Index : INEOS Pre-Fracking Application

In the eight preceding blog entries below, I have summarized INEOS's application for pre-fracking rights at a site off Bramleymoor Lane near Marsh Lane. Although sometimes this is all little more than a list of contents, which people may then use to focus on items contained in the full 731 page submission. But there are some passing comments and explanations.

If people trawl backwards into these blog items they will move via parts 8,7,6,5.4,3,2 back to the start. Therefore, below I provide links to click so these items can more easily be examined in a logical order.

Part 1 which sets the scene for what follows, can be found via this link.

Part 2  gives (a) INEOS's three page covering letter, then (b) a summary of  a 38 page submission entitled "Application Form, Certificates and Checklist". Click here.

Part 3 gives a summary of a 38 page submission "Our Proposal Explained". The Link.

Part 4 gives a summary of a 42 page submission "The Proposals". Next.

Part 5 gives a summary of a 24 page submission "Application Drawings". Here.

Part 6 gives a summary of a 54 page submission "Planning Statement". It is here.

Part 7 gives a (impossible) summary of a 445 page submission "Environmental Report". The 445.

Part 8 gives a summary of a 56 page submission "Statement of Community Involvement". Last Time.


  

    

Part 8 : INEOS Pre-Fracking Application

This is the final summary (part 8) of INEOS"s application submitted to the Derbyshire County Council to start its operations on land adjacent to Bramleymoor Lane near Marsh Lane in North Derbyshire. It is entitled "Statement of Community Involvement" and covers 56 pages - see here. However, anyone visiting the community would be hard pressed to find anyone who agreed with the thrust of INEOS's case. I refer to the pages as they are numbered in the top left hand corner of the County Council's coverage.

Page 4.  1. Introduction.

Page 5.   2. National and Local Policy Guidance.
               2. 1. National Planning Policy Framework.
               2. 2. Planning Practice Guidance.
Page 6.   2. 3. MPA's Statement of Community Involvement (MPA = the Derbyshire County Council's Mineral Planning Authority).

Page 7.   3. Pre Application Stakeholder Consultation.
               3.1. Presentation to MPA Officers and Members.
               3.2. Meeting with MPA Officers. (So can we have similar meetings please ?)

Page 9.  4. Public Consultation.
              4. 1. "Town Hall" meetings. (These were INEOS meetings for Parish Councillors and the like. I arranged to attend two of these. See here for a report of the first of these, which was held at Staveley. I attended a similar event at Shirebrook).
              4.2.   Consultation website.
              4.3.   Public Exhibitions. (These were at Green Lawns and the Marsh Lane Community Centre. I attended the latter). This section also includes - "Natascha Engel MP met the company as part of her research into issues around shale gas extraction. INEOS hosted a visit by Ms Engel to their four well gas production facility near Warrington, Cheshire as part of her fact finding series of visits to well sites and protest camps in Yorkshire, Lancashire and Cheshire" .
           
Page 11.  5.  Exhibition Feedback
                5. 1. (Part of the feedback is drawn from those who bothered to complete forms at the close of these "public consultations". Yet most of the disgruntled just ignored them as being rubbish.)
                5.2. Exhibition - (Charts)

Page 18.  6.  Responding to the Feedback.

Page 24.   7. Conclusions.

Page 25. Appendix 1. Exhibition Invites (e.g. "Dear Resident"letter and advert).

Page 29.  Appendix 2. Newspaper Advert.

Page 31.  Appendix 3. Feedback Forms (page 35 gives a "current form").

Page 36.  Appendix  4. Exhibition 1 Banners. (Page 37 shows a huge map of the area surrounding the proposed INEOS site, covering an area of 4,000 metres x 3,000 metres).

Page 52.  Appendix 5. Exhibition 2 Banners. (gives a huge picture of a rig - but it is not lit up for nighttime). 

Page 53 - photo of the mound.

Page 54. - a large well-site diagram

Page 56-  an ariel photo of the wider area.






 
                

Part 7 : INEOS Pre-Fracking Application

The seventh item submitted by INEOS to the Derbyshire County Council covers no less than 445 pages on the Councils site. See here. 

I use the County Council's page numbers this time. The best I can do on all this is to provide little more than a list of its contents (with the odd comment).  But a quick glance at what follows may lead to you finding an item that you have a key interest in and can then confront.

It is headed "Environmental Report" (The fact that they cover so much shows they have a lot to answer for. The index material from pages 3 to 15 below is followed with detailed items on these from page 16 onwards, so the immediate items are the menu which you can draw from later.) 

Page 3 - Executive Summary. 
              Stage 1. Site Development and Establishment (approx. 3 months)
              Stage 2. Drilling and Coring (approx 3 months)
              Stage 3. Maintenance of Suspended Well Site (up to 5 years)
              Stage 3a. Possible Work of the Suspended Well (up to a month)
              Stage 4. Use of Well as a Listening Well (approx 3 weeks)
              Stage 5. Decommissioning and Restoration (approx 2 months)

From page 3 are blocks on noise, traffic and transport, ecology, landscape/visual, surface water and flooding, hydrology, archeology and cultural heritage, emission of air, climate change, human health. (We are supposed to believe that all of these are unproblematic.)    

