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CPRE Lancashire submits comments to Inspector on fracking Monitoring Appeals

Tuesday, 29 September 2015 12:09

Shale gas extraction rig Shale gas extraction rig Photo: © Brian Jones

The oil and gas exploration and production company Cuadrilla1 has now appealed to the Planning Inspectorate against all four decisions by Lancashire Country Council. 

The decisions concern the company’s proposed fracking operations at its two sites in the Fylde, namely Preston New Road, Near Little Plumpton, and Roseacre Wood, Roseacre Road. 

All four appeals will be determined by Public Inquiry.

The appeals relating to the planning applications for exploratory activities at the two sites2 have only very recently been lodged.

However, the appeals relating to monitoring activities3 have now passed the written submission stage and CPRE Lancashire has submitted comments to the inspector appointed to determine the appeals; our principal object is to ensure that, if fracking is permitted at these two sites, it will be carried out with an acceptable level of risk.

In summary, CPRE Lancashire sets out three main points in relation to the monitoring appeals:

1. Condition relating to hydraulic fracture operations:

Fracking is to be a 2-stage process to enable ALL monitoring data (not just those from a relatively few realtime monitors) to ensure operations are confined to specified target formations.

The condition: Following the first hydraulic fracture stage of a given well, each subsequent stage shall not be executed until the signals from the entire deep 80-borehole seismometer array have been analysed to determine the penetration of the hydraulic fracture fluid, and the injection volume of the first stage shall not exceed 400m3.

Explanatory Note:
The Environment Agency and the Oil and Gas Authority agree that the risk of fracking in the shallower Millstone Grit is unacceptable. However the wording of the Environmental Permit states that, if the Millstone Grit strata were penetrated, it would not constitute a breach of the Permit. The Oil and Gas Authority, which approves the Hydraulic Fracture Plan, accepts the Permit. This is a deficiency in the regulation of hydraulic fracturing. It is not sufficient to rely on the goodwill of Cuadrilla to avoid the shallower strata. In the absence of robust regulation, it becomes the responsibility of the Lancashire County Council (as the Minerals Planning Authority) to make good the deficit, as stated in the Planning Practice Guidance for the National Planning Policy Framework (ref. ID: 27-112-20140306, par. 112).

2. Conditions relating to the decommissioning of the monitoring sites:

The sites shall be restored to their current agricultural condition and designation. Soil handling shall be undertaken in accordance with best practice, and the site restored by the replacement of stored soil, redepositing subsoil and topsoil sequentially.

3. No right of further development at monitoring boreholes: 

The consent must not establish the principle of a right to development at the borehole locations, i.e. the use of these sites for any purpose other than consented would require a new planning application. 

The full submission is available below.  

Please note that the Branch will also be making submissions to the inspector concerning the appeals4 relating to exploration for shale gas at the two sites.
 

Notes:
1. We use the term Cuadrilla to refer to both Cuadrilla Bowland Ltd. and Cuadrilla Elswick Ltd.

2. Exploration: Roseacre Wood, APP/Q2371/W/15/3134385; Preston New Road, APP/Q2371/W/15/3134386

3. Monitoring: Roseacre Wood, APP/Q2371/W/15/3130924; Preston New Road, APP/Q2371/W/15/3130923

4. Exploration: Roseacre Wood, APP/Q2371/W/15/3134385; Preston New Road, APP/Q2371/W/15/3134386

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