[vc_row][vc_column][vc_column_text]Please refer to our guidelines before making your objection so that you include details that are relevant and will be considered by the council.
You may wish to consider some of the points listed below. We do not believe this is a comprehensive list so please expand as you wish. Please don’t be put off by this list – just pick and choose the ones you think are the most appropriate, the key thing is to object, don’t leave it to others, they might be leaving it to you!
The deadline for objections to be received is 31st July.[/vc_column_text][/vc_column][/vc_row][vc_row][vc_column width=”1/1″][vc_separator color=”grey”][/vc_column][/vc_row][vc_row][vc_column width=”1/1″][vc_column_text]
[/vc_column_text][/vc_column][/vc_row][vc_row][vc_column width=”1/1″][vc_accordion active_tab=”false” collapsible=”yes”][vc_accordion_tab title=”Landscape, Visual and Environmental”][vc_column_text]
Landscape, Visual and Environmental
- At between 18m and 27m high the drilling rig will be prominent, unsightly and will have a significant visual impact.
- The area was heavily mined in the past and the coal fields were closed in part due to the subsidence risk. There are disused mine workings in the field very close to the site and many others around Dudleston, within 500m from the site. If test drilling were to lead to CBM extraction then this may cause a subsidence issue as well as releasing methane into the atmosphere and causing an environmental hazard.
- At the Dart open meeting their geologist stated that they should not drill within 1 km of mine workings and admitted that he had no knowledge of the mines in the area. There are disused mine workings in the field very close to the site and many others around Dudleston, within 500m from the site. It is very concerning that Dart appear to have no knowledge of such and important detail. The council should ensure that Dart are proven to have gained knowledge of the local mine workings and can prove that they are working within safe limits of these workings.
- According to a document written by DECC (Fig 29 in the document THE UNCONVENTIONAL HYDROCARBON RESOURCES OF BRITAIN’S ONSHORE BASINS – COALBED METHANE (CBM)), the area of the proposed site is outside the governments own recommended areas for drilling for coal bed methane, therefore why drill in this area when other areas would be more beneficial.
- Operating a 27m high drill rig in close proximity to overhead National Grid electricity wires would run the risk of creating a dangerous induced current, depending on the atmospheric conditions.
- To support their application Dart has stated that the application complies with polices CS6 and CS17 in the Core Strategy document, both of these policies are concerned with protecting and enhancing the natural and local character of the environment. In addition policy CS5 states all development “Protects and enhances the diversity, high quality and local character of Shropshire’s natural, built and historic environment, and does not adversely affect the visual, ecological, geological, heritage or recreational values and functions of these assets, their immediate surroundings or their connecting corridors”. Drilling a hole with a 27m high drill rig, leaving behind a permanent concrete substructure encased in steel is not temporary nor does it enhance, protect or conserve the local environment. This is further exacerbated because concrete will decay slowly over time. This would have a serious impact on local health if leakage of the methane then gets into the ground water that it is trying to protect. Therefore it does not comply and approving this application will be in contradiction with these policies.
- An important consideration in planning is the ‘precautionary principle.’ This requires that where there is significant risk of damage to the environment, pollution controls will take into account the need to prevent or limit harm, even where scientific knowledge is not conclusive.
- The drilling rig will be in use 24 hours a day, 7 days a week and will be extremely noisy as a result of a mixture of drilling, industrial diesel generators, flaring, jet pump and vehicle. The nearest residential properties are under 400 metres away and prevailing winds will also have an impact.
- The development site is proposed to have bunds placed at the north side of the compound, which is further surrounded by mature woodland. The South, East and West of the compound will not have these bunds and have no noise protection. Many houses, up to and above 1km away, have a direct line of sight of the site and will have no protection from the noise.
- The noise report, that has been included as part of the supporting document from the applicant is not independent, i.e. it is produced by the same company employed to submit the application, this is wholly unacceptable as any assumptions and measurements can easily be slanted in favour of the applicant. It is also noted that the values are only predictions. No effort has been made to actually assess the area to ascertain the true readings. These predictions do not take into account existing background noise, therefore the properties that are conveniently just below the WHO acceptable level may be over it when normal background noise is taken into account. It is imperative that a baseline noise measurement is taken from all areas surrounded the site and not just those that may be protected by both the bund and the wood and these measurements are checked throughout the drilling operation.