From page 9 we get what are problem areas they feel a need to overcome.

1. INTRODUCTION
1.1 The Proposal.
1.2 The Purpose of the Document.

2. NOISE
2.1 Introduction.
2.2 Scope and Methodology.
2.3 Baseline Conditions.
2.4 Noise Modelling Results.
2.5 Environment Assessment.
2.6 Conclusions.
2.7 References.

3. TRAFFIC AND TRANSPORT.
3.1 Introduction.
3.2 Scope and Methodology.
3.3 Baseline Conditions.
3.4 Environmental Assessment.
3.5 Conclusions.
3.6 References.

4. ECOLOGY.
4.1 Introduction.
4.2 Scope and Methodology.
4.3 Baseline Conditions.
4.4 Ecological Assessment and Conclusions.

5. LANDSCAPE AND VISUAL.
5.1 Introduction.
5.2 Scope and Methodology.
5.3 Baseline Conditions.
5.4 Representative Viewpoints (are these anywhere near your own ?)
5.5 Environmental Assessment
5.6 Embedded Mitigation.

6. SURFACE WATER AND FLOODING.
6.1 Introduction.
6.2 Scope and Methodology.
6.3 Baseline Conditions.
6.4 Embedded Mitigation.
6.5 Environmental Assessment.
6.6 Flood Risk.
6.7 Conclusions.
6.8 References.

7. HYDRO GEOLOGY.
7.1 Introduction.
7.2 Scope and Methodology.
7.3 Baseline Conditions.
7.4 Embedded Mitigation.
7.5 Environment Assessment.
7.6 Conclusions.
7.7 References.

8. ARCHEOLOGY AND CULTURAL HERITAGE.
8.1 Introduction.
8.2 Scope and Methodology.
8.3 Baseline Conditions.
8.4 Heritage Assessment.
8.5 Conclusions.
8.6 References.

9. OTHER ISSUES.
9.1 Introduction.
9.2 Air Quality.
9.3 Contaminated Land.
9.4 Human Health.
9.5 Climate Change.

APPENDICES.

2.1 Noise.
3.1 Traffic - Count Data.
3.2 Traffic - Network Assessment
3.3 Draft Traffic Management Plan (to overcome problems, it seems !)
5.1 Landscape and Visual - Zone of Theoretical Visibility.
8.1 Gazetteer of Designated Heritage Assetts.
8.3 Geophysical Survey Report.

Pages 12 to 14 give a list of some 61 tables.
Pages 15 gives a list of 20 figures.

Page 16 has an introduction to the above menu.
Page 17 "The Purpose of this Document" (This then moves into the index of items given above. From Page 18 also adding maps and tables.)

Page 23 - Map of Area.
Page 30 - Map of Noise Levels (worth a look).
Page 37 - Map of Traffic Areas (have a look up the nature of Dyche's Lane at Coal Aston.)
Page 40 - Map of the Area.
Page 55 - Map - Mammal Tracks and Badger Footprints.
Page 62 - Figure - Sensitivity and Magnitude.
Page 75, 79 and 83 photos of the area (these give a false impression of the site being in an isolated rural area - not as being close to Marsh Lane, Eckington and Coal Aston)
Page 90 - Map of area with tributaries.
Page 108 - Map of hydraulic circle.
Page 109 - Map of the same area as above (with some strange coloured sections)
Page 124 - Heritage Assetts (close to the site).
Page 125 - Photo of above.
Page 129 - Photo of the Cultural Heritage Gazette.
Page 129 - Enclosure Map of Eckington, 1795.
Page 130 - Staveley Enclosure Map, 1795.
Page 130 - Staveley Tithe Map, 1795.
Page 130 - First Edition Ordinance Survey Map, 1840.
Page 131 - Ordinance Survey Map, 1892-1905.
Page 131 -        -ditto -, 1898.
Page 132 -        -ditto  -, 1916 and1964-1978.
(All the above seven pages of maps need to be supplemented by information from Coal Authority Maps which show key additional information on matters such as "Development Risk Areas" and numerous (close to the surface) historical mine entrances, mine exits and adits (i.e. diggings into hillsides or avenues for taking water from mines). There are even two mine entrances on the intended INEOS site positioned on top of what are seen as being seen as being Development High Risk Areas. The British Geological Survey also need to be pressed to come up with more information on underground fractures in the area, which could cause problems - especially when INEOS moves onto its fracking stage.) 
Page 143 - Monitoring Location Photo (two photos near houses).
Page 144 - As above, near M3.
Page 145 - Chart of Noise Levels.
Page 146,147, 148 - Statistical noise level charts.
Page 149 - Map showing predicted noises levels in the effected area - with many charts.

We are then into information over-kill with masses of charts. But these and the above have many details which can be drawn from and turned against INEOS's application. e.g Page 372 gives a map with "narrow road, Riding School, on street parking, mini-roundabout, playground, school and tram lines".

