This is a template letter published by Frack Free Surrey, which we have been given kind permission to publicise and which may be a useful template:
APPLICATION NO: GU15/P/02110
Proposed development at: Albury Park Wellsite, East of New Road, Albury, Surrey.
Island Gas Limited.
I wish to object in the strongest terms to the application by IGas for production at the above site. As you know, planning applications have to be decided against national and local planning policy. The IGas proposals conflict with policies in the:
- National Planning Policy Framework (NPPF)
- Surrey Minerals Plan
- Guildford Local Plan
- Metropolitan Green Belt
The recent planning officers report defined the proposal as a “major development”. Under the NPPF paragraph 116, planning permission should be refused for major developments in AONBs except in exceptional circumstances and where it can be demonstrated they are in the public interest.
The planning officers accepted the development would have:
“some detrimental effect on the landscape and would not enhance the natural beauty of the AONB during either the construction or operational period.” That the proposal amounted to “significant harm” to the Green Belt by encroaching on openness.
The proposal also breached policies designed to protect the AONB in the Surrey Minerals Plan and Guildford Local Plan.
The Surrey Minerals Plan policies MC2 and MC14 state that minerals developments in the AONB can be approved only if they have been demonstrated to be in the public interest, there is a need for them and there will be no significant adverse impacts on the appearance, quality and character of the landscape.
Policies RE5 and RE6 in the Guildford Local Plan seek to conserve the visual quality or distinctive character of the AONB. Policy RE2 states that new building would be inappropriate unless it prevents sprawl, reserves character or assists urban regeneration.
The planning officers’ report also says that the proposal would harm ancient woodland by creating car parking on the access track. The NPPF says loss or deterioration of irreplaceable habitats, such as ancient woodland has to be outweighed by benefits.
I reject, in the strongest terms, the conclusion of the planning officer that all of the above negative impacts can simply be outweighed by a national ‘need’ for ‘indigenous’ gas supply.
The recently released DECC Committee on Climate Change report stipulates that UK onshore gas production should only be permitted
If three vital conditions are in place
– none of these conditions, especially Carbon Capture and Storage technologies, are remotely certain to be met.
I implore you to reject this proposal in an AONB as there are no reasonable ‘exceptional circumstances’ and it is clearly not in the national public interest, given our legally binding climate change mitigation commitments, and it is certainly not in the local public interest.
Air pollution and emissions
The period of gas flaring is very concerning for a number of reasons.
The Research Journal of Environmental and Earth Sciences 4(5): 525-528, 2012 states:
‘Gas flares have harmful effects on the health and livelihood of the communities in their vicinity, as they release a variety of poisonous chemicals. Some of the combustion by-products include nitrogen dioxides, sulphur dioxide, volatile organic compounds like benzene, toluene, xylene and hydrogen sulfide, as well as carcinogens like benzo(a)pyrene and dioxins. Humans exposed to such substances can suffer from variety of serious ill-health effects.’
No detailed analysis has been produced of the gas to be flared. This is a serious omission from the application.
Evidence of gas flaring from the USA and Australia suggests that the total harm caused by flaring pollutants is more than the sum of the individual components.
Natural gas processing is a significant source of fugitive emissions of both methane and volatile organic hydrocarbons (VOCs). The World Bank estimates that every year, some 360 million tonnes of CO2 is released to the atmosphere through flaring and venting. This has a detrimental effect on the environment, contributing significantly to global warming and acidification of both land and sea. A considerable proportion of this CO2 comes from the production of Oil and Gas. At a crucial point in human history, if we are to avoid runaway climate change ‘keeping it in the ground’ needs to be the concern of every public authority, and indeed the UK’s Climate Change Act 2008 places legal obligations on public bodies to comply with emission reductions targets relating to climate change. These duties require that a public body must, in exercising its functions, act in the way best calculated to contribute to the delivery of emissions reduction targets. Flaring is incompatible with this objective, which is why there are international calls for ‘green completions’, involving the capturing of the gas – this is not proposed at this site.
Gas compressor emissions
Very concerning for the local population is the proposed notion of powering the gas compressor by burning some of the gas from the well 24/7 for 15 years. There needs to be a detailed analysis of the effects of the exhaust emissions of this from a variety of aspects: human health, ecology, local amenity impacts e.g. from those using the nearby playing fields. Moreover, the effect on vegetation is likely to be very significant.
Traffic and Transportation
The increase in vehicle movements is very concerning, given the nature of their load. In effect there will be a couple of tonnes of compressed gas being moved on a daily basis. These vehicles are a serious danger to not only the local population around the site but to those on the route to the ultimate destination. A recent US study, by the National Institute for Occupational Safety and Health, showed that vehicle crashes are the single biggest cause of fatalities to oil and gas workers while the increase in onshore gas production has resulted in a 350% increase in traffic fatalities in regions where gas production is occurring.
The roads around in AONB are totally inappropriate for these sorts of vehicle movements, and the villages the HGVs will pass through are densely populated and the roads very narrow in places.
I urge you to reject this proposal.
Surrey CC email list
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