Comment on West Newton A Planning Extension – Autumn 2018

Rathlin Energy have failed to complete their test program at the West Newton A well site in Holderness, within the time 3 year time period granted by East Riding council.  Again.

So after five and half years on site, and a test program that was a catalogue of mishaps, they have applied for another 3 year extension.

This is concerning because they could drill a second well, or use unconventional processes including pumping toxic chemicals into the ground. This carries risks to the air, water, and land (and therefore to our health). This would be a step towards turning the area in to a gas field, and widespread Hydraulic Fracturing (fracking) as hydrocarbons are getting more and more difficult to extract. Although there is a ‘no fracking’ condition on this site, the government definition only covers the very largest High Volume Hydraulic Fracturing; most fracking is still permitted.

The application is currently open for consultation, and East Riding Council would like to hear your views.

 

West Newton A Wellsite – Temporary Period Extension
Planning Application Summary  18/02924/CM

Comment Here

 Even a comment of a single word, “Object” matters. 

The total number of objections, which will be read out to the Planning Committee, is vitally important in demonstrating opposition – especially from local people.

 

Key Points

  • Be clear about whether you support the application, to make it easy for planning officers to include your comment in the total number of supporters/objectors.  e.g. you may want to start your comment with the word, “Object”.
  • Be nice.  Don’t give them any reason to discount your comment.  (See below.)
  • Be relevant.  Only Material Considerations can be taken in to consideration.
  • East Riding council said, this is a temporary permission … At the end of the period the site needs to have been restored to its former use in the interests of protecting the visual amenities of the area.”  The time period has been extended once already.
  • Rathlin Energy incompetence & mishaps galore, using uncertified and dangerous rigs, rusty tanks with holes, multiple permit breaches, and a mini-frack emergency  – see Incidents
  • There’s a time out on the planning website, so if your comment is long write it in a text editor first, then copy & paste it in to the website.
  • Deadline for comments is 2nd October

 

West Newton A Wellsite information – click here

including exact location, links to planning documents, Environment Agency Permits, ‘Community’ Liaison minutes etc.

 

West Newton A Photo Gallery is here

 

Catalogue of Mishaps: Incidents

 

News Report

Rathlin Energy seeks three more years for E Yorks gas site – again – DrillOrDrop

 

Temporary Permission?

In 2015 the temporary planning permission for West Newton A expired, and Rathlin applied for a Variation of Condition, for another 36 months.  This was, “APPROVED … subject to the following conditions:”

1.  …  At the end of the 36 month period all drilling and test activities shall have ceased and all equipment, access, structures and buildings shall have been removed from the site, the borehole shall have been plugged and abandoned, the bunding and perimeter fences and ditches removed, the site levels re-graded and the site shall have been restored to agriculture …

This condition is imposed because this is a temporary permission …

At the end of the period the site needs to have been restored to its former use in the interests of protecting the visual amenities of the area.

Notice of Decision, East Riding of Yorkshire Council

In November 2018 Rathlin Energy’s 3 extra years will be up, and guess what, they haven’t restored the well site back to field yet.  Instead, they’re applying for a Variation to the Variation, requesting another 3 years.

Should they be permitted to continually extend their ‘temporary’ planning permission?

What is the point of temporary permission, if they’re allowed to repeatedly lengthen it?

Should we be allowing them more time to explore for yet more fossil fuels, even as the climate breaks down around us, with millions fleeing their homes in the face of raging storms, a summer of heat waves, and forest fires as far as the arctic circle?

The permission allows Rathlin Energy to explore and test for oil and gas, including drilling a second well, large numbers of HGV movements, noise, light, hazardous chemicals, toxic waste, air pollution from diesel fumes, methane emissions, carbon dioxide, gas flaring, and so on.  Testing could include the mini-frack test described in their Environmental Permit.

 

Another Well?

You may think that the worst disruption is over, as the well has already been drilled and tested here.  However they have permission to drill and test a second well on this site.  That would of course mean hundreds of HGV movements, return of a drill rig, a period of 24/7 drilling, and all the associated disruption, pollution, and risks.