Page 380 - a map of the route of their transport.
Page 390 - Landscape and Visual.
Page 391 - Map of Large Areas.
Page 393 - Heritage Assetts.
Page 399 - Land at Bramleymoor Lane - ground penetrating radar survey.
Page 417 - Discussion on Bell Pits in the area.
Page 418 - States "further archaeological investigation could be required by the Local Planning Authority" - so we need to press for this.
Page 430 - Map of the Site (a) wide area (b) close area.
Page 431 on - a series of what seem to be underground photos, which seem to be by Wessex Archeology.


 

Part 6 : INEOS Pre-Fracking Application

Part 6 of the INEOS application is entitled "Planning Statement", but it has different sections.  I concentrate on the inital section which covers some 54 pages. 

In earlier parts I have used the numbering system for pages as shown on the Derbyshire County Council's web-site. But it is easier this time for me to use the INEOS numbering system. So for the initial list of contents, five page numbers need to be added to convert the INEOS page references to the numbering system used on the County Council's web-site. This County Council's "Planning Statement" section can be found by searching near the bottom of the page when you - click here.

This (with additions from myself) is INEOS's first list of "Contents"

1.    Introduction............................... page 1.
1.1  INEOS Company Structure...............  1. (with a map of INEOS East Midlands' License Areas.)
1.2  Regulators Responsibility..................  2. (this appears, but INEOS fail to list on their index)
1.3  Application Context........................... 3.

2. Why is INEOS exploring Shale Gas......5.

3.    Site Selection......................................7.
3.1. Analysis of existing geophysical data within our PEDL area...........................................7.
(The above includes two charts. Figure 3.1 "Extract of Local Geology". Figure 3.2 "Example Interpretation of 2D data". Figure 3.1 shows our area as being close to the Edale Gulf. There is a reference to the Edale Gulf in a book published by the British Geological Survey (BGS) which deals with the geology of the East Midlands. See page 124 here. As the reference is incomplete, I will seek to arrange for this matter to be pursued with the BGS. Does the Edale Gulf provide us with extra problems?)
3.2   Desk top analysis of environmental constraints......8.

3.3   Site specific requirements......................................10.
3.4   Site availability......................................................10.

4.      Site Description...............................11.
4.1    Site Location...................................11.
    (Figure 4.1- an ariel image of the site and surrounding area, with the proposed site outlined in red)
    (Figure 4.2 - site location : more or less the above in the form of a map.)    
4.2     Environmental Designations...........12.
     (Figure 4.3 Designation in the vicinity of the application site).
     (Figure 4.4 Extract from the British Geological Survey (BGS) data on boreholes. This is badly  printed. I will approach BGS for a proper copy)

5.      The Application.....................................................................15.
5.1    Overview of the Hydrocarbon Extraction Process ...............15.
5.2    Overview of the Planning Application..................................15,
5.3    Regulatory Framework..........................................................16.
         (Page 18  provides a list of 23 items attempting to show that INEOS have people such as the above BGS and the Coal Authority on their side. This approach has to be challenged and the material held by such bodies drawn from to challenge the INEOS application)  
5.4   Future Application Proposals.................................................19.

6.    Summary of the Environmental Report. (This section contains no maps, no figures nor the like drawn from official or other sources. Although it provides references to seek to back up its submissions. The fact that they seek to overcome potential criticisms in these areas reveals that they are on their own shaky ground.  
6.1   Noise...............................................20.
6.2   Traffic and Transport......................20.
6.3   Ecology...........................................22.
6.4   Landscape and Visual.....................22.
6.5   Surface Water and Flooding...........23.
6.6   Hydrology.......................................24.
6.7.  Archeology & Cultural Heritage....26.
6.8.  Other Issues....................................26.
6.8.1   Air Quality...................................26.
6.8.2   Contamination.............................26.
6.8.3   Human Wealth ............................26.
6.8.3   Climate Change...........................26.
(Each of the above categories are areas in which the County Council need to have links and the recourse to fully test out - and cap - such claims)

7.   Policy Analysis.................................27. (This has 20 sub-sections. But it carries no figures nor maps to back up its claims, except the following map taken from the Coal Authority which can actually be turned against INEOS's case. My version below only covers part of the orginal. The INEOS version appears at page 40 below)

 


The areas of black crosses (including those in small back circles) show areas defined by the Coal Authority as being "Development High Risk Areas". The red rectangle has been added by INEOS to show its intended Bramleymoor Lane site. Yet it contains two of these "at risk areas" itself and is surrounded by many more.

