Question 21: What do you think of the draft policy to meet demand for hydrocarbons over the plan period?

The Plan states at para 4.109 (p94): "It is considered that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development."

The key question is Q21 which asks: "What do you think of the draft policy...?" - or, in the case of unconventional hydrocarbons, the lack of policy.

We think the following:

Teversal, Stanton Hill and Skegby Neighbourhood Plan was supported by more than three quarters of those who voted in the required referendum, an illustration of the community's commitment to its policies and principles.

The regulations governing the preparation of the Plan required the Forum to undertake a series of consultations with residents, businesses and interested bodies. The results of those consultations informed Plan policies and, in particular, revealed that 92% of residents gave the surrounding countryside and access to it as being the reason they liked living in the area.

The Community Vision endorsed by the community states "In 20 years' time the TSS Plan area will be a prosperous and thriving community. It will value its rural heritage and high-quality natural environment. It will provide people with employment, education and relaxation. It will be a regenerated place where everyone can fulfil their potential."

Amongst the objectives flowing from this vision, Community Objective 7 is "To protect and maintain the trails, open spaces and access to the open countryside that make the TSS area so special."

The Community Objectives are the basis upon which the Neighbourhood Plan policies have been prepared.

The benefits of green spaces in terms of health and well-being and opportunities for social interaction are well documented. The TSS area has a wide variety of open spaces and green corridors, including disused spoil heaps that are now thriving natural environments. As an example, Ashfield District Council's Green Infrastructure and Biodiversity Paper make the following comments on reclaimed colliery sites:

"Coal heaps, former quarries, railway land, post-industrial sites and related open areas, provide some of the most valuable habitat for flora and fauna in the District. Often such sites are characterised by a rich diversity of native and introduced species. Large numbers of plant species have exploited these sites and formed communities ranging from short ephemeral grassland to scrub, which in turn supports a wide range of invertebrates, mammals and birds. Some of the sites in Ashfield support unusual communities and rare plants. Coal heaps may display Bee Orchid and Autumn Gentian, whilst providing a habitat for Grass snakes, Sky Larks and Little Ringed Plover."

The Paper particularly highlights the benefit of open spaces and countryside to areas of deprivation. Ready access to areas of unspoiled countryside is proven to be beneficial to both mental and physical health as places where residents can relax and take worthwhile exercise. They also offer opportunities for social interaction that can otherwise be difficult to achieve. Stanton Hill is one of the most deprived areas in the Country.

The Paper also highlights the benefit to tourism and thus the local economy offered by such spaces. There is huge potential to increase tourism, as an example the award winning Teversal the Caravanning and Camping Club site on Silverhill Lane is particularly popular. The development of lasting tourism opportunities would add to the local economy and play a part in much needed regeneration.

The TSS area contains a number of designated SSSIs, Mature Landscape Areas and Ancient Woodlands. Within sight of each other is Pleasley Pit, a Scheduled Ancient Monument, Hardwick Hall and Teversal Conservation Area with its wealth of listed buildings and the only functioning Grade 1 listed church in Ashfield (St. Katherine's). This virtuous triangle is highly valued by people from the locality and elsewhere for walking, cycling and horse riding, away from the hustle and bustle and their urban surroundings.

An essential element is the setting of each of these treasured assets. The importance of preserving the setting of both Hardwick Hall and Teversal Village is dealt with in Sections 14 (Protecting Landscape Character), 15 (Protecting and Enhancing Heritage Assets) and 16 (Improving Access to the Countryside). The Hardwick Setting Study 2016 identifies Stanley, Silverhill and the Sutton Plateau that are within the Neighbourhood Area as having an impact on the setting of Hardwick Hall. These areas have the same impact on the setting of the other heritage assets both within and bordering the Neighbourhood Area.

Paragraph 191 states: "...Teversal village has heritage significance and the Conservation Area boundary around the village was extended in 2012 to include part of the wider setting."

