Development Management,
Derbyshire County Council,
County Hall,
Matlock,
Derbyshire,
DE4 3AG.
18 July,
2017.
Planning
Application Reference : CM4/0517/10
(As submitted by Ineos
Upstream Ltd, for planning permission to drill a vertical hydrocarbon
exploratory core well on land adjacent to Bramleymoor Lane, near
Marsh Lane, Eckington.)
I object to the above
planning application for the reasons which will appear below. But
because of the wider implications of this planning application, I
start in (a) with a suggestion as to how your Council should approach
its investigations into the full implications of Ineos's lengthy
submission.
(a) Under “Petroleum
Exploration Development Licences”, Ineos Upstream Ltd have the
right to seek to apply for a series of similar applications to the
above across wide areas of Derbyshire. The examination by the County
Council of this initial application is ,therefore, of great
significance as it could set a pattern for future applications,
including conclusions that might come to be drawn upon later. So the
closest possible form of scrutiny needs to be applied to this initial
planning application. This would be assisted by a full site visit by
those County Councillors who serve on your Planning Committee. It
would be especially helpful to include the local Eckington County
Councillor in both the preparations for such an inspection and in the
site visit itself, to draw from local knowledge. Further relevant
information could come from experts outside of the County Council,
including relevant academics (e.g. at Sheffield University such as Dr
Domenico Bau) and officials and representatives from both North East
Derbyshire District Council and the Eckington Parish Council. The
local MP has also taken a clear interest in this application.
(b) The closest
examination will, of course, need to be applied to the very site
which Ineos is seeking to use for its operations. A start can be made
by examining the site via the Coal Authorities Interactive Map and
making full use of its “Planning Themes” as shown in the top
right corner of their map. The Coal Authority have, however, pointed
out to me that the matters on their interactive map only refer to
their current knowledge and more problematic information could come
to be unearthed at any time in the future - see
http://mapapps2.bgs.ac.uk/coalauthority/home.html
A further source of
relevant and valuable Coal Authority information for our area can
also be found here -
https://www.gov.uk/government/publications/coalfield-plans-derbyshire-county-coucil-area
In fact INEOS have drawn from this source in producing a map
relating to their proposed Bramleymoor Lane development in their
submission to you. Their proposed site is in a red box which they
have added to the Coal Authority Map. This map is shown later. It shows that there are two old mine entries (or exits) in
the field where they wish to engage in drilling. It is possible that
other such entries and exits exist in that field, but have not yet
been discovered. How safe will deep excavation and the construction
of a substantial rig be in such circumstances ?
It should also be noticed
that the black shaded areas and the black round circles on the Coal
Authority's maps reveal a wide range of other “High Risk
Development Areas” (including many old entrances) in the vicinity
of the site. These include a nearby housing estate at Marsh Lane.
Clearly, your Council should err on the side of being cautious rather
than being sorry.
(c) It should also be
taken into account that the North East Derbyshire District Council
(on three occasions) rejected applications for the use of the Bramleymoor Lane site as
land for the operation of a car boot sale. On their 6 March 2009 response see application number 09/00038/FL. You can pursue this
matter with the District Council. One of their concerns was the
problem about likely heavy traffic in a rural area, this is related
to my next point.
(d) The amount, size,
nature and regularity of heavy traffic proposed by Ineos into and
out of the Bramleymoor Lane site is extremely worrying. The proposed
extensive use of the already busy narrow traffic routes of Dyche
Lane and Eckington Lane is a matter of serious concern, especially
given materials being driven to the site and then taken away –
especially by major HGVs . This matter should be given the
considerable attention , especially during the site visit which I
propose in (a) above.
(e) Ineos seek to give
the impression that the work they are seeking to undertake will
occur in a rather isolated rural area. But this is not the case. In
the close proximity to the proposed site, there is the community of
Marsh Lane – and a school. This is a village of almost 1,000
people many of whom live on a housing estate in close proximity to
the proposed site – starting out only some 330 yards away
according to the map from Ineos which appears on your own page 40 of
their submission here -
http://www.ineos.com/globalassets/ineos-group/businesses/ineos-shale/our-operations/bramleymoor-lane/pedl-doc/pedl-300-1-doc-7-environmental-report.pdf This results in problems of noise, pollutants and nearby heavy
traffic for long periods over several years. There will also be
unsightly, round the clock intrusion of a rig operating over much of
this time, which will often provide serious light pollution -
including throughout the night. The rig from proposals submitted by
Ineos could stand at 86% the height
of the dominant Crooked Spire at Chesterfield. It is not something
which can be hidden from view from such a short distance.
