right folks...if you lot cant do a simple copy & paste in to a website to save your local communitys environment from being destroyed by a scheme of polluting, profit-obsessed, corporations, then shame on you. Below is a step-by-step guide on how-to-do and WHAT TO PUT IN AS YOUR COMMENT: a group of very dedicated people have pulled together (in the last minutes) from both sides of the River Forth to create this VERBATIM response that EVERY ONE of you can submit to Fife Council. Its all legal and NEEDS to be submitted by you. Submissions need to be in before midnight, tomorrow (8th Dec) as it doesnt look like we will be granted an extension. PLEASE take ten minutes out of your schedules to do this. It is really, very important. Comments to be added by each of you, start & end as 7th DECEMBER 2014..........level of public health PLEASE SHARE THIS STATUS SO AS MUCH PEOPLE AS POSSIBLE SUBMIT A COMMENT ~~ please let us know if you have followed this and done so HOW TO OBJECT TO FRACKING POLICY AT FIFE COUNCIL Register or log in to Fife Planning portal at: lpconsult.fife.gov.uk/…/eve…/answer_questionnaire.jsp Navigate to ‘FIFE PLAN – PROPOSED PLAN’ Then click on ‘Comment on a Policy’ Scroll down to ‘Policy 15: Minerals’ Then click on ‘add comment’ 7 DECEMBER 2014 TOWN AND COUNTRY PLANNING (DEVELOPMENT PLANNING) (SCOTLAND) REGULATIONS 2008 EXAMINATION OF PROPOSED FIFE LOCAL DEVELOPMENT PLAN (“the LDP”) UNDER S. 19 OF THE TOWN AND COUNTRY PLANNING (SCOTLAND) ACT 1997 REFERENCE: ‘Fife Local Development Plan: Consultation Draft Minerals Supplementary Guidance’ Consultation response to policy FIFE LDP: DRAFT MINERALS SUPPLEMENTARY GUIDANCE SECTION 5.3 1) There is no current Scottish Government energy or economic policy that would explicitly support the favourable position expressed in FIFE LDP: DRAFT MINERALS SUPPLEMENTARY GUIDANCE SECTION 5.3. 2) In Fife there is clear evidence that the community does not support this policy, as can be seen in the opinions of over 2,500 signatories to the online petition entitled “Fife Council: Dont allow the burning of coal under the Firth of Forth” and over 49,000 signatories to the online petition ‘Ban Fracking in the Central Belt of Scotland’. Thus, the wording of policy FIFE LDP: DRAFT MINERALS SUPPLEMENTARY GUIDANCE SECTION 5.3 reflects neither the position of the new national policy framework, nor the will of the local community, nor, it appears, the principle that local planning policy should be neutral and in the wider public interest. Revised wording, therefore, should reflect these and be consistent in tone with a neutral wording. The implications arising from the newly published [Scottish Planning Policy (“the new SPP”)] and [National Planning Framework 3 (“NPF3”)] in terms of LDP policy response to hydraulic fracturing and coal bed methane gas extraction, is that a) a presumption in favour has been removed and replaced by opposition or more stringent guidelines; b) the LDP should pay greater and more explicit attention to the assessment of cumulative impact, as various representations suggest; c) buffer zones remain inappropriate; and the criteria in DRAFT MINERALS SUPPLEMENTARY GUIDANCE address all of the requirements set out in d) paragraphs 237 and 240 of the new SPP. 3) Additionally, evidence from a meeting between Laura Eaton-Lewis and independent Geologist, Angus Miller PhD (specialist in Seismology and the Midlands Valley) which provides evidence that current legislation being considered under the UK Infrastructure Bill is in contradiction with recommendations from the British Geological Society Shale Report for UK Government, and current industry protocols for safety. 1.1 The shift of Government’s position from supportive to precautionary is best highlighted in the change from “operators should take into account the potential effects on neighbouring uses and use directional drilling wherever feasible” in SPP 2010 (paragraph 238), and the 2013 consultation draft, to the following guidelines in paragraph 245 in the final version: applicants should undertake a risk assessment (which the letter attached as Appendix 1 makes clear is an “additional requirement” over and above environmental impact assessment); the risk assessment should be developed in consultation with local communities (as well as statutory consultees); the risk assessment should clearly identify potential risks using a source- pathway-receptor model; the risk assessment should explain how measures will be used to monitor, manage and mitigate the risks; and the evidence from the risk assessment should lead to buffer zones being proposed, to be assessed by planning authorities; if a buffer zone is considered inadequate, planning permission should be refused. 1.3.5 A theme which has remained consistent throughout the development from old to new SPP is the requirement, where a Petroleum Exploration and Development Licence (PEDL) extends across local authority boundaries to “provide a consistent approach to extraction”. As PEDL133 also extends across Stirling Council’s area, it is therefore necessary to examine their proposed plan. 1 In response to the my points 2 (a), (b), (c) and (d) about NPF3 and the new SPP: . a) A presumption in favour has been removed – as confirmed by the letter attached at Appendix 1, which says that stakeholders welcomed “the removal [in the consultation draft] of the perceived presumption in favour of development” – and replaced by more stringent guidelines, notably those that appear in the new SPP at paragraphs 240, 245 and 246. . b) Insofar as cumulative impact can be understood as meaning the accumulation of impacts over time within the same development, as old phases are completed and new ones begun, the new SPP does “encourage operators to be as clear as possible about the minimum and maximum extent of