Object

Representation ID: 287

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? No

Sound? No

Duty to co-operate? No

IGas notes paragraphs 4.96 - 4.100 remain unchanged (other than the deletion of 'very intensive' from 4.100). !Gas remains of the view that the approach being taken is not positively prepared and does not reflect the advice within NPPF or the Joint WMS of 17 May 2018 and WMS of 23 May 2019.

Whilst the introduction sets out the background and approach for shale gas and acknowledges there is a potentially significant shale gas resource within Nottinghamshire, IGas is concerned that the Plan continues to fail to make refeirence to the potential benefits of a shale gas industry within the UK or the Government support within the Planning Practice Guidance to the NPPF or the WMSs. There is a clear recognition of the contributions the shale gas industry could make towards a diversity of energy supplies at the national level and, for consistency, this should be reflected within the MLP.
The Planning Practice Guidance (PPG), originally published by the Department of Communities and Local Government (DCLG) in March 2014, at Minerals paragraph 91 (reference ID: 27-091-20140306) states that " as an emerging form of energy supply, there is a pressing need to establish - through exploratory drilling - whether or not there are sufficient recoverable quantities of unconventional hydrocarbons such as shale gas
.. ....present to facilitate economically viable full scale production." A Government supported Ernst and Young supply chain report (Getting ready for UK shale gas, April 2014) indicated 'there could be significant benefits for jobs and growth from a successful UK Shale Industry: over 64,000 jobs at peak could be supported across the wider economy, with more than 6,000 jobs on shale pads themselves. Many of these would be highly skilled, high quality jobs, with above average pay.'

A combined shale gas and oil policy statement by DECC and DCLG (15 August 2015) states:

A national need to explore and develop our shale gas and oil in a safe, sustainable and timely way. Exploring and developing our shale gas and oil resources could potentially bring substantial benefits and help meet our objectives for secure energy supplies, economic growth and lower carbon emissions. The Government therefore considers that there is a clear need to seize the opportunity now to explore and test our shale potential.

These comments were reiterated within the JWMS 17 May 2018. There is a clear intention at Government level to seize the opportunity now to explore and test the country's shale potential and this support should be explicit within the Plan.

Whilst the changes to policy MP12: Hydrocarbon Minerals are welcomed, part 1b) still requires exploration and appraisal developments to be located where they will not have an unacceptable environmental impact. Such an approach is not in accordance with the NPPF as there is no weighting provided on the level of environmental asset and whether it is of international, national or local significance.

IGas welcomes the changes to the Justification in paragraph 4.104 which recognises the national need to explore and develop new domestic sources of oil and gas.

IGas notes that paragraph 4.110 continues to state, a PEDL 'allows a company to pursue a range of oil and gas exploration activities ... ' which appears to have been derived from the UKOOG description of PEDLS. The PEDL licences actually place an obligation on the holder to explore and develop for hydrocarbons. In its current form, the paragraph suggests pursuing an interest is an option when in fact it is a requirement as set out in the guidance by the Oil and Gas Authorit y1; this should be amended.