Other Contamination Routes From the Hillhouse Site, Never Assessed
The Phase 3 report states, in passing, that the wider Part 2A inspection (the council's official contaminated-land process) covers 'other linkages of concern' beyond soil, including risk to the water environment. It never names them, never says where or when they are being assessed, and never mentions them again in sixty-six pages. That is a documentation gap worth asking about.
From the Environment Agency’s Phase 3 soil investigation of the Hillhouse site.
Every fact below comes from the public version of the WSP Phase 3 Factual Report, commissioned to investigate PFOA and wider PFAS contamination around the AGC Chemicals Europe plant, formerly ICI, at Hillhouse, Thornton-Cleveleys, published by Wyre Council: wyre.gov.uk/downloads/file/2452/phase-3-factual-report. Page numbers refer to that PDF, so the underlying page can be checked directly.
One sentence, on page 11, says there is more to this investigation than soil. It is the only sentence in the report that says so.
The report names a risk it does not describe
Section 1.2, setting out the project context, states plainly: “Whilst this report considers contaminant linkages associated with health risks from potential soil contamination, the Part 2A inspection also includes other linkages of concern from the facility, including the risk to the water environment” (p.11). (“Part 2A” is the council’s official process for identifying and managing contaminated land.) That is a direct admission that the investigation, taken as a whole, is looking at more than the shallow-soil pathway this report covers. It names one of those other linkages outright: water.
Then it stops
Nothing that follows says what the other linkages are, beyond water. Nothing says what the risk to the water environment consists of, whether it means groundwater, surface water, or both. Nothing says what the consequences would be if it went unassessed. Nothing says where or when that work is happening, who is doing it, or what protects anyone in the meantime. We read the rest of the report, all sixty-six pages of its main body, looking for a second mention. There is not one.
What the report’s own framework asks for
The same section cites the guidance this investigation is meant to follow: “EA, 2020, Land Contamination Risk Management (LCRM)” (p.11), the government’s standard approach to exactly this kind of assessment. A risk-management framework of that kind exists precisely so that a report does not just note that a pathway is being looked at elsewhere and move on. It exists so that uncertainties get written down, so that what is not yet known is stated alongside what would follow from it, and so that any gap has an interim answer, even if the answer is “not yet assessed, here is what we are doing about it in the meantime”. Naming a risk and citing the framework built to manage it, in the same paragraph, and then supplying none of that, is worth asking about against the standard the report names for itself.
We are not saying the water risk was ignored. We are saying this report doesn’t tell you what happened to it.
This is not a claim that the risk to the water environment has gone unassessed, or that residents are unprotected from it. WSP and the Environment Agency may have entirely good answers, in another document, another phase, another track of the same investigation. The report itself simply does not say so. On the evidence of the published text, a reader is told a second risk exists and given nothing else: not its scope, not its timeline, not its owner, not any interim safeguard.
We are asking this openly, and putting it directly to WSP and the Environment Agency. Any response will be published here.
How we know what we know
Everything above comes from one public document: the WSP Phase 3 Residential Soils Investigation, published by Wyre Council in March 2026 (link above). The single sentence naming the water-environment risk is Section 1.2, page 11. The guidance it cites is referenced in the same section and listed again at Section 1.6, page 14. We searched the full text of the report’s main body for any further mention of “water environment” or “other linkages” and found none. Nothing here is our interpretation of unpublished data. It is the report’s own words, and the silence that follows them.