Next week (Thurs 8 May) Nottinghamshire County Council’s Environment & Sustainability Committee will be launching an additional consultation on the Minerals Plan – but only on sand and gravel, with no mention of unconventional hydrocarbons. This means there is still no specific policy on shale gas or coal bed methane. So with help from Nottingham Friends of the Earth, we wrote this letter to them:
Dear Councillor Creamer,
Minerals Plan – failure to take a precautionary approach to unconventional hydrocarbons
We understand that you will be revising the draft Minerals Plan in relation to sand and gravel. (We have no comments on this, while recognising its importance.) The obvious question is why the opportunity is not being taken to also review policy relating to unconventional hydrocarbons. We note in particular that:
(1) DCLG issued revised planning guidance on 6 March 2014, including a section on Minerals (http://planningguidance.planningportal.gov.uk/blog/guidance/minerals/). There appears to be no reference in your revised Plan to this guidance.
(2) North Yorkshire has recently consulted on the possibility of taking a precautionary approach to unconventional hydrocarbons (see extract below). SO WHY IS NOTTINGHAMSHIRE NOT CONSIDERING A PRECAUTIONARY APPROACH?
You will be aware that Total is funding a consortium led by IGas to develop exploitation of shale gas resources in parts of North East Bassetlaw and South Yorkshire (PEDLs 139 & 140). Separately, Dart Energy is exploring the potential for extracting coal bed methane. So the lack of a precautionary framework in Nottinghamshire will be significant in the near future.
Amongst issues relating to unconventional hydrocarbons not adequately recognised in your current draft Minerals Plan are:
- requiring developers to identify underground zones where lateral drilling and hydraulic fracturing may take place (Minerals planning guidance ID: 27-115-20140306);
- the need for Environmental Impact Assessments to cover the full geographical area below ground as well as above ground (ID: 27-122-20140306);
- protecting the integrity of geological and hydrogeological resources, in particular Notts’ sandstone aquifers (which should be shown on a key diagram);
- risks associated with past coalmining activities, including recognition of Notts as the earthquake capital of Britain (http://www.earthquakes.bgs.ac.uk/earthquakes/recent_events/ollerton_earthquakes.html);
- the need for a precautionary approach to climate change (which should include monitoring methane emissions) (ID: 6-001-20140306).
At the moment, Nottinghamshire does not have a policy specifically about unconventional hydrocarbons including shale gas and coal bed methane. Is that because you don’t think Notts needs to be protected from the hazards of fracking and dewatering? Or because it is easier to put your head in the sand and hope it will go away?
Extract from Minerals and Waste Joint Plan: Issues and Options Consultation, February 2014 (North Yorkshire County Council, City of York Council, North York Moors National Park Authority) http://www.northyorks.gov.uk/article/23999/Minerals-and-waste-joint-plan-consultation
id28 Option 1 (pp102-103):
This option would support the principle of development of CBM, UCG and shale gas resources and the underground storage of carbon and gas subject, where relevant, to the other gas policies in the Joint Plan but would also in particular require robust assessment of, and the prevention of potential impacts on, a range of other matters including in relation to the integrity of geological or hydrogeological resources and processes (including groundwater and land stability), availability of water resources and local amenity and public safety issues. Transport of gas or carbon would be expected to be via pipeline, with the routing of pipelines selected to give rise to the least environmental or amenity impact.
This option would involve a precautionary approach, with support to specific proposals only being provided where a high level of assurance in relation to impacts and benefits, including community benefits, can be demonstrated. Particularly high standards of siting, design and mitigation would be required where any development is proposed within or in close proximity to the National Park or AONBs and in locations which may impact on the townscape and setting of the historic City of York.