Paragraph 192 states: "The adopted Conservation Area Appraisal 2012 notes that 'In terms of its setting, the landscape surrounding the conservation area plays a significant role in the character of Teversal. The village is surrounded by an undulating, agricultural landscape which is practically unblemished due to the lack of man-made vertical structures. This helps to emphasize the old English rural character of Teversal.'"

The continued existence of unspoiled views and lack of industrial activity are essential to preserve these settings and Plan policies are weighted to reflect these concerns and were guided by this principle. Thus, a key theme running through the Neighbourhood Plan is to preserve the open countryside from intrusions that would have a detrimental effect both on the countryside itself and the health and well-being of those living and working in the Plan area.

The Neighbourhood Area contained three collieries until the 1980s and was defined by coal production. The sudden closure of those collieries has left a legacy of unemployment, lack of aspiration and a catalogue of social problems. Lacking effective intervention by central government, the Neighbourhood Forum has embarked on a long-term project to remedy these issues and create a thriving environment where everyone can reach their potential.

Forum members unanimously oppose any further hydrocarbon exploitation in the area which is now defined by its post-industralised character and offers new opportunities. The area is still dealing and coming to terms with the legacy of historical exploitation of its natural resources and welcomes the move away from carbon and the opportunity to re-define itself for the future. Any form of shale gas hydrocarbon exploitation in the area would be a retrograde step contrary to the expressed wishes of the local population.

The Forum's aim to improve the surroundings, well-being and life-chances of the some of the most desperate in the Country requires a long-term, focused and consistent strategy based upon preserving the area's assets and carrying out meaningful improvements where necessary. Shale gas exploration, in particular, would be at odds with the Forum's vision and perpetuate the issues that blight the area.

Minister, Greg Clark, in his introduction to the Localism legislation said:
"For too long the Government has hoarded and concentrated power...And it leaves people feeling "done to" and imposed upon - the very opposite of the sense of participation and involvement on which a healthy democracy thrives..... "We think that the best way of strengthening Society is not for central government to try and seize all the power and responsibility for itself."

Therefore, the people of Teversal, Stanton Hill and Skegby support the Nottinghamshire County Council in developing and implementing a Minerals Local Plan.

However, we believe that experience elsewhere and the growing scientific evidence shows that there are (for example) the following specific, special and very substantial threats from shale gas exploration and extraction in terms of:
* Community health risks from air and water pollution.
* Damage and destruction of valued amenities through industrial development and heavy transport on rural roads.
* A significant risk of triggering earthquakes, especially in an area of extensive old mineral workings.

We believe that these and other factors do provide justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development.

We therefore call upon the County Council to give proper consideration to the risks of Shale Gas Development and to develop a clear and well thought out specific policy for this.

The people of our three villages wish to hold the Council to account for this responsibility and require that their wishes as expressed in the Neighbourhood Plan are respected.

I do not agree with extraction of shale gas anywhere within the UK.
Hide the terminology, if you wish, we are not fooled. This is fracking and this process is not suitable for our small island. We are not the US. I have seen this in the US - it has been disastrous. Have you seen it?
Stop following this greedy government and put your countryside first.

The demand must be met in a sustainable way. Shale gas does not come in to this category.
The exploratory site at Misson Springs went over the time scale they were given. They were told not to continue during bird nesting periods and ignored this. This is the safety for our environment we can expect.
I will not accept this procedure in this country.

In view of the fact that shale gas exploration and exploitation is an issue which has generated significant discussion both nationally and locally, and the references in the text to potential reserves in the south of the county, it is suggested that Nottinghamshire County Council ensures that the views of local authorities in Leicestershire, (in particular Leicestershire County Council as the Minerals Planning Authority) are taken fully into account in shaping the wording of this policy, and in the consideration of potential applications in the vicinity of the County boundary.

Hydrocarbon extraction by hydraulic fracturing has been proved to be extremely damaging to the environment and has caused numerous health problems. Therefore I feel the draft policy is weighted unfairly in favour of 'fracking'. Only in exceptional circumstances should it be permitted to take place where it can be proved beyond reasonable doubt that it will cause no harm.

