From attending the Prosperous Staffordshire Select Committee on Friday a current consultation was highlighted around the mineral plan for Staffordshire 2015 – 2030 . This is an extensive document many months in the production and this is the final consulation and is accessible here.
Consultation ends 31st July 2015 – get involved, comment and
I am making my own representations but on a very limited basis. Chapter 4 (page 17) discusses the County approach to Hydrocarbons and incorporated in to this is the issue of Fracking. The papers are available here. This is supported policy statement number 5 (page 48) related to the Planning for Hydrocarbon Extraction.
Have a read and see what you think are the statements regarding Fracking strong enough. In light of the planning decisions made in Lancashire and subsequent legal challenges should we not have a stronger position to prevent this unproven and environmentally dangerous technology.
Extracted from the plan…
Where do hydrocarbons occur in Staffordshire?
4.1 Historically, energy was derived from the Staffordshire coalfields but recent interest in energy minerals relates to developing hydrocarbon resources and in particular, gas. There are three potential sources of gas in Staffordshire.
4.2 Conventional gas: This is a term that relates to gas trapped in geological structures and reservoir rocks. Currently, a site at Three Nooks Farm, Horton near Biddulph has been appraised and permission granted to produce electricity from the gas17.
4.3 Coal Mine Methane (CMM) or Abandoned Mine Methane (AMM) refers to draining methane gas from active or disused underground coal mine workings. In Staffordshire, a site near Barlaston in Stafford Borough is being used to generate electricity from methane derived from abandoned mine workings associated with the former Florence Colliery (in Stoke-on-Trent).
4.4 Coal Bed Methane (CBM) is contained within unworked coal seams and its extraction is feasible at depths of 200 – 1500m. There has been recent interest in CBM at sites across Staffordshire but mainly in relation to the resource associated with the North Staffordshire coalfield. Several permissions granted for exploration and appraisal, however, have not been implemented but there is a valid permission for further exploration on at Keele University.
The Minerals Plan acknowledges that at the time of publication
“There are no current proposals to use hydraulic fracturing techniques in Staffordshire but this technique would be used to improve gas recovery from the exploitation of coal bed methane.”
“When are Staffordshire’s hydrocarbons likely to be developed?
4.10 National guidance indicates the need for further exploratory drilling to establish whether unconventional hydrocarbons (e.g. CBM and shale gas) are a viable national energy resource. Over the Plan period there is anticipated to be further drilling activity to confirm the extent and viability of the gas resource in Staffordshire but it is not possible at this stage to identify potential production sites. For the early stages of developing unconventional hydrocarbons, it is important that the Plan is able to define criteria for the appropriate location of sites used for exploration, appraisal and eventually production taking into account that planning applications for exploratory development should be considered on their own merits. Furthermore, it is important to recognise that planning control is one of several regulatory regimes associated with the development of hydrocarbons and national guidance sets out how these regimes should work together.”
This is the Policy Statement
Policy 5: Planning for Hydrocarbon Extraction
Exploration and appraisal
5.1 Proposals for the exploration and appraisal of hydrocarbons will only be supported where it has been demonstrated that they accord with the plan policies, including Policy 4.
5.2 Where proposals for exploration and appraisal are permitted, there will be no presumption that long term production from those wells will be permitted.
5.3 Proposals for the production of hydrocarbons will only be supported
where it has been demonstrated that the further works and the surface facilities required to manage the output from the well(s), including facilities for the utilisation of energy, where relevant, accord with the plan policies, including Policy 4.
5.4 Having assessed the impacts of the proposals for the exploration, appraisal and production of hydrocarbons, permission will only be granted where it has been demonstrated that there are no unacceptable adverse impacts on human health, general amenity and the natural and historic environment, except where the material planning benefits of the proposals outweigh the material planning objections.
With the limited nature of information in the County I would call for NO exploration and we should positively encourage this to be kept in the ground. Shale Gas, alongwith other non-conventional gas, could be found or predicted during the time of policy over the next fifteen years and without a strong statement of policy which will prevent untold damage to our Countryside we run risk of corporate exploitation of resources and remaining as a carbon-reliant economy beholden to gas and oil barons and the destruction of our planet through uncontrolled, but preventable, climate change.
This policy should be read in conjunction with the Tory government’s U-turn in environmental protection for sites across the County.
My response in relation to hydrocarbon extraction is copied here for information only
Why I believe the policy is not sound….
The strength of evidence that hydraulic fracturing (fracking) is harmful to the environment is building as improved knowledge of this technology is developed. The time period for this plan would show demonstrable weakness over time and should be strengthened with a clear statement of policy.
What modification do I propose should be made…
I believe a clear statement of intent should be included along the lines of the following.
“Staffordshire County Council adopts a risk averse approach to potential hydrocarbon extraction. The position of Staffordshire County Council is that no development of shale, or other forms of unconventional gas/hydrocarbons, should be explored, developed or exploited within the County whilst there remains strong evidence of the adverse environmental impact of hydraulic fracturing (“Fracking”). Until such time as evidence to the contrary Staffordshire County Council will promote a moratorium on any form of unconventional gas extraction and object in the strongest terms to the appropriate planning authority should permission be sort for permission to develop unconventional gas extraction.
Further Staffordshire County Council supports the evidence based approach to mineral extraction and as such will ascribe to the weight of international opinion in this matter supported by independent research. Until such time as majority worldwide opinion demonstrates that this technology is unequivocally safe and will have zero environmental impact on the Staffordshire Countryside no fracking will be supported anywhere in the County”
Why I would like the opportunity to make direct representations
As stated above due to the lack of evidence to support fracking as a safe technology for extraction of gas the County should take a risk averse stance towards proposed developments in the future. I would welcome the opportunity to present evidence of the harmful effects of fracking as observed in other parts of the world as well as the all-party parliamentary committee which supports a moratorium on fracking for the foreseeable future