“The boreholes will be drilled and installed in four locations. At each location up to three groundwater monitoring boreholes will be installed – a single deep borehole to target the bedrock Nottingham Castle Sandstone Formation and up to two shallow borehole to target a superficial sand and gravel horizon or isolated shallow bedrock sandstone/weathered sandstone horizon. The shallow boreholes will only be installed if an additional distinct water body is encountered which is isolated by marl or clay.”
REASONS WHY WE ARE CONCERNED
IGas are submitted this application as they are about to apply for planning permission for exploratory drilling, flow testing and then they are hoping to frack the wells. Soon though, boreholes applications like these could not need planning permission, due to new legislation, which will need to be challenged.
Given that these boreholes will only be necessary if IGas are given permission to carry out exploratory drilling and then fracking, it is our view that any decision to approve this application would amount to pre-determination of any subsequent planning applications.
It’s worth noting that in Lancashire, the monitoring borehole applications for Little Plumpton and Roseacre were considered at the same time as the main fracking applications, not in advance. You can find more on this on Drill or Drop. We therefore feel that this application for monitoring boreholes should be deferred, so that it can be considered at the same time as the exploratory drilling application, not in advance.
We believe IGas are doing this so that they can speed up the process to carry out the next stage – fracking at the site. I.E. By the time their exploratory drilling has finished, they will already have carried out the relevant monitoring they need to start fracking.
It is clear that the land is contaminated (maybe not uniformly, but certainly there are ‘hot spots’). The land sits above a significant aquifer and there are many surface water features around the site – the potential for contamination is, in our opinion, higher than the impression being given in the reports.
Therefore there is a risk that contamination will leak into groundwater, either through the borehole or around the side of the borehole. Their analysis shows groundwater close to the surface as well as aquifers further down. Some of the drains in this area drain west to east, i.e. from any contamination around the monitoring boreholes towards Misson Carr SSSI. Therefore it should be concluded that this area is not suitable for drilling boreholes into groundwater as there is a risk of introducing contamination into controlled waters and into an SSSI. (And it should be noted that the EU Water Framework Directive 2000/60/EC is based on the precautionary principle. And Policy M3.8 of the Notts Minerals Local Plan says permission will only be granted where there are no risks of polluting ground or surface waters (unless engineering measures and/or operational management systems can adequately mitigate such risks).
Also, because the site is already contaminated, it makes the establishing of a baseline for groundwater quality at this site effectively meaningless, as the water tested could already have been subject to some contamination in the past due to the previous activities on-site.
Future waste disposal
Perhaps IGas have other plans for the boreholes. The recently passed Infrastructure Act will enable IGas or any other company to store waste, including nuclear waste, in boreholes.
On noise, they say the daytime background noise level is 47-50dB(A) (LAeq,12h). The highest noise level at the nearest noise sensitive premises, at 155m, would be 64dB(A), below the 70dB(A) limit applied to temporary operations at minerals sites. However, they say they haven’t considered Misson Springs Cottage which is closer because that is ‘within the control of the applicant’. Our understanding is that this isn’t an acceptable reason for excluding this cottage – so the noise level at this cottage should at least be considered.
Misson Training Area Site of Special Scientific Interest (SSSI) is located approximately 125m to the east of the site boundary, which raises concerns about how close this operation is taking place to it.
Risk to human health
The Environmental Site Assessment states that: “Phosphorus concentrations were reported to exceed the Stage 2 GAC for Human Health, assuming a commercial/industrial land use, in all samples analysed. However, the reported concentrations are considered to be naturally-occurring and are therefore not considered to present a risk to future site users.” – Just because something is ‘naturally-occurring’ doesn’t mean that it can’t cause any harm.
State conditions that should be met if the application is approved
Even though we do not want this application to be approved, it could be likely. So we would request that:
- this application is put before the planning committee,
- monitoring and testing is carried out by a separate impartial body,
- monitoring and testing is carried every 3 months out for a minimum 12 months period before any exploratory drilling,
- all results are made public as soon as each test is completed via local councils, EA, water company etc. and placed on public record
- testing is carried out for all the chemicals that will be used in exploratory drilling/fracking AND all substances that may be released from shale rock AND all new chemical compounds that may be created when these chemicals and substances combine under heat and pressure
- testing is carried out a minimum of every there months
CALL THE PLANNING COMMITTEE
Planners have recommended approval of this application and we urge that it is rejected. Please call the planning committee councillors and demand that they reject it based on the reasons above.