The policy is poorly drafted and ambiguous. What impact is unacceptable and on what criteria is that determined? Assessment should focus on RESERVES not resources.

Extraction should refer to exploitation of the reserve not resource.

Restoration should specify the standards expected - eg return to original condition - the wording used on Environmental Permits could be the basis for what standard might reasonably be a minimum; you could even ask for betterment of the land, linking it to a status where it is suitable for the next intended use of the land in accordance with in place or emerging local development plans.

NSDC is supportive, but would emphasise the importance of a thorough and robust assessment of impacts on the environment and residential amenity.

No comment.

The planning application to undertake exploratory drilling for shale gas at Springs Road was significant for being the first of this type that the MPA had to consider and notable for the length of time it took to determine. Whilst the MPA is required, through NPPF to support such applications there can be no doubting the widespread opposition to such proposals wherever they arise. In this instance the MPA consulted extensively with the local community who in turn felt that the process was fair and open. What will happen if permitted development rights are granted for this in future?

No comment

No comment

4.105 gives a brief outline of the fracking process. Unfortunately this process is much more dangerous to human health and to the environment than is acceptable for our communities. It would therefore be correspondingly difficult to devise appropriate environmental safeguards that could satisfy me of its feasibility here.

The Coal Authority supports this policy which identifies the individual elements of exploration, appraisal, extraction and restoration against which proposals for hydrocarbons will be considered.

Anglian Water is identified as a statutory consultee through Schedule 4 (zf) of the Town and Country Planning (Development Management Procedure) (England) Order 2015 in relation to development involving the boring for or getting of oil and natural gas from shale.

It is noted that the Draft Local Plan includes a single policy relating to hydrocarbon minerals including the proposals relating to the extraction of shale gas.

Reference is made to proposals from exploration through to extraction ensuring that it would not have an unacceptable impact on the environment or residential amenity. However no further guidance is provided in terms of what would constitute an unacceptable impact in this context or what is the required at each stage identified in Policy MP12: Hydrocarbons Minerals.

The policy relating to hydrocarbon extraction should specifically refer to water resources/environment and require applicants to demonstrate that there proposals would not have an adverse impact on potable water sources in the ownership of Anglian Water. This would include providing sufficient technical detail at the planning application stage about how any risks to potable water resources will be addressed.

Introduction
Frack Free Warsop is concerned about the effectiveness of the draft Minerals Plan in its current form to control and mitigate impacts from a fully producing shale gas industry, the development of which could happen within the Plan period.
The Minerals Plan will set the baseline of policy in Nottinghamshire for all types of mineral extraction for the Plan period, including fracking and other types of unconventional oil and gas extraction. Large sections of North Nottinghamshire fall within Petroleum Exploration and Development License areas; affected communities may become enveloped by fracked gas field development on an unprecedented scale during the Plan period.
The draft Minerals 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."

The following extract from Ryedale Draft Minerals Plan (5.120) defines the difference between conventional and unconventional hydrocarbon development, stating:
"Whilst a number of activities associated with shale gas development are similar to those associated with conventional hydrocarbons development, including the need for construction of a well pad and the operations involved in initial drilling of a well, there are also a number of significant differences. Examples include the potential for increased activity associated with the fracturing operations themselves, the expectation of the need to drill a number of horizontal wells from one or more well pads, the potential for high noise levels during periods of hydraulic fracturing activity, and increased traffic movements as a result of the need to bring in additional materials or water and remove waste materials."