This is the full list for this counter-productive section.
7.     Policy Analysis............................................................................27.
7.1   The Development Plan................................................................28 (the source of the above map).
7.2  The Principle of Hydrocarbon Extraction in the Countryside.....28.
        (Yet the Bramleymoor site is not pure "countryside". It is surrounding by urban territory.
          Which its development will hit - and later intends to undermine).
7.3   Building a strong, competitive economy, and; supporting a prosperous rural economy.
        (INEOS being the main beneficiaries and other benefits being outweighed by the widespread
         social costs).................................................................................29.
7.4.  Promoting sustainable transport (sounds familiar !)....................30.
7.5.  Protecting the Green Belt land (by ruining it !)...........................32.
7.6.  Meeting the challenge of flooding and coastal change (!!)..........33.
7.7.  Conserving and enhancing the natural environment
        (by first messing it up)..................................................................34.
7.7.1 Landscape (retrospective?)..........................................................34.
7.7.2 Geological conservation (via intrusion?).....................................36.
7.7.3 Soils..............................................................................................36.
7.7.4 Biodiversity...................................................................................37.
7.7.5 Pollution, Land Instability, Contamination, Pollution Control and
         Remediation, including the water environment.
        (Sounds like an admission of guilt)...............................................38.
        The map shown above is taken from page 40.
7.7.6 Noise..............................................................................................41.
7.7.7 Air Quality.....................................................................................42.
7.7.8 Lighting..........................................................................................43.
         (Yet in reality, all the above three are real problems).
7.8.   Conserving and enhancing the historical environment .................44.
7.9. Facilitating the sustainable use of minerals.....................................45.
7.10 Cumulative Impact..........................................................................46.
7.11 Hydrocarbon Specific Issues...........................................................46.
7.12 Policy Conclusions..........................................................................48.
(Section 7 makes it sound like everything will be for the best in the best of all possible worlds)

8.  Other Material Considerations...........................................................49.
8.1 The Regulatory Regimes...................................................................49.
8.2  Public Health and Public Concerns..................................................49.
8.3  Climate Change................................................................................50.
8.4  Restoration and After Care...............................................................51.
8.5  Hydraulic Fracturing.........................................................................52.
       (This section reads -  "INEOS confirms that the planning application does not propose any hydraulic fracturing or fracking. Hydraulic fracturing forms no part of this application and therefore this proposal should be assessed on its own merits". So why are they spending so much time, effort and resources on this application? It is clear where they wish this application to lead them to. The ends can not be seperated from the means.)
8.6  Monitoring..........................................................................................52.
8.7. Environmental Safety..........................................................................52.
8.8 Health and Safety.................................................................................52.
8.9 Economic Benefits and Disbenefits.......................................................53.
8.10  Conclusions.......................................................................................53.

9. Conclusion..............................................................................................54.
(Below I quote the final words of the conclusion, which need to be challenged -  We need to challenge their first point, press to change Government Policy on their second point and raise the key alternatives they miss with their third point"

"The analysis in this report has demonstrated that -
- The development accords with the relevant policies of Development Plan
- The development accords with the principles of National Policy and Guidance, being a material consideration to be afforded significant weight; and
- There are no other material considerations which indicate that the development should not be approved."

The rest of this submission is presented in the form of Appendices and are supportive of the above claims. So these can also be tackled -

Appendix 1. "Screening Request" is 19 pages long.
Appendix 2 "Screening Opinion" is 17 pages.
Appendix 3. "Outline of Abandonment (Decommissioning) and Restoration Operations. 3 pages.
Appendix 4. "Model Planning Conditions" 3 pages.
Appendix 5. Designations Maps. 3 pages.

Part 5 : INEOS Pre-Fracking Application

Part 5 of the INEOS application provides a set of 22 "Application Drawings" over its 24 pages as shown on the Derbyshire County Council site. Click here.

By their nature these drawings can not be summarized. But in examining them, comparisons can fruitfully be made by using the Coal Authorities Interactive Map and homing in onto the position of the Bramleymoor Lane site. When you do this, click into the categories in the box in the top right hand corner, especially those showing "Development High Risk Area" and "Mine Entry". You will discover that there are two from each category (on top of each other) on the site INEOS are seeking to use. How safe is that ? Click here.

Also see the map at the close of Part 1 of my summaries. This is taken by INEOS from a different Coal Authority source, to which they have added a red box to pinpoint the site in question. The two small black circles on their map being the problematic "high risk areas" referred to above. Click here. 

People can also check out how far they themselves live from a "Development High Risk Area" and a "Mine Entry"  - or from the other categories provided by the Coal Authority.

The order in which these drawings are listed on page 2 of this submission are - 

List   List of Application Plans

 A Strategic Location Plan

Application Site Plan

 Existing Ground Plan

Proposed Site Entrance & Highway works

Proposed Site Layout Plan - Construction

Proposed Site Layout Plan - Drilling Stage

Proposed Site Layout Plan - Listening Stage

 Proposed Site Restoration

Proposed Lighting Plan - Drilling & Coring

 Proposed Drainage Plan

Proposed Site Layout Plan - Suspension

Proposed Internal Access Plan

Proposed Sections & Details

Proposed Site Layout Plan - Possible workover

Parameter Sections - Develop. & Establish

Parameter Sections - Drilling & Coring

Parameter Sections - Suspension

Parameter Sections - Work over of Well

Parameter Sections - Listening Stage

Parameter Sections – Abandonment

     Fence Details

     Lighting Examples

Part 4 : INEOS Pre-Fracking Application

The purpose of this series is to summarize the application by INEOS to the Derbyshire County Council for planning permission to start its search for shale gas from a site off Bramleymoor Lane near Marsh Lane, Eckington. This is to enable people who are opposed to such a major development towards fracking in the area, to develop their own counter-arguments when making their own submissions to the County Council.