THIS IS THE MAP REFERRED TO IN (b) ABOVE
THIS IS THE MAP REFERRED TO IN (b) ABOVE
(f) Under the planning
procedures which are in place, the current application for an
exploratory well are dealt with theoretically as if they were
entirely separate from a later application for the hydraulic fracking
of shale gas. Yet everyone knows that this is not the case. Ineos
would not be seeking the authority to operate an exploratory well
near Marsh Lane unless it had very strong reasons to believe that
this will lead on to evidence which would enable them to make an
application in the future for hydraulic fracking operations, either
from the same area or nearby.
The dangers of hydraulic
fracking in the vicinity in the future are massive. The main sources
for the extraction of shale gas will be former areas where coal
extractions have taken place or coal seams remain. In the immediate
Eckington, Marsh Lane and Coal Aston areas, these are mainly beneath
built upon urban areas and not mainly in the green belt.
The Coal Authority sources
which I refer to in point (b) above reveal that surrounding built up
areas near the proposed site are pock marked with former mine entry
points. Such areas are likely to be the leading sources for access to
shale gas. On page 6 of the INEOS publication entitled "INEOS :
the energy behind UK manufacturing" it claims that its
horizontal fracking activities can run up to 2,000 metres (which is
around a mile and a quarter). From the proposed site this would reach
Eckington, Apperknowle, West Handley and Middle Handley. Then there
is also a possibility that horizontal underground fracking could
reach much further than INEOS indicate. A firm called Halliburton in
the USA having engaged in such operations for three and a half miles.
See -
It needs to be appreciated
that the Coal Authority have been obliged to conduct treatment works
in the area for mine stabilisation purposes. There was a case at the
back of a property on Eckington Road itself in July 2011. See their
contract reference CA18/2295.
Local people are naturally
concerned about the impact which moves to fracking in their vicinity
would have on (a) the safety of their property, (b) its commercial
value and (c) the costs and availability of appropriate house
insurance.
There is a rich literature
on relevant past coal mining operations in Derbyshire, especially the
993 page “The Derbyshire Miners” by J.E. Williams (George Allen
and Unwin,1962) which can fruitfully be consulted so that fracking
dangers are not missed. Also see http://www.oldminer.co.uk/
(g) There is a further
source which may be as significant as that provided by the Coal
Authority. It is the British Geological Survey. The British Geological
Survey (BGS) runs this web-site - http://www.bgs.ac.uk/
I have been able to
establish a much better relationship with the Coal Authority than
with this body. But hopefully you are in receipt of other relevant
submissions about their work in your area. You can also turn to them
yourselves on the following matters.
The Marsh Lane area (and
much of Derbyshire) sits on an active geological fault line running
from south Humberside to the Cannock area of the West Midlands. There
was an earthquake centred on Market Raisen on 27 February 2008, which
had a wide ranging damaging impact in Derbyshire. The following
survey shows that 7,872 reports of damage were received from
Telegraph readers as a consequence. However, many people were unaware
that the survey was even taking place. 150 reports were received from
Derby, 83 from Chesterfield and 303 from nearby Sheffield. Several
other areas in Derbyshire are also listed, including four from
Dronfield where I live. I know of others locally which were not
recorded. See - http://www.telegraph.co.uk/news/uknews/1580010/UK-earthquake-town-by-town-statistics.html
The question arises as to
how far underground excavation leading to eventual underground
fracking will replicate such problems given the nature of local
geological fault lines. Earth tremors having halted drilling near
Blackpool in the past.
(h) Other safety related
concerns include – (i) Groundwater quality – contamination via
the use of chemicals and the mobilisation of naturally occurring
radioactive materials, (ii) waste from the contamination of drilling
and fracturing activities; such as drill cuttings, waste drilling mud
from the use of oil and water, (iii) loss of local habitats through
noise and vibration, air and water, as well as the truck movements
mentioned earlier, (iv) possible methane and nitrogen oxides released
into the atmosphere during the recovery of shale gas itself and (v)
the impact on the supply of water on local supplies if catchments are
over-abstracted.
(i) Vertical drilling is also an unproven technology
which could involve or disturb naturally occurring gas deposits
including benzene which is cancer causing when drilling fluids are
used. The operator Ineos are in an impossible position to tackle
these and other potential problems having no experience of operating
an onshore drilling site. See -
https://www.gov.uk/government/publications/shale-gas-extraction-review-of-the-potential-public-health-impacts-of-exposures-to-chemical-and-radioactive-pollutants
Yours sincerely,
Harry Barnes.
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