Unconventional shale gas extraction using High Volume Hydraulic Fracturing techniques is new to Nottinghamshire and will require a "robust regulatory framework" to ensure the environmental risks and health impacts are minimized.
Consideration needs to be given to the cumulative impact of the development of potentially hundreds of wells across the Nottinghamshire countryside: the National Strategic Infrastructure Project consultation paper indicates the scale of intended development and the requirement for associated infrastructure, which is greater by far than the existing conventional wells operating in Nottinghamshire (DBEIS Initial Consultation Paper "Inclusion of Shale Gas Production Projects in the Nationally Significant Infrastructure Project Regime" July 2018). Such significant development will bring extensive industrialisation to rural areas, impacting air quality, water resources, traffic movement and public amenity, amongst other factors.
In order for the NCC Minerals Plan to properly carry out its planning function of controlling the use and development of land in the public interest and ensuring that new development is appropriately located, a specific and separate policy seems essential. The draft policy at present bypasses a useful opportunity to address many issues of public concern, including:
* Safeguard existing land use by specifying areas that should be protected from the impacts of unconventional hydrocarbons, especially already-designated areas of natural beauty, heritage, and water source protected, for example, and setting safety guidelines for distances from faults, old mine working, residences, etc. in case of blow-outs and explosions.
* 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
* water resource issues - large amounts of water for fracking; disposal of toxic flowback water; precautionary approach to protect groundwater - particularly the Sherwood Sandstone Aquifer
* evidence of seriously destructive impacts to health of local people, farm animals, wildlife, local economy, climate and local environment - which cannot be regulated away
* seismic activity, particularly in former coalfield areas
* the global consensus to move away from fossil fuels to combat climate change and move towards clean, green energy sources - the draft Minerals Plan states a presumption to support hydrocarbon developments, "provided they do not give rise to any unacceptable impacts on the environment or residential amenity." This does not specify criteria, nor defines what "unacceptable impacts" would be. Again, this is missing an important opportunity to move policymaking towards encouraging greener, sustainable development. Hydrocarbon use is neither sustainable, nor clean.
Legal precedent on establishing carbon neutral planning criteria has been set by Kirklees Council, who have included the following in their hydrocarbons policy statement, which has been approved by the Inspectorate:
"Policy PLP42
Proposals for production of hydrocarbons will be considered against the following criteria:
.......
h. Where a proposal demonstrates that it will have a net zero impact on climate change."

https://www.kirklees.gov.uk/beta/planning-policy/pdf/policies-and-strategies-2016.pdf
The National Planning Policy Framework states the importance of having a plan-led system with local plans setting out a positive vision for the future of the area.
"186. Local planning authorities should approach decision-taking in a positive way to foster the delivery of sustainable development. The relationship between decision-taking and plan-making should be seamless, translating plans into high quality development on the ground."
NPPF, March 2012
Both the draft Warsop Neighbourhood Plan and the draft Mansfield Local Plan have been developed through wide consultation with the communities and based on research and evidence thereby collected, grasping the opportunity afforded by Localism legislation to move decision-making responsibility to communities themselves.
Warsop Neighbourhood Plan (Draft)
Community Vision states: "Protection of the rural landscape will have kept the area as an attractive location to live. The sustained emphasis placed upon improving bus, cycle and pedestrian routes will have reduced the impact of traffic through the area, including on the A60, facilitating a more sustainable pattern of development in this part of the district."
Aims of the Plan include preserving, protecting and where possible enhancing the distinct and historic identity of the Parish, open countryside, important green spaces, local wildlife and biodiversity and promoting the health and well-being of residents.
The natural environment is one of Warsop Parish's greatest assets, being set within the attractive countryside on the edge of Sherwood Forest. Warsop's countryside is a special and important aspect to its character and valued by 92% of Community Questionnaire respondents.
Mansfield Local Plan (Draft)
2.28 "There is a need to put safeguards in place against possible contamination of water sources, especially areas designated as zone one aquifers. These are mainly around Market Warsop, Meden Vale and areas to the south of Mansfield urban area."
2.29 Key Issues... "A requirement to ensure growth and development takes fully into account sustainability issues relating to land use, climate change, air pollution, water quality and abstraction"
2.38 "One of the most significant attributes of the town (Warsop) is the green corridor along the River Meden, including The Carrs recreation ground and local nature reserve that connects to Pleasley Vale and Shirebrook. Not only is it a local hub for recreation, its position on the northern edge of Market Warsop makes it one of the most important areas of strategic green infrastructure in this part of the district."
The Plan stresses "The need to protect and manage important strategic areas of open land."
3.38 Mentions that "Sustained emphasis on improving bus, cycle and pedestrian routes will have reduced the impact of traffic through the area."
Objectives 5, 6 and 7 relate to ensuring the district is safe, clean, green and of a high quality; that all new development achieves a high standard of design to support sustainable development; ensures that development reduces, mitigates and adapts to the impacts of climate change .... whilst protecting residents' amenity from noise and visual impacts.
Both the draft Warsop Neighbourhood Plan and the draft Mansfield Local Plan highlight the importance of our green spaces, countryside and heritage sites with a vision of protecting and enhancing same, together with promoting the health and well-being of residents. The extensive development of shale gas extraction across the area will challenge the achievement of that vision, therefore it is imperative that the Minerals Plan should include comprehensive criteria to protect that vision, against which planning applications for shale gas development should be assessed.
Summary

