Nottinghamshire Minerals Local Plan Publication Version

Please see attached supporting statement.
We are pleased to note that policy MP12 provides a simple policy that makes a positive statement in support of onshore oil and gas.
We have concerns with one element of the draft policy. There is inconsistency between the terms used in ‘part 1 b’ for exploration and appraisal and ‘part 2 b’ for commercial production. In ‘part 1 b’ the term ‘unacceptable environmental impact’ is used, but in ‘part 2 b’ the term ‘least sensitive location’ is used.
We wish to object to this element of the policy, which we believe needs to change. In our view the terms used should be the same. Regardless of whether it is exploration or commercial production the tests should be equally relevant. Reference to unacceptable environmental impact should be changed to “significant unacceptable environmental impact” because as currently worded all impact can be read as unacceptable. Furthermore the term ‘least sensitive location’ is subjective and therefore should be replaced with the term ‘Are located where they will not have a significant unacceptable environmental impact’.

Please see attached supporting statement
We have concerns with one element of the draft policy MP12. There is inconsistency between the terms used in ‘part 1 b’ for exploration and appraisal and ‘part 2 b’ for commercial production. In ‘part 1 b’ the term ‘unacceptable environmental impact’ is used, but in ‘part 2 b’ the term ‘least sensitive location’ is used.
We wish to object to this element of the policy, which we believe needs to change. In our view the terms used should be the same. Regardless of whether it is exploration or commercial production the tests should be equally relevant. Reference to unacceptable environmental impact should be changed to “significant unacceptable environmental impact” because as currently worded all impact can be read as unacceptable. Furthermore the term ‘least sensitive location’ is subjective and therefore should be replaced with the term ‘Are located where they will not have a significant unacceptable environmental impact’.
As noted above we are largely supportive of policy MP12. However, if it were to be suggested that policy MP12 should be significantly amended INEOS would wish to put forward revised text to the anticipated Minerals Plan Examination as set out in our earlier representations to the draft Minerals Plan

The issue raised is complex and we have found it helpful when responding to other plans for the matter to be debated. This was done most recently at East Riding of Yorkshire in January 2019 where the Inspector was able to hear the points raised on each side of the argument and to understand that there was in fact little between the parties in terms of principle. In our submission this may not have been fully apparent in reviewing written submissions and this was confirmed by the conduct of the Hearing where the Inspector thanked the parties for their frankness, helpfulness and courtesy. We anticipate that policy MP12 may be subject to scrutiny and we believe that it would be helpful for all parties to be able to come together to discuss the issues.