Comments from Frack-Free Nottinghamshire 27-9-2018

These comments are written on behalf of Frack Free Nottinghamshire (FFN) which is part of a national movement that opposes unconventional hydrocarbon extraction by means of hydraulic fracking. It acts as an umbrella/support group for other more local frack-free campaign groups across the county.

We are taking the opportunity to comment again upon this repeat Local Plan exercise, although Minerals Planning Authority (MPA) officers will recognise that many of our concerns on the Hydrocarbons section have been aired at previous stages of the Plan's preparation. However, we have found that they have been generally (and unjustifiably) overlooked, often with little coverage in the Council's reports of consultation.

For instance, in the latest Draft Plan the box that heads the chapter on Hydrocarbon Minerals, the main thrust of our submission (and comments from FoE and several individuals) that unconventional hydrocarbon exploration and production requires a separate policy approach has been omitted. Hence we would argue that the Committee and wider public has been misled about the real " focus" of these comments which emphasised how its scale and other factors make hydraulic fracking (or fracturing) for shale gas a special case in addition to its adverse impacts on local communities, groundwater and wildlife etc.

Consequently we are re-submitting the comments made in January this year on the Issues and Options consultation (see attached), and intend to reinforce the points made there in favour of a separate policy approach -as has been favourably greeted by the Inspector at the ongoing Public Examination of the North Yorkshire Minerals & Waste Local Plan. We also argue that there is thus even less justification for promoting or supporting fossil fuel extraction in the light of increasing evidence that the climate is in crisis and cannot easily adapt to its existing carbon loading.

The MPA maintains that "..there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development ".
In disputing this statement, FFN insists that there should be a distinction (as agreed in North Yorkshire) and that it is too complacent of the MPA to rely on applying the same Development Management policies that the Draft Plan prescribes for conventional hydrocarbons and other mineral activities whose impacts are well understood. We have listed our preferred justifiable reasons below:

a) the Draft Plan needs to recognise the different scale and techniques of operation employed by companies that undertake hydraulic fracking as opposed to conventional oil and gas extraction from less deep permeable rock, and also that these more aggressive techniques ( at depths up to km) are relatively unproven as yet in the UK.
As has been recently recognised by the Government in anticipating that some fracking proposals might be classified at NationalIy Significant Infrastructure Projects, there is potential for extensive infrastructure, ie multiple well-pads,roadways,lights and pipelines etc., capable of industrialising the countryside, disrupting agriculture and overwhelming local communities.

b) the Government has recently been warned by a report from Professor Styles of the risk that deep fracking can trigger seismic activity in former mining areas (Ref: Prof Styles Report). This is a legitimate, additional concern for an MPA, and in the light of Government proposals to introduce permitted development rights for exploratory drilling, it is suggested that tighter rather than looser regulation should probably apply in Nottinghamshire. Since there are regular tremors recorded in parts of the county, the MPA must view seismicity reports from the appropriate regulator with great care.

Also, greater attention to and more community involvement in emergency planning procedures is required given that drilling/fracking activities can give rise to serious incidents (such as blow-outs) affecting public health across a wide area. In this connection, it would be wise for the local plan policies to establish minimum buffer zones and well-pad density as per the North Yorkshire Local Plan.

c) The safeguarding of the Sherwood Sandstone and other aquifers in Nottinghamshire for its value in providing drinking and process water for the county is crucial as the consequences are very long-term if breaches occur during or after deep drilling. The potential for leakages via damaged or corroded well-pipes and surface spills that can pollute this vital resource is so high (Ref: USA experience) that groundwater integrity should be subject to a precautionary or no tolerance approach. We believe that Policy SP6's reliance on the prospect of such impacts being "adequately mitigated and/or compensated for" is ill-conceived and should not apply to fracking activities. In addition we recommend a strengthening of DM2 to ban frack-drills through major aquifers because, in accordance DM2 1(c), we understand it to be an "unacceptable risk".

d) Since the aim of fracking is to extract high volumes of methane gas, the process has considerable potential to release carbon emissions and to leak methane into the atmosphere -mainly during the construction and production phases. Furthermore, it should never be overlooked that the end product is a fossil fuel whose use the Government and the County Council are duty bound to reduce (by virtue of planning law) in order to address climate change. Whilst this is recognized by the revised NPPF in paras 149 and 151, its emphasis on renewable and low-carbon energy sits uncomfortably with the positive view of onshore oil and gas development urged upon MPAs in para 209(a) elsewhere in the document.
Whilst generally approving of Policy SP4, we would advocate the deletion of para 3.37 which allows energy minerals to be treated as an exception, and the replacement of "help reduce" with "consistently minimize" concerning GHG emissions in 1(a).

e) There is a real issue with fracking company debt, as explained in our Issues and Options submission (p.3) and the prospect of sites being abandoned at considerable eventual cost to the public purse. Whilst the County Council has seen fit to require financial bonds from developers to insure against this risk, it should not be assumed that their operations (or that of their successor companies) will always remain viable -which will need to be better reflected in implementation policies and planning conditions.


Finally we wish to query the Government's strong support for the fracking industry as a response to predicted future energy shortages. This is echoed in para 4.106 by the drive for less dependency on imports, which supposedly prompts a need for "a very strong impetus to explore and develop new domestic sources of oil and gas" including "previously untapped unconventional sources such as coal bed methane and shale gas".
We suggest that, apart from dangerously delaying action on climate change, this response to depletion perpetuates the failure to recognise its inevitability, and that increasingly costly ventures (in commercial, social, environmental and energy terms) to explore and extract fossil fuels will eventually become unaffordable. The real response would be to prioritise effective plans and programmes to boost energy conservation and renewable schemes throughout the local economy.