- Heavy goods vehicle traffic and the 24×7 operation of the drill engine, 2 generators, 2 mud pumps and the wheeled loader (as detailed in the Noise report) will cause many emissions which will impact on local air quality.
- The prevailing wind will take airborne pollutants away from the site towards areas of housing.
- An air quality baseline test should be done prior to any work commencing and then monitored to ensure that levels are kept to an acceptable standard.
- The site will be lit at night and this could be a nuisance to those living near the site, especially the many properties that are in direct line of sight and therefore are not shielded by woodland and farm buildings, and a distraction to drivers on both the road at the site entrance but also on the B5068, where the site will also be visible.
- There are 3 springs on the field including one under the drilling site, which run down and water the cattle and then run into Bryndaniel Brook and then ultimately reaches the river Dee. Run off from the site poses a real threat to the water course.
- Any water borne pollution could be dispersed from the site via the existing waterways and aquifers. This is a concern as the area of the proposed site is in a protected water catchment area from Water Act 1991. This legislation requires permits to conduct any operation that could impact the drinking water supplies of Chester and Wrexham. Permits are needed for the storage of fuel and chemicals on the surface as well as drilling operations. There is no mention of the required permit being obtained.
- There is a very real risk of groundwater contamination. According to a report written by the Environment Agency (Baseline Report Series:20. The Permo-Triassic Sandstone Aquifer of Shropshire) the area around the proposed site is on a major aquifer. The drilling will be going through these aquifiers and therefore they are at a high risk of contamination. The risk of contamination is highest with production wells however it has been proven that test extraction drilling operations can, and have, caused pollution. If this is contaminated, it could lead to contamination of the nearby River Dee. The Dee Valley has a restriction on all chemicals. As the proposed site is within this area the proposed drilling should not commence.
- The above points means that the development is not compliant with Core Strategy Policy CS18 and ‘Saved’ Policy M4.
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Archaeology and Cultural Heritage
- Paragraph 4.81 in policy CS6 of the Shropshire Core Strategy 2011 states that: “The quality and local distinctiveness of Shropshire’s townscapes and landscapes are important assets… Regard should be paid to urban characterisation and historic environment assessments” there are several buildings of historic significance within 700m of the site, Meil House and Pentre Morgan barns (Grade II*), and Plas Yolyn (Grade II) therefore a drilling rig situated in such close proximity is not paying regard to the historic environment. In addition, due to the proximity of these listed building the application is not compliant with Core Strategy Policy CS17 and ’Saved’ Minerals Plan Policy M6 with regard to Archaeology and Cultural Heritage.
- Dart have quoted that in the first 3 weeks of setup and the last 3 weeks of site abandonment there will be 160 truck loads. Does this include both the entry and the exit vehicle movement? Assuming the worst case scenario this would mean 360 truck vehicle movements in a 5 day daytime-only working week for this type of work, therefore resulting in 24 movements per day. These will not only affect the local residents and impact on the farm traffic but will also be large lorries going through St Martin’s and will impact both the village and may have important implications on the two small bridges used to get to and from St Martin’s.
- There are lots of wildlife inhabiting in and around the area of the site of the proposed well pad, including are a number of ponds that are habitats for the Great Crested Newt, which is protected under European Law, and common toads. They inhabit areas in and around the pond therefore the access road being just 10m away and the development site being a mere 100m away, plus 24×7 drilling and the additional 6 weeks of heavy traffic will severely impact their habitat and therefore contravenes Core Strategy policy CS17.
- This area of north Shropshire is recognized for its role in the conservation of wildlife. While this tends to focus on the meres, the surrounding countryside makes an important contribution to the process. A wide range of species, including wildfowl and other birds, overfly the area and use it for roosting, nesting and foraging. Little consideration seems to have been given to the impact of the drilling noise and drill site preparation on these activities. The impact on nocturnal species, such as owls and bats, will be exacerbated by the addition of the night time lighting. Many mammals and amphibians, including water voles, populate the watercourses and ponds surrounding the site. The proposed development could have a significant impact on the local ecological systems supporting this wildlife, through the run-off from the hard-standings and vehicles and from leakage of lubricants and waste water, especially during the construction phase.