Experience elsewhere, plus the growing body of scientific evidence shows specific and substantial threats from shale gas exploration and extraction in terms of, for example:

* Community health risks from air and water pollution.
* Damage and destruction of valued amenities through industrial development and heavy transport on rural roads.
* A significant risk of triggering earthquakes, especially in an area of extensive old mineral workings.

We believe that the above, plus other factors highlighted, do provide justifiable reason in planning policy terms to separate unconventional hydrocarbons from other hydrocarbon development.

Frack Free Warsop calls upon Nottinghamshire County Council to ensure the Minerals Plan provides more specific shale gas development policy through clear, comprehensive and detailed criteria addressing procedures, risk mitigation and emission reduction and is respectful of our Neighbourhood and Local Plan visions for our communities.

End of Response

(Information used in compiling the above statement was obtained from:
Draft Warsop Neighbourhood Plan
Draft Mansfield Local Plan
Draft Nottinghamshire Minerals Plan
National Planning Policy Framework
NSIP Consultation Paper DBEIS
Ryedale draft Minerals Plan
Kirklees Council draft Local Plan
Frack Free Ryedale website
Frack Free Nottinghamshire website
Teversal, Stanton Hill and Skegby Neighbourhood Forum)

Hydraulic fracturing should not be considered due to the environmental concerns regarding contamination of ground water, destabilisation of ground, release of radioactive radon gas and seismic activity. This process is banned in scotland and is likley to be banned in the UK if oppossition government come to power. Any licences granted will see significant opposition by campaigners and local politicians alike.

I am deeply concerned that there is no separate and detailed section on so called fracking as implications on the county and local communities are immense.Given our experiences in Misson and the complete contempt shown by IGas the community by naming our group in an injunction, we are reliant on clear processes that should be included as part of this plan.

As the county council you have a duty of care to both current residents and to protect the landscape and environment. I would urge you to take this on board and publish a more detailed plan which gives clear guidance on approaches to industrialisation of the countryside , impact on traffic management, groundwater controls and contamination as well as potential issues with horizontal drilling.

Hydraulic Fracturing for the extraction of natural gas from shale deposits ('Fracking').
An observation from Keyworth Branch Labour Party with regards to the NCC Minerals Policy.

Fracking is a means of extracting gaseous hydrocarbons, i.e. natural gas, from buried shale deposits by drilling vertical (then horizontal!) boreholes into a likely source of gas, using controlled explosions to fracture the surrounding rock and thus to increase its porosity, then using a carrier solution of various chemicals under pressure to further increase the rock porosity and extract the gas. This is not really a 'new' technology - similar processes have been used in 'over mature' oilfields, i.e. those coming to the end of their productive lives, for decades. Improvements in drilling technology over the years have, however, made the process more viable for the exploitation of shale gas resources.
The development and use of Fracking has, up to now, seen its greatest success in the USA where shale gas initially had a significant output and did bring down the price of natural gas. This was mainly due to the particular geological conditions in the USA, where shale-hosting sedimentary basins are large (hundreds of square miles) and have undergone relatively light tectonic deformation. Unlike in the UK, where such basins are much smaller and more strongly deformed. However, there are already signs that the initial success in the US is proving to be short-lived as production costs rise and profits in this sector have tumbled. Clearly the 'low-hanging fruit' have already been picked. Some large companies are already pulling out of the sector, unable to make sufficient returns on their investments.
However, even with the relative early success of Fracking in the US, some serious problems have arisen, especially environmental concerns mostly regarding possible leakage of gas and extraction fluids into aquifers and consequent contamination of water supplies. There have also been examples of minor earth tremors associated with the initial exploration and production stages. There are also infrastructure issues regarding the drilling stage and access for either road tankers or pipelines to transport the gas away from the site and maintain the pumping equipment.