The whole of the INEOS submission is 731 pages long. My own summaries are highly selective and far from perfect. But hopefully they may be  of some assistance to those seeking to tackle INEOS's analysis and arguments.


This is summary (D) of the pattern I provided earlier. It is entitled "The Proposals" and is 42 pages long.To find the full version click here.   I use the numbering system from the County Council's web-site.

Pages 3 to 6. Introduction.

Page 3 "On completion, the well would be temporarily suspended with the potential to use a "listening well" to monitor subsurface impacts arising from other operations in the region should such operations receive the relevant planning consents and environmental permits. This proposal is not to ... test or produce gas by hydraulic fracturing - a separate application would be required... "(they could then) "support a separate planning application for further work". Which "may include future wells on the same pad".

On page 4 appears INEOS's own summary of its proposals. It can be accessed via the link I provide above.

On page 5 is "Box 1 : Health and Safety" which mainly relates to the position of their workers. So it is worthwhile to check our INEOS's record in this area, to see if they have failed to live up to their claims.

On page 6  is "Box 2 : Aims of Core Well", i.e. geographical and safety, health and environmental issues.

From page 7 to 25 is a "Summary of the Proposals".  There is the question of how far this is just a standard submission of theirs.

From page 10 is Table 1 on "Environmental Protection Measures" covering in turn - water and soil, air, noise, traffic, ecology, visual impact, flood, cultural heritage and archeology,waste and monitoring - these are all areas open to challenge.

Page 14 deals with "Drilling, Coring and Suspension". In blue below is the summary provided by INEOS -
   

Stage 2: Key Points

DURATION – APPROXIMATELY 3 MONTHS

Rig Assembly – 2 weeks

Drilling and Coring – 10 weeks

Suspension and Demobilisation – 2 weeks 

HOURS OF WORKING 

    Assembly, drilling, coring and suspension – Monday-Sunday – 24 hours per day; 12 hour shifts

Site deliveries

Monday – Friday 0700-1900 – Saturday – 0700-1300 - Sunday or Bank/ Public holiday – no working

unless in an emergency or as agreed with the MPA

STAFF NUMBERS

Staff on site at one time during Stage 2 – up to approximately 25 (plus approx. 3 security)

Approximate total staff – 45

As the drilling operations would take place over 24 hours, the site would be continually manned.

SAFETY

Standard well safety equipment would be present on the site during drilling, including a blow-out

preventer, vent for emergency venting of gas encountered and methane (and radon) monitoring as outlined in the Borehole Regulations.

Safety measures for any construction site would also be followed, including an emergency plan,maintenance of fire extinguishers, and routine monitoring of plant to ensure safe operation.

Pollution prevention measures would be used including bunding, spill kits and training of staff.

Page 15 gives the "Rig Parameters". The rigs maximum height will,be 60 metres (i.e 86% the height of the Crooked Spire at Chesterfield .HB).

Page 16 on "Well Design and Geological Understanding of the Site". THERE IS AN IMPORTANT DIAGRAM ON THIS PAGE WHICH SHOWS THAT AT THE BRAMLEYMOOR LANE SITE THERE ARE 'WESTPHALIAN COAL MEASURES' ESPECIALLY AT 1,000 FEET BELOW GROUND. THEN AT 3,000 FEET AND BELOW THERE IS NAMURIAN BOWLAND SHALE. THE SHALE IS LIKELY TO BE RELATED TO WHAT INEOS ARE AFTER. BUT THIS COULD DISTURB THE COAL MEASURES NEAR THE SURFACE - ESPECIALLY IF LATER FRACKING RIGHTS WERE OBTAINED IN THE AREA. WHAT THEN OF SUBSIDENCE PROBLEMS?     

Pages 17 shows boxes on "Drilling Fluids" and "Coring and Logging". Includes a section on "Environmental Protection Measures".

Pages 18 to 21 give tables with over 50 points on "Environmental Considerations and and Protection Measures". Page 20 (as Stage 3) being on the Maintenance of the Suspended Well Site. Page 21 giving "Features of Vertical Core Well" showing a photo of a large pool of water and a chart of the proposed well suspension.

Pages 21 to 22 give Environmental Considerations and Protection Measures, the Possible Workover of a Suspended Well and Use of the Well as a Listening Well.

Page 23 features a stage of the vertical corewell site (Although a photo is should show is missing at this stage)

Page 24 on "Abandonment (Decommissioning) and Restoration" leads to page 25 on aftercare, including a table with 8 points on "Environmental Protection Measures".

Pages 26 to 36 has 49 sections and contains 32 photos.

Page 33 has a table on "Summary of Traffic Movements via Vehicle Type".

Page 34 has a table on "The Breakdown of Total Traffic".

Page 35 has a table on the "Maximum Daily Traffic Movements" which it claims will average 240 per day drawn from (1) Site Construction - 266 movements (2) Drilling and Coring Suspension - 200 (3) Routine Maintenance (annual) - 96 (3a) Well Intervention/ Workover - if required 184 (4) Listening Well Operations - 174 (5) Decommissioning and Restoration - 281.