 

To Frack Or Not To Frack?

The test program could include various risky procedures, using a range of toxic chemicals, and unconventional techniques, including the hydraulic injection of fluids.

It is true that a No Fracking Condition applies to this well.  However, it specifies the government re-definition of Hydraulic Fracturing, which is rather specific, and extreme.  Therefore most fracking is still permitted at this site. That includes the mini-frack Rathlin Energy want to carry out.

More details here.

 

General advice about responses

Guidance for commenting on planning applications, on the Council Planning Department website.

Guidance for commenting on planning applications, on the Council Planning Department website.

Guidance from East Riding of Yorkshire Council (ERYC) is available here:

Guidance for commenting on planning applications

Particular attention is drawn to two vital aspects of writing your response.

  • Comments deemed to be libellous, discriminatory or otherwise offensive will lead to your letter being set aside and ignored.
  • Any objections must be based on material considerations. These are defined in the guidance and attention is drawn to the statement that “The applicant’s motives” are normally not a material consideration.

This means that responses must be based on what is known about Rathlin Energy’s actions since the planning permission was notified in 2013 and specifically the issues arising from the current planning application. It is not a material consideration to oppose fracking in the UK or the East Riding but nevertheless there are serious concerns that the ERYC Planning Committee must address. Given the well problems there may be material considerations about regulation, risk assessment, well design and environmental impact that need to be considered.

Handwritten responses may be sent in but are not advised because the scanning process for inclusion on the ERYC website and photocopying for elected members will cause delay due to work pressure.

Material Considerations

Material considerations you may wish to write about include:

  • Impact on the neighbourhood
  • Planning history of the site i.e. the contrast between what Rathlin Energy stated in their planning application and supporting documents, the planning conditions and their actual behaviour. Breaches of planning permission are also relevant.
  • The overbearing nature of the proposal. The expert report on hydrogeology (i.e. the aquifer and water supply) submitted by Rathlin Energy in their initial application refers to water supply to Hull but overlooks significant risks. This is an overbearing proposal which prolongs the risk to our water courses. (More detail below)
  • Loss of ecological habitats. Observations at West Newton and Crawberry Hill indicate that the initial independent ecology report commissioned by Rathlin Energy was wholly inadequate.

 

You May Want To Comment On…

Some points that you may like to raise and extend upon (in your own words):

Traffic

There will be many vehicles in and out of the site, including large tankers and lorries. West Newton A is on a narrow road and increases in traffic will cause increases in noise and air pollution.

Noise and Light

There will be work undertaken 24/7 in an area that is currently tranquil and rural. People living and working around the area could be affected by noise and light, day and night. The site is too close to homes.

Water and Ground Water

There is a potential for spills and leaking around the well resulting in pollution above or below the ground. As large quantities of hydrochloric acid are being used there is a serious risk to water.

Air quality

Fumes from the flare stack; gas leaks when it fails to ignite; pollution from generators. The application shows that the flaring would lead to increases in pollutants around the area.

Wildlife

Industrialisation of the site could have negative impacts on wildlife including barn owls, grass snakes, and newts

Energy Security

The extraction of onshore fossil fuels would make minimal difference in the UK’s energy security. In three recent reports it was only mentioned once minimally but not in future government projections. The need for gas and oil is reducing due to developments in renewables, including plummeting costs. It’s the wrong time to be exploring for yet more fossil fuels.

Climate

Burning fossil fuels is causing climate breakdown. The UK Government and others have made legally binding climate change targets. The extraction of oil and gas will make it much harder to meet these targets. The government’s national planning guidance highlights this.

Rathlin Energy’s Track Record

Their record includes numerous breaches of Environmental Permit, and other problems.

Other comments

Rathlin Energy keep pushing back the ‘completion date’ on their planning permission and therefore are not meeting the terms of the permission, which is to return the land back to agricultural use.