is all still contained within the lagoon, but now questions about groundwater are relevant.

The Birmingham canal samples are dodgy to say the least. This canal as can be seen is utter crap in any case, regularly polluted by boat traffic and topped up by whatever shite comes out of the lagoon when it is on. Conveniently as is revealed, the samples taken were not done from out of the pipe into the canal as the pump was not switched on, and so are pretty irrelevant.

The EA throw a spanner in the works here, as the company will now have to make up dates that they probably have no records of.

In terms of ground gas, why are there no phosphine records! 

What is then revealed is that the EA trash the excuses of the late report, in that there was no delay in the white phosphorus reports being received and that it took the company 7 months to submit the reports to the EA for no apparent reason. I would state the reason was they knew the results contravened their previous results and the delay was entirely deliberate.

They also subtly ask for accreditation of the laboratory reports- thus questioning if these are credible. They refuse the absurd request made to delay providing the results to the EA and insert the need to do so after one month of the tests being carried out, and then every three months after that.

N.B I have looked at the report for June 2025 in this page as already stated, their last apparent visit.

NUMBER OF EA MONITORING VISITS AND CONCLUSIONS. 

Subsequent clarification by the EA has only provided just 9 reports in 12 years up to 2025.  

This compares to 182 inspection response forms, of which 71 recorded a breach of the permit waste management licence  between 1996-2006.

I think that statistic is utterly stark and shows how the EA has performed under the previous Conservative Government, and in particular under the leadership of the appointed former fuckwit crone CEO who now finds himself at the helm of a water company. The self operator monitoring of this site, instigated by this pricks design is shocking, but not unexpected given how the water industry also has been exposed to have had the same free pass blind eye treatment under his watch. THE ENVIRONMENT AGENCY HAVE BEEN MISSING IN ACTION FOR NEARLY TWO DECADES, AND THAT MATTER HAS BEEN ORCHESTRATED BY CIVIL SERVANTS WHO SHOULD FACE A PUBLIC INQUIRY UNDER OATH. 

  • It suggests corruption on a major scale and a joke of regulation and monitoring of a very dangerous site.
  • I wonder how many more rattlechain lagoons the EA have failed to inspect? Historic sites are poorly understood, and yet the EA newbies appear to rely on information from the liars running this company and operating the site.
  • The environmental consultants ERM also have serious questions to answer here regards their testing regime and the credibility of those tests and results. Their legitimacy is seriously questionable when the EA themselves have not verified any of them by doing their own tests.
  • Having no access to a site is also something that was shown in the documentary drama Dirty Business.
  • Unannounced visits and inspections are not carried out routinely, with only one being done according to this FOI request in all the years.

We feel that this underlines and proves our point on the way in which regulation of sites like this is broken, politically engineered that way and bordering on outright corruption. 

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