'Fracking' in the UK - and more local matters.
Does the UK really need a Fracking/shale gas industry?
Even under optimum geological conditions (which we don't have in the UK), it is unlikely that, even with extensive development, shale gas will ever be a major component of the UK's energy sector. Given the difficulties involved it seems unlikely that development would proceed without large taxpayer subsidies, making the economic justification for this very fragile. Nevertheless, the Conservatives had the 'development of a shale gas industry' in their 2017 manifesto. This rather suggests that they are keen to transfer taxpayer's money to the shareholders of the Fracking companies with very little benefit for the general public.
Anyway, why do we need to expand another industrial producer of greenhouse gases when the energy sector is already moving towards renewables? Surely investment and public subsidy, if required, should be directed into this area along with emerging and more environmentally sound 'green' technologies.
Would a shale gas industry create a significant number of jobs? Apart from some extra work for specialist drillers, a handful of jobs in construction, a few drivers and security guards, not many. Far more jobs could be created by investment in the renewable energy sector.
Environmental impacts.
Now, many industries have a negative impact on the environment. Our historic heavy industries such as mining and steelmaking are prime examples of this, so we should not automatically decry a 'new' industry because of its possible environmental impacts - though, of course, these should be minimised. However, with Fracking there are both visible environmental impacts arising from the construction of the extraction infrastructure, and potentially more damaging 'invisible' impacts arising from contamination of groundwater.
The latter is of particular interest in our area where Fracking companies are keen on exploring the shale resources of the Widmerpool Basin, a largely buried sedimentary basin in the East Midlands lying mainly to the south and east of Derby. The shales in this basin are the deep-water contemporaries of the white Carboniferous Limestones of the Peak District, about 300 million years old. These deposits are mainly rather organic-rich dark bituminous mudstones. The shales may well be rich in hydrocarbon gases, but they are also rich in a number of trace elements, notably cadmium, uranium and molybdenum, which may have toxic effects under certain conditions. To work the deeply-buried Widmerpool shales the drilling operation would have to pass through the Sherwood Sandstone, the most important aquifer for both public and industrial water supply in the East Midlands (and the main water source for the brewing industry in Burton). The environmental, economic and health impacts of contaminating this aquifer with either Fracking fluids or liberated soluble cadmium, molybdenum or uranium in solution would be highly significant, and little short of disastrous.
Similar concerns regarding Fracking have been widely expressed, and many local authorities have already moved to ban exploration and development on the basis of the risk of serious environmental damage. Some nations, such as Ireland, have also banned Fracking on this basis.
In the circumstances, we recommend that Fracking should not be permitted by the local authority until there has been a much more rigorous investigation of the risks involved and a full cost-benefit analysis, including legal liabilities for environmental damage, has been carried out.

I am appalled and alarmed that the new draft Minerals Plan fails to contain a separate policy on Unconventional Hydrocarbons, and that Notts County Council planners consider that there is no justifiable reason in planning policy terms to separate shale gas from other hydrocarbon development. How can this be, when it is a completely different process from the extraction of 'conventional hydrocarbons', and comes with far greater risks to the environment and to people?

I am aware that many comments and "justifiable reasons" were submitted to the County Council earlier this year by concerned groups and individuals who had done plenty of research into the industry, and would like to know why these comments from the public appear to have been ignored?

