Nottinghamshire Minerals Local Plan Publication Version

Object

Representation ID: 278

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? No

Sound? No

Duty to co-operate? No

Section 2 on Nottinghamshire's mineral resource and industry identifies the range of minerals within the county. The section identifies sand and gravel, gypsum and clay as being all of national importance. Notwithstanding reference is made to shale gas (paragraph 2.26) as a potential resource which is thought to exist in the north and south of the county, it is considered that there should be a greater recognition of such as set out in national guidance and the recent Ministerial Written Statement (WMS) by the Secretary of State for Ministry of Housing, Communities and Local Government 23rd May 2019.

Support

Representation ID: 279

Received: 10/10/2019

Respondent: IGas Energy

IGas supports the strategic policies for the plan; they will establish the vision and objectives for development, including minerals, to 2036. IGas supports the intentions of paragraph 3.6 for minerals developments to minimise the impacts on climate change and transition to a low carbon economy. IGas is of the view that onshore oil and gas development is compatible with this vision, specifically through the development of an adequate supply of domestic minerals under a regulatory environment superior to that of countries from which the UK imports its minerals. It is also important that the plan recognises the need to combat climate change. A domestic oil and gas supply offers significant carbon savings over fuels, which otherwise would be imported from overseas, possibly without regulatory regimes as strong as those in the UK, generating much needed local jobs in fields such as engineering and contributing to the transition towards a low carbon economy.

Object

Representation ID: 280

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

IGas supports the Plan Strategic Objectives. However, SO3: Addressing climate change should recognise the diversity of mineral operations and the fact that mineral extract on occurs and could occur from sites other than quarries and to which the same principles would apply.

Object

Representation ID: 281

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

It is noted that policy SP1 - Sustainable Development, of the draft plan has been removed. In the absence of such a policy there is a risk that the Plan fails to comply with national poli:y that requires "a// plans should be based upon and reflect the presumption in favour of sustainable development, with clear policies that will guide how the presumption should be applied locally".

Object

Representation ID: 282

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Policy SP1 - Minerals Provision
IGas previously commented that this policy, as a strategic policy applying to all minerals, appears to be very aggregate orientated.

Support

Representation ID: 283

Received: 10/10/2019

Respondent: IGas Energy

IGas supports the commitment to reducing the impact from development on climate change and the fact that it is the development that must reduce greenhouse gas emissions and move towards a low carbon economy (SP3(a)). IGas also supports the supporting justification that indigenous energy minerals have potential benefits in environmental and climate change terms. IGas is of the view that onshore oil and gas development is compatible with the policy through the development of an adequate supply of domestic minerals under a regulatory environment superior to that of countries from which the UK imports its minerals. A domestic oil and gas supply offers significant carbon savings over fuels, which otherwise would be imported from overseas, possibly without regulatory regimes as strong as those in the UK, generating much needed local jobs in fields such as engineering and contributing to the transition towards a low carbon economy.

Object

Representation ID: 284

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

IGas supports the policy to maximise the use of sustainable forms of transport of minerals and the inclusion of pipelines as an option as recommended in previous representations . IGas currently utilises pipelines in existing operations and which reduce the potential use of HGVs to transport oil and gas and will continue to do so where local circumstances permrt.

IGas supports the policy to minimise traffic movements in the development of minerals where it is practical to do so. The onshore industry aims to maximise the reuse and recycling of materials and waste products from its operations , wherever it is feasible to do , sJ. However, the policy must align with the principal that minerals, including oil and gas, can only be worked where they are found. IGas remains concerned that the policy requirir g mineral workings and mineral related developments to be located 'within close proximity to the County's main highway network and existing transport routes in order to avoid residen tial areas, minor roads , and minimise the impact of road transportation' remains unchanged and does not recognise this.

Object

Representation ID: 285

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

IGas supports some of the changes made to the policy and justification from the consultation draft. However, IGas remains of the view that the policy continues to be onerous and does not recognise the weighting of all facets of sustainable development that should be applied when considering applications for development. Regarding hydrocarbon development, whilst there may be potential for environmental impact, the economic benefit of mine aI extraction should be afforded 'great weight' (paragraph 205 of the NPPF). This is furtrer ratified by the Joint MWS (17 May 2018) .

