Comment

Draft Nottinghamshire Minerals Local Plan

Representation ID: 31994

Received: 28/09/2018

Respondent: Phil Langran

Representation Summary:

I object to the Minerals Local Plan as it does not contain a separate policy on shale gas.
Contrary to what is claimed, getting gas or oil out of shale rock is very different to getting 'conventional' hydrocarbons out of permeable rock formations which allow gas or oil to flow to a well head from some distance.
Shale has to be fractured underground using horizontal drilling and high volume hydraulic fracturing. This can only be done up to a mile or so from the wellhead, requiring wellpads every couple of miles - potentially leading to a industrialisation of the landscape.

Full text:

To whom it may concern

I wish to object most strongly to the proposed minerals plan on the following grounds

Nottinghamshire County Council's draft plan does not contain a separate policy on Unconventional Hydrocarbons, stating (para 4.109):
"It is considered that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development."
Contrary to what is claimed in the Draft Plan, getting gas or oil out of shale rock is very different to getting 'conventional' hydrocarbons out of permeable rock formations which allow gas or oil to flow to a well head from some distance.
Shale has to be fractured underground using horizontal drilling and high volume hydraulic fracturing (which has so far been done only once in the UK - at Preese Hall, Lancashire by Cuadrilla in 2011). This can be done only up to a mile or so from the wellhead, requiring wellpads every couple of miles (and repeated fracturing every year or so) - potentially leading to a widespread industrialisation of the landscape.

WHY IS THERE NO ACKNOWLEDGMENT OF THIS DIFFERENT SCALE OF OPERATION?

There are large areas which could be fracked for shale gas across the North and South West of the county. The whole of the East of the county could be drilled for coal bed methane.
Large parts of Notts are underlain by Sherwood sandstone with aquifers important for drinking water and agriculture. Much of Notts has also been subject to coalmining - with associated instability and subsidence, which means Ollerton is known as the earthquake capital of the UK.
Already, oil and gas company IGas has permission to drill at two sites in North Notts - at Misson and Barnby Moor. Chemical company Ineos has licences covering around 1,000 square kilometres around the Sherwood Forest area (including almost all of the area between Chesterfield and Ollerton and between Mansfield and Sheffield). If IGas and Ineos get their way this whole area will be covered in fracking rigs.

HOW WILL THE MINERALS PLAN PROTECT SHERWOOD FOREST AND THE REST OF NOTTS FROM THE LIKES OF INEOS AND IGAS ?

Why has Notts County Council ignored people's comments?
During a previous consultation on Notts Minerals Plan a wide range of people put forward a number of reasons why there needs to be a specific policy to control 'unconventional hydrocarbons', including:
* a legal requirement for Plan policies to reduce climate emissions (Planning & Compulsory Purchase Act 2004, s19(1A))
* industrialisation of the landscape - lorry movements, toxic gas haze, groundwater contamination, increased accident risk, occupational hazards
* horizontal drilling - requiring a 3-D site boundary and complex mapping of fault lines
* need for large amounts of water for fracking
* need to dispose of toxic flowback water
* precautionary approach to protect groundwater - particularly the Sherwood Sandstone Aquifer
* methane leaks making greenhouse gas emissions greater than for coal overall
* mapping to protect groundwater sources and sensitive sites
* toxic air emissions
* seismic activity, particularly in former coalfield areas
* many impacts are unavoidable
* difficulties of regulation due to scale
* damage to farming and tourism
* it won't bring the price of gas down
* very few local jobs
* ignoring evidence of seriously destructive impacts to health of local people, farm animals, wildlife, local economy, climate and local environment - which cannot be regulated away
Fracking companies do not have a good record. IGas has lost 96% of its share value in the last four years. Ineos has a deplorable environmental and health & safety record - with fires, toxic air and water pollution at a number of sites around the world, including the Grangemouth Refinery in Scotland. Large numbers of plastic pellets have been discharged into the North Sea.

Yours sincerely