The draft Minerals Plan does not appear to protect our beautiful countryside - Sherwood Forest, for example - from becoming industrialised and turned into a gas field, given that the unconventional hydrocarbon industry requires the construction of many well pads two to three miles apart. Why?

Large parts of Nottinghamshire have been subject to coal mining and as such are unstable; large parts of the county are also underlain with sandstone aquifers providing drinking water. The risk of earthquakes in these areas from seismic testing, exploratory drilling and subsequent fracking is very real, and the potential risk to drinking water is frightening. I would particularly draw your attention to the work of Professor Peter Styles - former adviser to David Cameron, former President of the Geological Society of London, a project leader with the ReFine fracking research project and previous Head of Geology at Keele University - who says the fracking process could lead to seismic activity by stimulating faults in geology that has already been stressed by mining. The Professor knows his subject and attention must be paid to what he has to say. His report can be studied here:
https://www.keele.ac.uk/media/keeleuniversity/facnatsci/schgge/news/2018/Fracking%20and%20Mining-%20Styles%202018.pdf

Given, too, that there may well be areas of very old mining activity for which no records even exist, I find the lack of a specific policy on shale gas to be incomprehensible and would urge you most strongly to incorporate such a policy into the new Minerals Plan.

I look forward to your response and hope to see a revised draft of the Plan following the consultation.

I, strongly, object to exploratory drilling which may lead to full fracking on the following grounds:

* industrialisation of greenbelt land
* possibility of underground water source being contaminated
* pollution - from chemicals used in the drilling process and the fumes from increased hgv movements
* possible seismic occurrences
* use of huge amounts of water - allowed in drought conditions when the public is expected to conserve water.
* Ecology - vibration, lighting, noise will affect the habitats of local wildlife

Finally, the Govt should be moving away from the use of fossil fuel to renewable energy by 2020.

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

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, (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.
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

Good afternoon,

I would like to see an adjustment to the above plan to make shale extraction of hydrocarbons a different consideration that extraction from permeable rock.

Please could this be taken into consideration as they are such different extractions.

Kind regards

Dear Sir/Madam
I'd like to provide comments ahead of the new minerals plan being made, regarding unconventional hydrocarbon extraction.

Firstly, it is increasingly recognised that we must reduce our dependence on hydrocarbons as soon as possible, as recognised by the UN Secretary-General in his recent speech. If we use gas to "bridge to a lower carbon economy" over the next 10 years or so, it could well be too late. County councils should recognise this and play their part in creating a future for our country by supporting renewables.

Secondly, even if unconventional extraction of hydrocarbons goes ahead, it should not go ahead in Nottinghamshire without significant further study. Professor Styles' recent report highlighted the risks of fracking in former coal mining areas. Permission has been given for drilling at Tinker Lane in Bassetlaw, without a full picture of the underlying geology. This could result in seismic events and damage to properties and businesses. Who will pay for any resulting damage? Landowners, the drilling companies and the Coal Board are unlikely to feel responsible

Finally, even without these issues, the record of the drilling and fracking industry to date is poor. There is little consideration given to the health and safety of local communities- fracking is imminent in Lancashire despite there being no evacuation plan for local people. As far as I am aware, there is no evacuation plan for the Tinker Lane site in Notts, where drilling is imminent. Even drilling could involve the risk of catastrophic well blow outs - and yet it is not deemed necessary for local people to know what to do if this happens.

Applications to drill and frack are made that include unsatisfactory HGV routes, or locations that threaten local drinking water supplies or protected wildlife species. And let's not forget that to date, the only frack carries out on the UK resulted in an earthquake.

Finally, the government's proposals relating to PD and NSIP will further endanger our county, especially given the coal mining issues.

Nottinghamshire county council has so far given permission for drilling (for shale gas exploration, and previously for CBM). I hope that with the developments in the past year the MPA sees that unconventional hydrocarbon extraction is not the responsible choice for Nottinghamshire or for Britain.