- The supporting documents do not contain the full ecology report that has been undertaken. This should be undertaken to provide a baseline of the wildlife and habitat in the area and numbers before any work commences.
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- The site is located on greenfield land which is currently used grazing of dairy Jersey cattle, which is a premium category of milk. Policy CS6 of the Shropshire Core Strategy 2011 states that sustainable design and development principles “Makes the most effective use of land and safeguards natural resources including high quality agricultural land, geology, minerals, air, soil and water “, this work is not intended for agricultural purposes and but instead is the preliminary work required for industrialisation and therefore should be considered as such. This application is not compliant with policy CS5, CS6 or the Joint Minerals Plan ‘Saved’ Policy M4.
- The fields around the site support an dairy farm. The disturbance of the drilling poses a very real threat to the well-being of the animals. In Australia well pads cannot be sunk within a 2 kilometre range of dairy or livestock for this reason.
- Activities are proposed outside the areas zoned for industry. The Test drill is regarded as being within the remit of agricultural use, however future potential extraction activities are not.
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Health & Safety
- There is no mention in the planning application of a local emergency and evacuation plan. All hydrocarbon drilling presents the hazard of hydrogen sulphide gas, which can disable at a concentration of only 10 parts per million. The public safety hazard is particularly acute if the accident happens at night when people are sleeping and evacuation is difficult – in Canada there is a hydrogen sulphide hazard zone radius of 3.5 miles. As local residents, we need to know what will happen if there is an emergency.
- Coal Bed Methane wells could leak. These wells can never be removed, and the steel and concrete structures plunged deep into the earth will decay slowly over time. All gas wells will leak eventually. This would have a serious impact on local health.
- No reassurance has been given as to which party will accept ultimate responsibility or that adequate liability insurance cover has been provided for.
- According to the Shropshire Core Strategy 2011 “Tourism is an important part of the local economy, with approaching 11 million people visiting each year. Overall, tourism directly supports over 8,000 full time equivalent and more than 6% of all Shropshire-based jobs are tourism related”, plus of paragraph 4.81 in policy CS6 of the Shropshire Core Strategy 2011 states that: “The quality and local distinctiveness of Shropshire’s townscapes and landscapes are important assets. They have a direct impact on quality of life and are an important influence on the local economy in terms of attracting investment and boosting Shropshire’s image as a tourist destination. The Council will ensure new development complements and relates to its surroundings, not only in terms of how it looks, but the way it functions, to maintain and enhance the quality of Shropshire’s environment as an attractive, safe, accessible and sustainable place in which to live and work. Regard should be paid to urban characterisation and historic environment assessments” this application will have a huge negative visual impact and is the forerunner to industiralisation of the countryside. Approving this planning application will impact tourism and as a result the local economy.
- This application is stated as providing zero jobs for the area. UK Methane estimate if this led to full scale production that each well would provide 10-15 jobs, however they are likely to be temporary jobs and very few would go to local people This compared with the loss of many permanent local jobs caused by local employers moving their operations due to the risks and industrialisation caused by CBM.
- The fact that converting North Shropshire into a gas extraction field will wipe a significant amount off the value of all properties is not considered to be a “material planning consideration” however it could readily be argued that by making the area into a poorer one, the local economy will suffer from there being less disposable income around.
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Preliminary to full-scale Coal Bed Methane production
- There are three important risk factors with Coal Bed Methane operations. Any one of them can be worked around with care however the combination of all three is a very significant risk to the local population. 1) Sloping coal beds mean increased subsidence risks. The industry ideal is for horizontal or near horizontal strata 2) Former mine workings need to be given a wide berth because they create unintended interconnections 3) Areas with extensive fracturing of the ground need to be avoided because the fractures create seepage paths to the surface and facilitate subsidence.
- There is a disused mine shaft in the field very close to the site and many others around Dudleston, within 500m from the site. Coal Bed Methane can only safely be done in virgin coal bed layers therefore the existence of mines close by must pose a health and safety risk.
- The area was heavily mined in the past and the coal fields were closed, in part, due to the subsidence risk. There are disused mine workings in the field very close to the site and many others around Dudleston, within 500m from the site. This may cause a subsidence issue, which could release methane into the atmosphere and cause an environmental hazard.