The significance of impact depends on the significance of the asset it affects. Paragraph 171 of the NPPF states that Plans should, 'distinguishbetween the hierarchy of international, national and locally designated assets.' Paragraph 184 of the NPPF recognises a similar approach for the historic environment in that assets should be conserved in a manner appropriate to their significance.

Object

Representation ID: 286

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? Yes

Sound? No

Duty to co-operate? No

Significant changes have been made to this policy. IGas supports the principle of the policy which, other than the omission of 'do not conflict,' has been taken from the from paragrapn 146 b) of the NPPF: ' certain other forms of development are also not inappropriate in the Green Belt provided they preserve its openness and do not conflict with the purposes of including land within it..' including minerals.

Object

Representation ID: 287

Received: 10/10/2019

Respondent: IGas Energy

Legally compliant? No

Sound? No

Duty to co-operate? No

IGas notes paragraphs 4.96 - 4.100 remain unchanged (other than the deletion of 'very intensive' from 4.100). !Gas remains of the view that the approach being taken is not positively prepared and does not reflect the advice within NPPF or the Joint WMS of 17 May 2018 and WMS of 23 May 2019.

Whilst the introduction sets out the background and approach for shale gas and acknowledges there is a potentially significant shale gas resource within Nottinghamshire, IGas is concerned that the Plan continues to fail to make refeirence to the potential benefits of a shale gas industry within the UK or the Government support within the Planning Practice Guidance to the NPPF or the WMSs. There is a clear recognition of the contributions the shale gas industry could make towards a diversity of energy supplies at the national level and, for consistency, this should be reflected within the MLP.
The Planning Practice Guidance (PPG), originally published by the Department of Communities and Local Government (DCLG) in March 2014, at Minerals paragraph 91 (reference ID: 27-091-20140306) states that " as an emerging form of energy supply, there is a pressing need to establish - through exploratory drilling - whether or not there are sufficient recoverable quantities of unconventional hydrocarbons such as shale gas
.. ....present to facilitate economically viable full scale production." A Government supported Ernst and Young supply chain report (Getting ready for UK shale gas, April 2014) indicated 'there could be significant benefits for jobs and growth from a successful UK Shale Industry: over 64,000 jobs at peak could be supported across the wider economy, with more than 6,000 jobs on shale pads themselves. Many of these would be highly skilled, high quality jobs, with above average pay.'

A combined shale gas and oil policy statement by DECC and DCLG (15 August 2015) states:

A national need to explore and develop our shale gas and oil in a safe, sustainable and timely way. Exploring and developing our shale gas and oil resources could potentially bring substantial benefits and help meet our objectives for secure energy supplies, economic growth and lower carbon emissions. The Government therefore considers that there is a clear need to seize the opportunity now to explore and test our shale potential.

These comments were reiterated within the JWMS 17 May 2018. There is a clear intention at Government level to seize the opportunity now to explore and test the country's shale potential and this support should be explicit within the Plan.

Whilst the changes to policy MP12: Hydrocarbon Minerals are welcomed, part 1b) still requires exploration and appraisal developments to be located where they will not have an unacceptable environmental impact. Such an approach is not in accordance with the NPPF as there is no weighting provided on the level of environmental asset and whether it is of international, national or local significance.

IGas welcomes the changes to the Justification in paragraph 4.104 which recognises the national need to explore and develop new domestic sources of oil and gas.

IGas notes that paragraph 4.110 continues to state, a PEDL 'allows a company to pursue a range of oil and gas exploration activities ... ' which appears to have been derived from the UKOOG description of PEDLS. The PEDL licences actually place an obligation on the holder to explore and develop for hydrocarbons. In its current form, the paragraph suggests pursuing an interest is an option when in fact it is a requirement as set out in the guidance by the Oil and Gas Authorit y1; this should be amended.