By e-mail
24 October 2013
Ms Jane Moseley
West Sussex County Council
County Hall
Chichester
South East Office
39-41 Surrey Street
Brighton
BN1 3PB
Dear Ms Moseley
Planning Application No: WSCC/083/13/KD
Land south of Boxal Bridge, Northup Field, Wisborough Green, West Sussex, RH14
0DD
The installation of a well and associated infrastructure, including access road and soil
bunds, for the drilling of a vertical borehole and contingent horizontal borehole from the
same well for the exploration, testing and evaluation of hydrocarbons for a temporary
period of three years
Friends of the Earth OBJECTS to the application on the following grounds:
1. Inconsistent with the need to mitigate climate change emissions
2. Inconsistent with the precautionary principle and EU Water Framework Directive
3. Insufficient evidence on impacts (both existing and future)
Climate change
The climate change impacts of an over-reliance on gas are very serious, with the Committee
on Climate Change concluding that to meet our carbon budgets, electricity generation must
be almost entirely decarbonised by 2030. The CCC have warned that ‘excessive use of
unabated gas-fired capacity… would be incompatible with meeting legislated carbon
budgets’ and the Climate Change Act.
The Tyndall Centre at Manchester University conducted an assessment of the climate and
environmental risks from shale gas and concluded that shale gas extraction poses
‘significant risks to human health and the environment’ and that there is no evidence to backup industry claims that shale gas could be a transition route to a low carbon future
The Inter-Governmental Panel on Climate Change (IPCC) recently confirmed that there are
unprecedented levels of greenhouse gases in the atmosphere and that it is extremely likely
[95-100%] that human influence has been the dominant cause of observed warming since
the mid-20th century. It confirmed that there will be more frequent temperature extremes,
heat waves will occur with a higher frequency for longer, and there will be more intense and
frequent extreme rainfall, resulting in flooding.
The International Energy Agency has said that expansion of unconventional gas reserves
globally is consistent: "with a probable temperature rise of more than 3.5 degrees Celsius in
the long term"
The National Planning Policy Framework points out that:
“Planning plays a key role in helping shape places to secure radical reductions
in greenhouse gas emission”
Local government must take its climate change obligations seriously and refuse damaging
development. Burning more fossil fuels in England would not help us to meet our
commitments under the Climate Change Act in the future
Precautionary principle
We are aware that this is not an application to use hydraulic fracturing. However, it is clear to
us from the fact that the developer wishes to drill horizontally, together with information
about the geology in the area that should gas or oil be discovered it would lead to a need for
hydraulic fracturing. We therefore believe that the precautionary principle must apply
because the development risks unacceptable adverse impacts
The precautionary principle is a principle at the heart of environmental law to which the UK
Government has committed since the UK signed the Rio Declaration on Environment and
Development in 1992. This states (at Principle 15) that, “where there are threats of serious
or irreversible damage, lack of full scientific certainty shall not be used as a reason for
postponing cost-effective measures to prevent environmental degradation”. Article 191(2) of
the Treaty on the Functioning of the European Union declares that EU policy on the
environment “shall be based on the precautionary principle”.
The precautionary principle finds specific expression through international and EU law
instruments to which the UK is a signatory (and in the case of EU law, bound) including the
Water Framework Directive and the Habitats Directive. The Water Framework Directive
applies strict standards and controls in relation in particular to groundwater.
There is growing evidence in the UK and globally of the serious environmental impacts from
hydraulic fracturing including to ecology, climate, water resources, air quality and seismic
activity. The European Commission recently identified water contamination, water resource
depletion, air pollution, biodiversity impacts and noise as high risk concerns in its report
‘Support to the identification of potential risks for the environment and human health arising
from hydrocarbons operations involving hydraulic fracturing in Europe’ August 2012
(http://ec.europa.eu/environment/integration/energy/pdf/fracking%20study.pdf).
Environmental Impacts
The Sussex Wildlife Trust has pointed out that the site is situated within an important area
for bats. We are concerned that there are discrepancies between the information submitted
by the developer and the surveys completed by the West Weald Landscape Project.
As Habitats Directive Annex II species have been identified in or near the site we feel it is
crucial that the authority is given full data before making any decision on the application.
We also note that the Sussex Wildlife Trust raise valid concerns regarding noise and lighting
impacts and we ask that these issues are fully addressed. We support the Wildlife Trusts
requests for further consideration of a range of issues in their letter. It is our view that this
development would be detrimental to biodiversity in the area.
The National Planning Policy Framework states that “The planning system should contribute
to and enhance the natural and local environment by minimising impacts on biodiversity and providing net gains in biodiversity where possible,
contributing to the Government’s commitment to halt the overall decline in biodiversity,
including by establishing coherent ecological networks that are more resilient to current and
future pressures”.
We note that the company has three sites it wishes to develop in West Sussex and that
other companies have licenses in the area. We are concerned about the cumulative impacts
if a number of sites are developed across the county. This site lies near to the border of the
South Downs National Park and we understand that Celtique will be submitting another
application inside the National Park.
Local Authorities are directed by the National Planning Policy Framework to
“ensure, in granting planning permission for mineral development, that there are no
unacceptable adverse impacts on the natural and historic environment, human health or
aviation safety, and take into account the cumulative effect of multiple impacts from
individual sites and/or from a number of sites in a locality;” (paragraph 144)
Friends of the Earth is of the view that the authority lacks sufficient information on the
environmental impacts of the proposed activity such that the application cannot be
determined at this time.
Yours sincerely,
Brenda Pollack
South East Regional Campaigner