Councillors are being recommended to approve IGas’s plan for up to 12 groundwater monitoring boreholes at a proposed shale gas site in north Nottinghamshire.
The application, which goes before the county council’s planning committee next week (Tuesday 19th January), is the first step towards fracking at the former Cold War missile base near the village of Misson.
There have been more than 300 objections to the application. Concerns included risk to local heritage, as well as contamination and noise.
There have been doubts about whether the proposed boreholes would produce useful data. And some objectors have argued that the plans should be considered at the same time as a separate IGas application for two exploratory shale gas wells. Approving the monitoring boreholes would, they said, amount to pre-determination of the exploration application.
A report by planning officers, which will go before the committee meeting, concluded that the application should be approved. The application complied with planning policies, the planners said, and no adverse impacts significantly outweighed the benefits.
This could be one of the last times a planning authority decides an application for ground monitoring boreholes. The government proposes to make these boreholes a permitted development that don’t need planning permission.
The site off Springs Road is about 3km from the centre of Misson. During the 1960s it was the launch site for the mark 1 Bloodhound surface-to-air guided missile. It is next to the fenland area of Misson Carr Site of Special Scientific Interest (SSSI) and within 2km of two other SSSIs.
IGas has no current applications to frack at the site. But its website makes clear that if it gets permission for two exploratory shale gas wells (application ES/3379) and they are successful it will apply to frack.
The application is for up to 12 boreholes, with three each at four different locations. Four boreholes would be drilled to depths of up to 40m into Nottingham Castle sandstone, another four to depths of up to 10m into sand and gravels and the final four down to 3m into marls and clays.
According to the application, the drilling and installation of each set of boreholes would take up to two weeks and total drilling would last up to eight weeks. Drilling would be carried out between 7am and 7pm on weekdays. Access to the site would be off Springs Road.
The nearest property is 30m away but this is unoccupied and described as “in the control of IGas”. The next nearest property is about 130m away.
Under the Infrastructure Act 2015, IGas is required to monitor methane in groundwater for 12 months before carrying out hydraulic fracturing. The planners’ report said:
“The proposed groundwater monitoring boreholes are not exclusively proposed for, but would assist in, meeting the identified requirement of the Infrastructure Act”.
The planners said there had been 314 public objections to the application. Misson and Blaxton parish councils objected and CPRE Nottinghamshire recommended refusal.
Drilling the boreholes The parish councils and others said the depths of boreholes and their locations were inadequate to provide confident and comprehensive data.
Yorkshire Water said its drinking water boreholes in the Sherwood Sandstone Group were between 144m and 175m deep. It recommended the monitoring boreholes should be at least 150m deep. Emeritus professor David Smythe recommended boreholes at least 1,500m deep and some should be at least 1.5km away from the site.
The Environment Agency did not object to the application but it also recommended deeper groundwater monitoring, through the entire thickness of the Nottingham Castle sandstone principle aquifer. It told Nottinghamshire County Council that in the absence of data, the EA would assume the groundwater was clean and uncontaminated. If it deteriorated following future exploratory drilling IGas could be liable for cleaning it up. The planners said:
“Consideration will have to be given on whether the boreholes truly reflect up-gradient and down-gradient conditions after a period of groundwater monitoring has taken place”.
Nottinghamshire Wildlife Trust questioned whether work on the boreholes could be completed within the eight weeks claimed.
Pre-determination 145 objections argued that the application made no sense as a stand-alone consent. They said if the monitoring boreholes were approved in advance of an application for shale gas exploration this would amount to pre-determination.
Heritage The parish councils said IGas had not considered the heritage value of the missile site and the impact of the application on archaeological features, such as crop marks. Historic England, which did not object, said there was an important historic landscape relationship between the site and the Cold War bomber base at Finningley. “Due care” should be taken to avoid damage, it said.
Contaminated land IGas had commissioned 10 test pits on the site. These revealed above recommended levels of phosphorous, Polycyclic Aromatic Hydrocarbons (PAH), Total Petroleum Hydrocarbon (TPH) and metals. Asbestos was also detected. Some objectors said the disturbance of the site would be an unacceptable risk to site employees and visitors to the nearby SSSI. Some objectors pointed to an inconsistency in the planning application form which said there was “no known contamination on the site” while reports supporting the application indicated that there was.
Noise Bassetlaw District Council, which did not object to the application, said 7am was too early a start time and recommended 8am. The local MP, John Mann, said the site was too close to Misson and nearby dwellings. He said fracking locations should be more remote.