Page 36  is on Regulation and Internal Management, including working with the Coal Authority on its interaction with coal seams (There could be hope here that the depth of information the Coal Authority hold on (a) mine entrances, exits and other entry points called "adits"  (b) on development high risk areas - two of them on the site INEOS wish to use, and (c) on a whole range of other information which can be discovered via this following link, can be used to destroy INEOS's case. -click here)


Page 36 Gives five sets of figures - (1) Site Development and Establishment, (2) Drilling and Coring, (3) Maintenance of Suspended Well Site Listening Well, (4) Use of Well as a Listening Well (5) Abandonment (Decommissioning) and Restoration.

Page 38, 39 and 40 contain six sideways photos - with boxes of information placed on them.

INEOS case can be overturned by the Derbyshire County Council, District Councils and individuals checking out their case and adding counter-information from the sources it often uses itself. 

  

 

Part 3 : INEOS Pre-Fracking Application

This series of items attempts to summarize INEOS's planning application to the Derbyshire County Council for explorations on land adjacent to Bramleymoor Lane near Marsh Lane. This is done to show key items we need to overcome, especially when preparing our own counter submissions. Any responses showing any key material which I have missed out are most welcome.

This summary is item (C) from the pattern I provided earlier and is nine pages long being described by INEOS as "Our Proposals Explained" - it is actually something of a propaganda sheet. I use the County Council's numbering system from its relevant site. Which can be accessed via this link.

Below I centre mainly on the headings of each section, but then reproduce their concluding comments in full as they seem to me to cover the main element in this submission. 

Page 3 : "Who Are INEOS Upsteam ?"  It employs 4,000 people on seven sites (There is an accompanying map which shows six sites in England, plus those in Scotland where fracking is now blocked by the Scottish Government. However, some of its sites may not be the type of fracking areas which are being prepared for in our region - such as those which are next to the sea).

Page 4 : "What Is Shale Gas ?"

Page 5 : "Why Is It Important ?"

Page 6 : "What Does The Planning Application Propose ?"  Includes what it uses as "evidence" from other bodies such as the British Geological Survey. The latter is a body which I feel should be doing a better job in revealing dangerous underground fracture lines in our area.

Page 7 : "What Happens Next ?"

Page 8 : Finally they give the following "Concluding Comments"  - reproduced below.

CONCLUDING COMMENTS

In conclusion:

• The proposal is critical to exploring the potential of shale gas in this area

• Without exploration, the UK will not be able to establish the potential of this resource

• The application concerns only this core well stage, with any future stage subject to separate planning applications to be judged on their own merits at that time

• The technology and method to be applied is tried and tested and developed to meet specific site requirements taking in to account the local characteristics

• The proposed development is designed and will be managed to either avoid, minimise or mitigate potential effects

• The proposal is wholly consistent with the Government’s support for shale gas as a prospective resource capable of enhancing energy security, economic performance, and UK’s path to a low-carbon future

• INEOS Upstream takes its responsibilities seriously and will continue to engage with all local stakeholders through this planning application process and subsequently.

H.B. As residents are the biggest stakeholders of all, we need to unite against these proposals via as effective means as possible.

Part 2 : INEOS Pre-Fracking Application

(A) The first document submitted by INEOS to the Derbyshire County Council is only three pages long. It seeks the following overall permission -

‘Construction of a well site and creation of a new access track, mobilisation of drilling, ancillary

equipment and contractor welfare facilities to drill a vertical hydrocarbon exploratory core well and mobilisation of workover rig, listening well operations, and retention of the site and well head assembly gear for a temporary period of 5 years on land adjacent to Bramleymoor Lane, near Marsh Lane.’ 

My note : this is "only" (elsewhere) for up to five years. So the sooner they advance this work, the quicker they will hope to engage in full scale underground fracking.

It then lists eight sets of enclosed material, which I will later go on to summerise (and comment upon) in the order in which they are presented by INEOS. This first document ends with an Annex which lists the headings of 24 documents which I will draw from in the following seven items, doing this in the order in which they are presented.

(B) The next document is 38 pages long and is entitled "Application Form, Certificates and Checklist".  The page numbers I use are those provided on the County Council's site for this particular item.

Page 3 on the Type of Application - "full planning permission for oil and gas working including exploratory, appraisal and production phrases"

Page 4 on Type of Development - "explority phase"

Page 5 on Hours of Operation -
                  Use                    Monday to  Saturday             Sunday and Bank Holidays                                  Construction         07.00 to 19.00                               n.a.
               Drilling                 00.00 to 23.59                       00.00 to 23.59
               Suspension/          07.00 to 19.00                               n.a.
               Restoration


Page 6 shows the need for new or altered vehicle access to or from a pubic highway and the same for pedestrian access. The full-time employment equivalent to be approx 15 people, not including the local supply chain. With trees and hedges being on the site or on adjacent land, there may need to be a full tree survey at the discretion of the local planning authority.