- Speaking to an independent geologist and local miners and research, the coal face in this area is on a 3 in 1 incline, this will make it very difficult to drill horizontally as required for CBM and will make the process uneconomic, therefore if the end result is not possible why start the initial process.
- An independent geologist has also advised that the structure of the coal bed layer across north Shropshire is severely fractured and would pose a great risk of methane migration if CBM is done in the area.
- There is a very real risk of groundwater contamination. According to a report written by the Environment Agency (Baseline Report Series:20. The Permo-Triassic Sandstone Aquifer of Shropshire) the area around the proposed site is on a major aquifer, which is at a high risk of contamination. “The overlying soils have little ability to attenuate pollutants and the fractured nature of the geological strata can provide pollutants with fast pathways into the deeper saturated zone which can make the aquifer highly susceptible to contamination. “. Coal Bed Methane has been linked to water contamination in Australia and the US where the technology is widely developed. CBM almost always involves pumping huge quantities of water out of the coal seam – this is water that has been marinading in coal for thousands of years, and can contain a wide variety of toxic contaminants. There is groundwater in the silt, sand and gravel above the coal seams. If this is contaminated, it could lead to contamination of the nearby River Dee. The Dee Valley has a restriction on all chemicals. As the proposed site is within this area the proposed drilling should not commence.
- If the intention of the test site is to become a full scale production site, then all of the risks and implications of full scale production must be taken into account to determine whether it is worth doing the test drill in the first place. Section 144 of the National Planning Policy Framework states “ensure, in granting planning permission for mineral development, that there are no unacceptable adverse impacts on the natural and historic environment, human health or aviation safety, and take into account the cumulative effect of multiple impacts from individual sites and/or from a number of sites in a locality”. CBM does have many unacceptable adverse impacts on the natural and historic environment, human health and therefore contravened the National Planning Policy Framework. Particularly important in this context is the question of what to do with the millions of gallons of heavily polluted water that is pumped out to initiate the gas flow. The industry norm is to partially clean the waste and then discharge it locally. Given that all runoff from North Shropshire is used as drinking water, that will not be permissible which then means that the only option would be a huge fleet of tankers taking the pollution significant distances to a coastal location. As well as being environmentally unacceptable, this is like to be uneconomic.
- Very large numbers of wells need to be drilled to extract Coal Bed Methane, because each well does not yield much gas. In Queensland, Australia, over 3,000 wells have been drilled with projections of 40,000 to come. If CBM goes into full production here, there could be over 2000 wells across North Shropshire to make the whole process economically viable. This is unacceptable.
- In Australia and the US where Coal Bed Methane is produced commercially, hydraulic fracturing is commonly used to extract the gas. Often fracking is necessary if a well is to produce enough gas for the project to be economically viable. Even if Dart say that they do not intend to use hydraulic fracturing, they could later sell their PEDL licenses in this area to another company, who might use fracking. If this planning application is approved, and large amounts of methane are discovered as a result of coal seam testing, it will be much easier for them to sell their licenses.
- This industrialisation could change the towns and villages in this part of Shropshire for the worse, forever.
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- Coal Bed Methane extraction could lead to runaway climate change. It is very carbon intensive, and has the additional problem that the methane extracted is a stronger greenhouse gas than the carbon dioxide emitted by burning it. Strategic Objective 9 in the Shropshire Core Strategy 2011 document states that Shropshire wish to “Promote a low carbon Shropshire, delivering development which mitigates, and adapts to, the effects of climate change, including flood risk, by promoting more responsible transport and travel choices, more efficient use of energy and resources, the generation of energy from renewable sources, and effective and sustainable waste management.”. Approving this planning application would be in contradiction of this.
- As an EIA was not deemed to be required, there has been no baseline measurement for noise level, air quality and wildlife in the area from which to check and subsequent measurements. The planning department should insist that these baseline measurements are made, at varying times of day at various locations before any work commences.
- The council should make checks to ensure that the agreed drilling depth is adhered to.
[/vc_column_text][/vc_accordion_tab][/vc_accordion][/vc_column][/vc_row][vc_row][vc_column width=”1/1″][vc_separator color=”grey”][/vc_column][/vc_row][vc_row][vc_column width=”1/1″][vc_column_text]Planning objection guidelines >>
How to make a postal objection >>[/vc_column_text][/vc_column][/vc_row]