operations” in order that such future cumulative impact can be assessed at the exploration phase. In the DRAFT MINERALS SUPPLEMENTARY GUIDANCE Sections 6.45 and 6.46 make no reference to the monitoring of water quality. Planned unconventional gas extraction is associated with the risk of gas or contaminated water escaping into local ground water or into the sea-bed of the Firth of Forth. It is therefore essential for communities close to this activity that monitoring of water quality takes place regularly, transparently and close to drilling sites. Sections 6.45 and 6.46 make no reference to baseline monitoring of any kind. In order to make an accurate assessment of the impact of unconventional gas extraction, there must be baselines of air, ground water and surface water quality. These should take place for at least one year before any activity begins to allow for seasonal variations and ideally for several years to allow for variations in weather between years. Without these baselines, any attempt to hold potential polluters to account will be restricted and environmental monitoring would therefore be insufficient to protect the environment. . c) It is quite clear that buffer zones based on the new risk assessment have become extremely important, to the extent that an inadequate proposal for a buffer zone may lead to a refusal of planning permission. Section 6.53 makes reference to buffer zones of 500m to protect communities from noise, dust, vibration and visual intrusion. This buffer zone does not consider the potential for air and water pollution which should necessitate a much larger buffer zone. We suggest 2,000m as recommended by Friends of the Earth Scotland and implemented in New South Wales, Australia. Latest Scottish government policy states that buffer zones should apply to all onshore oil and gas activity. . d) Impacts on “individual houses”, as set out in paragraph 237 of the new SPP, are not covered by policy DRAFT MINERALS SUPPLEMENTARY GUIDANCE. Nor are any of the guidelines in paragraph 240 (or indeed many in paragraphs 245 and 246). 1.7.2 Additional evidence gathered from a meeting between Laura Eaton-Lewis and independent Geologist, (specialist in Seismology and the Midlands Valley) which provides evidence that current legislation being considered under the UK Infrastructure Bill is in contradiction with recommendations from the British Geological Society Shale Report for UK Government, and current industry protocols for safety. The UK government and Scottish Government are committed to reducing emissions and increasing renewable energy sources, both of these goals will be set back by UCG extraction. If UCG extraction is to be considered for planning permission, independent scientists and industry specialists recommend that planning regulations require the following as a minimum: a) provision of adequate community restoration bonds to cover cleanup and restoration in the event of community damage, pollution and well failure b) Baseline studies of water, air and soil must be carried out for at least a year by an independent body, such as SEPA. This does not currently happen and would have to be undertaken at cost to the company. This is essential to measuring pollution and safety levels and showing the absence or presence of public health effects. c) a 2km buffer zone between communities is an essential safety measure, since wells can and do fail, leading to contamination of groundwater, farmland and air d) As recommended in the British Geological Society Shale Reports, there should be absolutely no drilling at all between a barrier distance of 304m from the bottom of the lowest existing mine. This is due to risks of subsidence from collapse of mines. Independent geologists actually recommend a more stringent minimum safe depth of 500m as per protocol in USA and Australia. e) Planning should consider fully the risks of the geology under settlements which include fractures and fissures from historic mines, meaning that in such geologies, leakage of gas and fluid from hydraulic fracturing and goal gasification is highly certain. f) Current UK plans in the infrastructure bill to allow seismic activity of up to 3.5 magnitude is too problematic for the geology of the Midland Valley and Fife area and causes collapse of mines through and under mines. Independent geologists recommend maximum of 2.0 magnitude. g) British Geological Society have baseline level of seismic activity, and show there are currently very few big earthquakes but lots of tunnel collapses in coalmines, some serious subsidence related to shallow mines. Since the demise of the coal mining industry there are no longer many seismic stations around preventing BGS from recording such small events now. There is case for installing seismic monitoring equipment to ensure monitoring is done properly to prevent recurrent collapse of historic mines (the impact of which would be subsidence and leakage of gas and fracturing fluid into the surrounding environment) h) For planning permission to be granted you need to have a process in place to monitor: Depth, Where earthquakes might be, where contamination might happen. The Fife and Midland Valley area is a very fractured coalfield and fractures will be bad. i) New Scottish Planning Policy includes recommendations for Green belt, and protection of the coastal environment at a high level, as guidance for Local Authorities. Council Planning should ensure that this policy is followed and on that basis what should and shouldn’t be allowed If communities are to experience a truly safe extraction of UCG in the particular geology of the Midland Valley, these safeguards are reasonable to provide the minimum level of public health.
Posted on: Sun, 07 Dec 2014 15:09:57 +0000
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