Representation
If the Plan is to achieve aims of sustainable development, not compromising future generations, ensuring no unacceptable impacts on natural and historic environment, human health and residential amenity and "engaging with and supporting communities affected by minerals development", it must prioritize robust protection against the known unacceptable impacts of the Shale Gas Industry instead of facilitating the development of the Shale Gas industry. Planning permission for shale gas must not be granted unless it is demonstrated beyond all reasonable scientific doubt that any risk of adverse impacts has been eliminated.
SG development cannot be compared to previous conventional oil/gas activities; unconventional high volume hydraulic fracturing is new to the UK; the number of drill sites proposed is unprecedented - Ineos propose 15 drill sites per 6 mile square license area (10-12 wells per site) effectively industrializing huge areas of rural landscape.
Special Areas of Conservation and future Special Protection Areas are already under threat from unacceptable impacts e.g. Sherwood Forest faces underground fracking and intrusive seismic surveying; Ineos threatening court action at Clumber Park for refusing the intrusive surveying procedures; archaeologically important Thynghowe Viking assembly site is very close to a possible exploratory drill site. Ecological, conservation and wildlife issues must be made a priority if we are to preserve our countryside for future generations. In addition:
Robust protection within the Plan will be essential for:
* Groundwater and surface water - Millions of gallons of fresh water needed per frack with no infrastructure yet to deal with huge increases in levels of toxic flow back waste - Groundwater already under stress from demand and other forms of pollution; dumping into rivers should be absolutely forbidden unless the treated water is free from any toxins/radioactivity. Protecting farming areas/produce from water/air contamination risks. Development should not be allowed to commence until all necessary infrastructure is in place. Well integrity failure, a big risk in an area of increased seismic activity like Ollerton, is a known cause of aquifer contamination.
* Many studies done to date shows regulatory system currently inadequate to control a largely self-regulating industry with a poor track record for pollution and safety issues. Cumulative effects of multiple well sites must be taken into consideration with each application for realistic appraisal. Reduction in funding for monitoring/enforcement agencies is a serious concern. Plan policy must ensure that all required standards are fully implemented without exception. Environmental samples should be taken by an independent organisation ahead of the commencement of any operations to provide baseline figures to ensure public confidence in any monitoring procedures.
* Known emissions from producing shale gas wells are benzene, ethylbenzene, methane, ozone, toluene and xylene, all of which are harmful to the environment/human health and wildlife. Increased HGV traffic - emissions reduce air quality; increased road congestion/accident risk. All go against existing policies aimed at increasing air quality and reducing climate changing impacts.
* Protecting the human rights of residents to live without increased risk from: reduced air quality and scientifically-proven health risks, noise and light pollution, stress.
* Economic impacts from increased industrialization of an area of tourism and agriculture, loss of tourism jobs, risks to farming from water shortages, contaminated water/air, and the impact of reduced house values.
* Ensuring that companies who wish to engage in SG extraction are able to fulfil their obligations regarding the decommissioning, decontamination and restoration of any sites and compensation for health issues caused, without the risks/costs falling on the taxpayer/landowner/local authority should the company fail. Other issues - handling of abandoned wells and their future leakage, possibly thousands throughout Notts, and compensation for any resulting long term impacts. Clarification of the responsibilities of local authority and central government to deal with the cost of any long term environmental/health issues is essential.
* Ensure voices of the communities who live in the proposed gas field are heard, prioritized and acted upon! -"engage with and support communities affected by minerals development"
* Contravenes Nottingham Declaration on Climate Change - not moving away from fossil fuels even when SG is not essential to the UK's energy future (government report October 2017).
Resource material available to back up the above points, not included for reasons of space!