Page 7 shows that the designated area is in a greenbelt. On floodrisk - surface water will go via a soakway with interceptor ditch and sump. There will be foul sewage "stored in proprietary tanks with on-site-toilet facilities and collected from site by licensed water carriers for disposal"

Page 8 on disposal of trade effluent and waste - "All solid and waste will be stored on site in segregated facilities". Storage will be in self bunded sealed containers. There is a blue line on a map showing which lane is open to the applicant, subject to the formal approval of the landowner.

Page 10 gives notices to the landowner and the County Council on 8  May 2017. Then where notices were placed on 27 April 2017 and in the Derbyshire Times on 8 May 2017.

Page 11.  Item 24 claims that the planning requirements have been met.

Pages 12 to 18 - "Planning Portal" - this is mainly used to claim that the required items have been covered in the application.

Page 21 gives the Site Notice.

Pages 22 to 31 gives evidence of the above notice being displayed on the site, showing 18 photos as proof.

Pages 32-34 gives the notice placed in the Derbyshire Times.

Pages 35-38 gives the notice given to the landowners.

An earlier notice.

 



  

   

Part 1 : INEOS Pre-Fracking Application To Derbyshire County Council

INEOS have a planning application in front of the Derbyshire County Council, initially for a  hydrocarbon exploratory core well on land adjacent to Bramleymoor Lane near Marsh Lane in North Derbyshire. By itself such exploratory work could lead to serious local problems. The proposed initial rig intended for operating horizontal explorations for shale gas, could be up to 86% the height of Chesterfield's Crooked Spire - dominating surrounding areas and lit up. Then there would be large numbers of huge tankers going in and out of the proposed INEOS site along Eckington Road and onto the restricted facilities of Dyche Lane at Coal Aston.  A clear source of danger and disruption.

Yet the current application by INEOS is just the tip of the iceberg. They would not be spending massive amounts of time, resources and specialisms on this initial application if they did not already hold strong evidence indicating that their efforts will lead them on to seek to obtain further planning permissions for highly problematic underground horizontal fracking operations. In one of their publications they state that when it comes to such horizontal operations these could operate for 2,000 metres (i.e. around a mile and a quarter). We need to remember that whenever they start their horizontal underground work, it will fan out in numbers of differing directions. Furthermore in the USA (where INEOS have close connections with their fracking businesses) a distance of three miles has been reached horizontally underground by one operator. 

The application which INEOS have submitted to the Derbyshire County Council can be found by clicking here. 

Unfortunately, there are a couple of defects on the County's site. When I attempt to click into the first item they show, it does not work for me. There are then a further eight items to link into. But the County Council have placed these in a jumbled-up order - differing from the order shown on the eight available documents from INEOS.

In following blog items, I will deal with these items in the order given to them by INEOS.

These are (1) - "Application Document, Covering Letter".  This is three pages long. (But has to be checked in case it was really longer). 

(2) "Application Form Checklist" - 38 pages.

(3) "Our Proposals Explained" - 9 pages (and something of a propaganda sheet).

(4) "The Proposal" - 42 pages.

(5) "Application Drawings" - 24 pages covering 22 items.

(6) "Planning Statement" - 114 pages.

(7) "Environmental Report" - 445 pages (I kid you not).

(8) Statement of Community Involvement (trying to show how much we all love INEOS !)

The question arises of how fully our County Councillors will be aware of the wide ranging nature of INEOS's submissions. I can't really see them studying all of INEOS's total of 731 pages and then having them checked out by looking at alternative sources. Yet sometimes INEOS's evidence can actually be used against them - as with the map at the end of this first item.

                    -------------------------------------------------------------------------------

As a starter (before turning to the above battling order), I give below the central section of a map displayed by INEOS on page 45 of item (6) as listed above. That is the County Council's page number. The INEOS document numbers it page 40. . My thanks go to "Sarah KayBee" on the "Eckington Against Fracking" Facebook Site for providing a connection to the map when my technology failed me.

23rd May 2017 - NOTE and ALTERATION: What appears below is a correction to what initially appeared here. I am grateful to the Coal Authority (whom I have been in contact with) for telling me of my error.  I mistakenly claimed that the Coal Authority Interative Map was the source of the map below. But as invaluable as the Interative Map is, the map below was actually taken by INEOS from another of the Coal Authority's key sources - this source is now linked to in the text of the revised paragraphs below. It covers - "Development Risk Plans, Specific Risk Plans and Surface Coal Resource Plans for Coalfield Local Planning Authorities"

The map is taken from the following Coal Authority Source, where you can search for your own immediate locality to see if falls under the above heading - see here.

Below Ineos have added a red rectangle to a map selected from the above Coal Authority's material which shows their proposed area of operation off Bramleymoor Lane and they have acknowledged the Coal Authority as being the source, via -
https://www.gov.uk/government/publications/coalfield

Via black crosses (and small black circles) this Coal Authority's Map shows potential "at risk" areas which have measures such as past or remaining coal stocks where great care should be taken over any future underground developments.

This folowing map (from the above link) only shows certain areas of North East Derbyshire. The uncovered surrounding white sections are not clear of such problems. They just happen to fall in different areas and are on different maps. 
 

