Draft Nottinghamshire Minerals Local Plan

I would like to submit the following response to the Notts county draft mineral plan consultation on behalf of Warsop parish council.

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.

Warsop Parish Council call 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.