Wildlife Objections included no assessment of the potential impacts of the boreholes on great crested newt, water vole and breeding birds. The site is within 2km of 12 local wildlife sites and three SSSIs. Nottinghamshire Wildlife Trust said it was raising water levels in the Misson Carr SSSI and there had been no assessment in the application of the impact on hydrology. Noise levels at Misson Carr were likely to be above 55dba which can deter bird breeding.
- Ground and surface water contamination
- Risks of spillage of transported chemicals and waste
- Impact of water extraction on local hydrology
- General opposition to fracking (mentioned in 144 objections)
- Risk of vibration detonating unexploded ordnance: Misson was a war-time decoy runway for RAF Finningley
- Industrialisation of the countryside and adverse impact on tourism
- Light and air pollution
- Previous unacceptable performance of IGas and Dart Energy
- Late submission of additional information and failure of IGas to inform the community liaison group about these details
- Cumulative impact of other sites
What the planners said
The planners’ report said there were three comments in support of the application. The supporters said there was a need to exploit all home-grown resources to meet energy needs and that drilling would be suitably managed and monitored.
In response to objections, the planners said:
Boreholes “If the Environment Agency do decide that additional and/or deeper boreholes are necessary, that does not make the ones that are under consideration now, unacceptable. Whilst there may be a need for additional and/or deeper monitoring boreholes, this is not a reason for those proposed thus far to be refused”.
Predetermination “Approval of this application will not prejudice the MPA’s [Mineral Planning Authority’s] ability to determine future applications.”
Heritage: The boreholes were outside the area of the site which contained the remains of the 16 missile launch pads and so would not cause direct harm. The planners said:
“The proposal would have no direct impact on the missile pads and any impact on potential archaeology would be minimal.”
“The proposed development is assessed as outweighing the significance of the missile pads as a non-designated heritage asset”.
But they recommended archaeological supervision of the drilling work.
Contamination “The proposed development is a suitable land use and there would not be an unacceptable risk to groundwater, surface water and human health”. The report said the boreholes would be not be on the missile pads where there were higher levels of contamination. The planning authority should assume that the regulatory regimes operated by the Environment Agency and others to protect human health “will operate effectively”.
Noise The noise from drilling was “within acceptable noise limits for temporary operations”, the planners said. Once the boreholes had been drilled there would be no perceptible noise. They added that short duration and temporary nature of the works allowed the proposed development to comply with national guidance.
Wildlife There were no objections from Natural England or Nottinghamshire County Council. The planners said:
“Where there are differing views between ecological bodies the Minerals Planning Authority is entitled to take the recommendation of the statutory body [Natural England]”.
They concluded there would be no unacceptable impact on the SSSIs or the local wildlife site ditch network and the application complied with planning policy and legislation.
Flooding: Low risk of flooding from the River Idle, nearby drainage ditches, artificial water bodies or from surface water.
Planning policy The planners said it was a material consideration that counted in favour of the application that the government proposed to make monitoring boreholes a permitted development, without the need for planning permission. They said monitoring boreholes were not covered by the Nottinghamshire Minerals Local Plan, either the adopted version or the one in preparation. They were also not covered by paragraph 144 of the National Planning Policy Framework, which gives great weight to the benefits of mineral extraction. The application met the requirements of the Bassetlaw Core Strategy policy DM3 on the reuse of previously-developed land.
Landscape Three of the four borehole locations would be screened by large industrial buildings. The drilling rig, likely to be 5.5m high, and the proposed welfare unit were not in keeping with the wider countryside character but they would be temporary and have a minor impact.
Traffic There would be two lorry journeys: one to bring in the rig and one to remove it. Local roads could accommodate heavy traffic but the planners recommended avoiding Misson.
IGas The report said the previous performance of IGas or Dart Energy would not be considered in deciding the application. It added there was no statutory requirement on IGas to inform the community liaison group.
The planners recommended 21 conditions. These included:
- Work must start within three years and be completed within five years of the start date
- Boreholes should be no deeper than 40m
- The height of the drilling rig shall not exceed 10m
- Lorries visiting or leaving the site should avoid Misson
- Boreholes should be cleared of unexploded ordnance before drilling starts
- Noise shall not exceed 91Dba at a distance of 7m
- No one can live in Misson Springs Cottage (the nearest property) during drilling
- No boreholes should be drilled within 155m of the nearest occupied property
- Work should be between 7am and 7pm on weekdays only
- No drilling, vegetation clearance or restoration between 1st April and 1st September in any year
- Agreed plans for archaeological watch brief
- Work to follow Great Crested Newt precautionary working method statement
The planning committee meets at 10.30am on 19th January 2016 at County Hall, West Bridgford, Nottingham NG2 7QP.