An Open Letter To Alex Dale

 
First three from right to left - Alex Dale, Lee Rowley (Conservative Candidate in the General Election for NE Derbyshire), Sir Patrick McLoughlin (Chair of the Conservative Party and Conservative MP for West Derbyshire/Derbyshire Dales from 1986 to 2017 and currently the area's candidate ).


Dear Alex Dale,
                          You have recently been elected to the Derbyshire County Council as a Conservative Candidate to serve Dronfield East, which is the Ward in which I live. As I am approaching the 60th anniversary of my first joining the Labour Party, you will appreciate that I did not vote for you.

You will be aware, however, that I am a strong opponent of current moves towards fracking in North Derbyshire and its surrounding areas. By tomorrow for instance, the fracking firm INEOS could be applying to the newly Conservative controlled Derbyshire County Council for permission to engage in vertical explorations to search for access to shale gas in a field near Bramleymoor Lane close to Marsh Lane. We are both aware of serious traffic and other problems which such a move could cause and the impact upon your ward of Dronfield East, which could also later be seriously worsened if it led on to underground horizontal fracking operations in the area.  

As you opposed such moves to fracking in this area in literature you published for the County Council elections and in your role as a Dronfield Town Councillor, you are now fully committed to opposing the immediate application from INEOS. If not, it would be one of the quickest U-turns ever.

You are, however, being thrown into an immediate situation where you will need to press your position at your new County Council level. If Labour had been re-elected, then I believe that the coming INEOS application for developments would have been rejected and INEOS would then have needed to appeal to Government level in an effort to overcome this blockage. But what will happen now that the Conservative Party is in control of the Derbyshire County Council, for the current Conservative Government has a clear legislative commitment to moves to widespread fracking ?

You may need to start out your County Council career as a Conservative rebel. Indeed if you press your clear commitments you could immediately be expelled from the Conservative Group of Councillors. 

The Conservatives at County level now have 37 seats, Labour 24 and the Liberals 3. Even if Labour and the Liberals unite in opposition to the move by INEOS at Bramleymoor Lane, at least six Conservative Councillors will need to join them. Is this likely to happen ?

Have you immediately been working within the Conservative Group on the Council for it to reject the application? If not will you rebel over the Conservative line and attempt to take others with you ? And is there a danger that you will yourself be technically debarred from voting, for being held to have prejudged the INEOS planning application without having yet seen it in full detail ? 

Then will you be using your close links with prominent figures in the Conservative Party such as Patrick McLoughlin (who canvassed for you) to get them to change their overall pro-fracking stance at national level.

I am emailing a link to this open letter to you via your Dronfield Town Council email address. I will also be posting it on Dronfield, Eckington and other local anti-fracking facebook sites. You might like to respond publically also.

The regular literature you published against fracking now has to be acted upon. If not, some of us will just not let any lack of action on your part be forgotten.  You have given yourself a big task and will be judged as to how quickly and vigorously you pursue it.


Yours faithfully,
Harry Barnes.  

Under Fracking Could This Happen Near You ?

 


Do you live, work, shop, travel, play or socialize near any former or remaining coal seams ? To check this out, I provide appropriate links near the end of this item. Although these can only deal with what has so far been discovered.

When you follow them, you might be in for a shock, because coal extraction in this country has been taking place for hundreds of years.  Long before many of our current facilities were ever built.

If you find anything, then it is likely that a firm will currently hold legal rights from the Government (subject to planning consents) to engage in fracking operations beneath such places. The owners of properties themselves having had their previous rights to prevent such actions removed from them in England under Government legislation.

It is exactly such areas which are likely to be attractive to those seeking to obtain shale gas. These areas can easily be accessed via underground horizontal fracking activities, which can be set up from neighbouring vertical operations which can initially be established in nearby rural areas. The horizontal extractions can fan out from such initial vertical activities and reach out to under major urban territory.

From experiences in the USA, the vertical starting point for such operations can lead to horizontal  underground extractions travelling distances of up to three miles. So few people in such danger areas will be immune from possible fracking problems.   

To check your own position, turn to this Interactive Coal Authority Map - click here.

If, like me, you have limited computer skills you might need to turn for help to your children or grandchildren.  But it is well worth the effort - either for your peace of mind or to recruit you to the nearest anti-fracking group. Unfortunately, the Coal Authority readily admit that they have not yet found every possible place - it is involved in a huge project of historical research. 

From a further avenue you can separately examine wide ranging areas which the Coal Authority judge to be "Development High Risk Areas" - click here.How close are these to you and yours ?

Then if you feel a need to check with the Coal Authority to see if your own property is fully effected, also click here.

I apologize if what I say repeats various earlier material placed on this blog. But I feel that it is of deep and immediate importance - especially in my own area of North Derbyshire.

If people have a blog facility, they can let me know generally what they find that is of relevance to them - via my "comment box" below. l will also add links to this item via local anti-fracking sites, then those on facebook can respond via these. Anyone who comes across me can also let me know what they find. Any information given to me privately, will not be circulated without the person's express consent.  For, I appreciate that anyone living near former mining areas could have the value of their property hit if fracking ever takes place near them. Publicity about their problem might then seem to be rather counter-productive. 

(For the source of the above photo see here.)