You are going directly against the wishes of the people of the County by including fracking in any plans for us. Whole countries have decided to ban fracking. Why wait until our beautiful county has been despoiled? Be brave and do the right thing. Ban fracking, or take the blame when it all goes wrong.

Having studied the New Minerals Local Plan I would like for the following point Re. Shale Gas Extraction to be taken into consideration:
Can Nottinghamshire County Council clearly demonstrate that it has the resources and expertise in the Departments of 'Health and Safety Executive' and the 'Environment Agency' to recognise 'Gold Standards' in the fracking industry bearing in mind that this industry is very new in the UK, and also as the Government has slashed Council budgets by 50% since 2010. I read with interest on the Community Liason Groups page/Resources that the HSE will be working from a publication "A guide to the well aspects of the Offshore Installation and Wells Regulation"
Cuadrilla's first fracking attempt in 2011 produced seismic events which cracked the casing of the well which was not discovered until some 12 months after the event which demonstrates a lack of expertise and resources by the regulating authorities in this country.
Can Nottinghamshire County Council assure particularly the communities affected by Shale Gas Extraction that this industry will NOT be self regulating and - in detail - how the vast quantities of toxic waste/frack water will be dealt with so there is NO contamination anywhere in this county or surrounding counties.

I would like to comment on the draft Nottinghamshire Mineral Plan for the following reasons:

There is no separate consideration for Unconventional Hydrocarbons. The recovery of gas from Shale rock is a dangerous and potentially polluting business, that will need extra restrictions and safety measures. It is far more hazardous than other mineral extraction operations taking place in the county, such as gravel extraction. The fact that Shale gas has to extracted using Hydraulic Fracturing means that there is a potential for subsidence and earthquakes particularly in areas where there are underground tunnels left by coal mining. The large Aquifer under Sherwood Forest is also at risk of pollution, if the chemicals used in the water remain in the ground after the gas is extracted. It has been reported that this can happen with up to 40% of the chemicals in the water used to extract the gas, being left. If these chemicals enter the water table, they can create serious pollution. Some of them are carcinogenic and others effect people hormones.

The Fracking companies operating in Nottinghamshire - Island Gas and Ineos do not have good records. I Gas have used unreliable debt finace and has lost 96% of it's share value in the last four years. INEOS has a really bad 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. [bit.ly/awful-INEOS]

I hope that you will reconsider this part of the pan so that people and the environment in Nottinghamshire remain safe. Nottinghamshire is full of important Historic and Ecological areas which need to be protected from the activities of unscrupulous companies like IGas and INEOS. To do this I believe that you must separate Unconventional Hydrocarbon extraction from other mining and extraction activities.

To whom it may concern,
I am writing in response to the draft Minerals Plan.
I am concerned about the lack of a separate policy on unconventional hydrocarbons, particularly as I believe there was a substantial demand for this in a previous consultation. As I understand it, extracting shale gas is very different to more 'conventional' hydrocarbons, and the technique is incredibly underdeveloped in the UK. Particular care would need to be taken to protect the landscape in 3D, including mapping of fault lines and coalfields, protection of groundwater and prevention of methane leaks which would contribute to further greenhouse gas emissions. There is a requirement for huge amounts of water, and the subsequent disposal of toxic flowback. I also feel that any speculative drilling will open the flood gates to a widespread industrialisation of the county that will be impossible to regulate. I am worried about the damage to farming, tourism and living conditions that will arise from increased lorry movements and toxic air quality.
Primarily, I am deeply concerned about the contribution of a new fossil fuel to climate change. Is it not a legal requirement for Plan policies to reduce climate emissions (Planning & Compulsory Purchase Act 2004, s19(1A))? I feel that 'fracking' at the expense of sustainable alternatives is both illogical and immoral. Furthermore, I am astounded and saddened that the local council and the national government consistently seem to ignore people's concerns and evidence of the profoundly destructive impacts to health of local people, livestock, wildlife, local economy, local environment and global climate.
I urge Nottinghamshire County Council to address unconventional hydrocarbons in the detail required.