Planning Objections

When objecting to the planning application, please include your name and address or your objection may not be counted. If using a template, please adapt it using your own words as duplicate letters will not carry the same weight.

The planning reference is 12/04304/FUL. You can submit comments online at: http://www.bathnes.gov.uk/services/planning-and-building-control/view-and-comment-planning-applications

The main points the local planning authority will consider when deciding whether to approve a planning application are the ‘material considerations’ of that specific project. These are likely to carry more weight than those relating to developments that could stem from it, which would require a new planning application (eg Full-scale Coal Bed Methane production).

Specifically, important points to include involve the size and location of the project, how it will function, and the relationship of the site with the immediate surroundings. Here are some examples you could use:

  • The drilling rig will be prominent and unsightly.
  • To approve this planning application would be in contradiction of policy GB.2 of the Local Plan, which states that: “Permission will not be granted for development within or visible from the Green Belt which would be visually detrimental to the Green Belt by reason of its siting, design or materials used for its construction”.
  • Policy NE.1 states that: “Development which does not either conserve or enhance the character and local distinctiveness of the landscape will not be permitted.”
  • The drilling rig will be in use 24 hours a day, 7 days a week and will be extremely noisy. The nearest residential properties are only 285 metres away.
  • The site will be lit at night and this could be a nuisance to those living near the site, and a distraction to drivers. Para C3.96 of the Local Plan states that: “Within rural areas and open countryside external lighting can be extremely prominent and visible for some distance…proposals for external lighting in the countryside are therefore not generally acceptable.”
  • The site would be situated within the Green Belt and the Forest of Avon.
  • The site is located on greenfield land which is currently used for the grazing of agricultural stock. Para C1.3 of the Local Plan states that a purpose of the Green Belt is: “to retain land in agricultural, forestry and related uses”.
  • There is a very real risk of groundwater contamination. Coal Bed Methane has been linked to water contamination in Australia and the US where the technology is widely developed. CBM almost always involves pumping huge quantities of water out of the coal seam – this is water that has been marinading in coal for thousands of years, and can contain a wide variety of toxic contaminants. There is groundwater in the silt, sand and gravel above the coal seams. If this is contaminated, it could lead to contamination of the nearby River Avon.
  • Para B6.30 of the Local Plan states that: “An important consideration in planning is the ‘precautionary principle.’ This requires that where there is significant risk of damage to the environment, pollution controls will take into account the need to prevent or limit harm, even where scientific knowledge is not conclusive.”
  • Coal Bed Methane wells could leak. These wells can never be removed, and the steel and concrete structures plunged deep into the earth will decay slowly over time. All gas wells will leak eventually. This would have a serious impact on local health.
  • Policy ES.10 of the Local Plan states that: “Development will not be permitted where it would have an adverse impact on health…by virtue of odour, dust and/or other forms of air pollution.”
  • Approving this plan would contradict policy M.8 of the Local Plan: “Minerals development will not be permitted unless adequate safeguards can be secured for the protection of the environment and the amenities of the area likely to be directly or indirectly affected during all phases of the development.”
  • The drilling fluid described in the application consists of bentonite clay. This is difficult to dispose of in an environmentally friendly manner.
  • This application will not provide new jobs in the local area. Nor would full-scale Coal Bed Methane production. UK Methane estimate that each well would provide 10-15 jobs. These would be temporary and short-lived, and many would be technical jobs that might not go to local people.

This application could be a stepping stone to full-scale Coal Bed Methane production, which would be unacceptable:

  • Very large numbers of wells need to be drilled to extract Coal Bed Methane, because each well does not yield much gas. In Queensland, Australia, over 3,000 wells have been drilled with projections of 40,000 to come. If CBM goes into full production here, there could be 2,100 wells across Somerset.
  • Policy GB.1 (iii) of the Local Plan states that: “within the Green Belt..permission will not be given, except in very special circumstances, for development other than…development and material changes of use of land which maintain the openness of the Green belt and do not conflict with the purposes of including land in it.” The huge number of wells that commercial Coal Bed Methane production would necessitate would clearly contradict this policy.
  • In Australia and the US where Coal Bed Methane is produced commercially, hydraulic fracturing is commonly used to extract the gas. Often fracking is necessary if a well is to produce enough gas for the project to be economically viable. Even if UK Methane say that they do not intend to use hydraulic fracturing, they could later sell their PEDL licenses in this area to another company, who might use fracking. If this planning application is approved, and large amounts of methane are discovered as a result of coal seam testing, it will be much easier for them to sell their licenses.
  • Fracking can contaminate groundwater with toxic chemicals. The process uses huge amounts of water mixed with toxic chemicals, a large fraction of which are never recovered. While the fracking fluid is underground it is in contact with rocks at high temperatures and pressures. This can result in toxic elements like arsenic leaching out of the rocks and being brought to the surface. Even more worryingly the fracking fluid can also leach radioactive elements out of the rocks causing radioactive contamination as well. The contamination of irrigation water means that everyone’s food supplies could potentially be affected. Both Duke University and the US Environmental Protection Agency have correlated gas in water with proximity to fracking sites.

Other points you might wish to raise:

Coal Bed Methane extraction could lead to runaway climate change. It is very carbon intensive, and has the additional problem that the methane extracted is a stronger greenhouse gas than the carbon dioxide emitted by burning it. Para E.5 of the Local Plan, in relation to environmental assets, states that an aim of the council is to: “conserve and reduce the consumption of non-renewable resources, including…fossil fuels.”

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