Nottinghamshire Minerals Local Plan Publication Version
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Nottinghamshire Minerals Local Plan Publication Version
MP12: Oil and Gas
Representation ID: 47
Received: 08/10/2019
Respondent: Stapleford North Town Council
Legally compliant? No
Sound? No
Duty to co-operate? Yes
The policy is not legally compliant as no future site-specific proposals for hydrocarbon extraction in the area are included in the emerging minerals plan. No sustainability appraisal (SA) has taken place specifically for Petroleum Exploration Licence (PEDL) areas.
Paragraph: 106 Reference ID: 27-106-20140306 states:
Criteria-based policies for each of the exploration, appraisal and production phases of hydrocarbon extraction. These policies should set clear guidance and criteria for the location and assessment of hydrocarbon extraction within the Petroleum Licensed Areas.
The policy is insufficiently clear in terms of guidance and criteria as it is reliant on the Environmental Impact assessment regulation (2011) which is generic for all developments. The objectives of the SA are more appropriate for aggregates than unconventional gas extraction. specifically:
Sustainability objective 11. Protect and improve local air quality.
5.13 and 5.14 do not cover all aspects of potential air pollution due to unconventional gas extraction. Methane leakage will be much harder to control and is far more serious. It is well established that air pollution is associated with unconventional oil and gas extraction; this includes primary emissions of nitrogen oxides (NOx), volatile organic compounds (VOCs) and dust, and secondary pollutants such as ozone.
Sustainability objective 12. Protect and improve water quality and promote efficient use of water. Vast amounts of water are required for unconventional gas extraction (circa 6 million gallons, which could mean 60m gallons per drilling site if there are 10 wells). The policy and supporting documents are insufficiently clear as to how they will ensure that a detrimental effect is avoided due to the abstraction of water (which may need to be transported from elsewhere). There is no clear definition of what classifies as an unacceptable impact in policy DM2
Sustainability objective 14. Protect and improve human health and quality of life. In addition to the safety risk to those site workers in the immediate area of unconventional gas extraction, examples from the US suggest that local residents could require evacuation. This is not a consideration covered by the policy.
The policy is not sound. In March 2016 the Government declared its intention to legislate for a zero carbon economy by 2050. The policy does not meet Sustainability Appraisal Objective 7 Minimise any possible impacts on, and increase adaptability to, climate change. The burning of fossil fuels contributes to climate change. Additionally promoting unconventional gas extraction would appear to be inconsistent with Sustainability Objective 10. Promote energy efficiency and maximise renewable energy opportunities from new or existing development.
The policy is not legally compliant as no future site-specific proposals for hydrocarbon extraction in the area are included in the emerging minerals plan. No sustainability appraisal (SA) has taken place specifically for Petroleum Exploration Licence (PEDL) areas.
Paragraph: 106 Reference ID: 27-106-20140306 states:
Criteria-based policies for each of the exploration, appraisal and production phases of hydrocarbon extraction. These policies should set clear guidance and criteria for the location and assessment of hydrocarbon extraction within the Petroleum Licensed Areas.
The policy is insufficiently clear in terms of guidance and criteria as it is reliant on the Environmental Impact assessment regulation (2011) which is generic for all developments. The objectives of the SA are more appropriate for aggregates than unconventional gas extraction. specifically:
Sustainability objective 11. Protect and improve local air quality.
5.13 and 5.14 do not cover all aspects of potential air pollution due to unconventional gas extraction. Methane leakage will be much harder to control and is far more serious. It is well established that air pollution is associated with unconventional oil and gas extraction; this includes primary emissions of nitrogen oxides (NOx), volatile organic compounds (VOCs) and dust, and secondary pollutants such as ozone.
Sustainability objective 12. Protect and improve water quality and promote efficient use of water. Vast amounts of water are required for unconventional gas extraction (circa 6 million gallons, which could mean 60m gallons per drilling site if there are 10 wells). The policy and supporting documents are insufficiently clear as to how they will ensure that a detrimental effect is avoided due to the abstraction of water (which may need to be transported from elsewhere). There is no clear definition of what classifies as an unacceptable impact in policy DM2
Sustainability objective 14. Protect and improve human health and quality of life. In addition to the safety risk to those site workers in the immediate area of unconventional gas extraction, examples from the US suggest that local residents could require evacuation. This is not a consideration covered by the policy.
The policy is not sound. In March 2016 the Government declared its intention to legislate for a zero carbon economy by 2050. The policy does not meet Sustainability Appraisal Objective 7 Minimise any possible impacts on, and increase adaptability to, climate change. The burning of fossil fuels contributes to climate change. Additionally promoting unconventional gas extraction would appear to be inconsistent with Sustainability Objective 10. Promote energy efficiency and maximise renewable energy opportunities from new or existing development.
