Downholland Parish Council
In respect to Planning ALCC/2019/0037 Altar Moss Wellsite, Suttons Lane, Great Altcar, Lancashire:
We have had many strong representations from local residents who wish their voices to be heard and for their concerns to be taken seriously, there is a feeling of powerlessness and also anger that this is being imposed upon us by far off central government.
We therefore wish to relay the following observations, comments and representations.
The Parish Council strongly feel that the application should be
refused.
1. Inappropriate
Development in Greenbelt
Whilst the National Planning Policy Framework states at para.146 that ‘certain other forms of development are also not inappropriate in the Green Belt’ and includes both mineral extraction and engineering operations ‘provided they preserve its openness’, it does not state explicitly that buildings associated with these uses could be considered to represent appropriate development.
The proposal includes:
A 37m high work over rig
30m Coil Tower + Injector Goose Neck
13m high silos
18m high lighting towers
12m high structure supporting gas flare
3m high steel fence
Electrician’s and Mechanic’s Workshop
Multiple 80m3 Storage Tanks
Offices
Car Parking
These are clearly substantial buildings and constructions,
and not merely engineering operations. They should therefore be considered to
represent inappropriate development in the Green Belt.
2. Failure to qualify “need”
Inappropriate development in the Green Belt can only be justified by
reference to Very Special Circumstances – usually understood to be a need
for the development. In this case, we
say that there is no such need.
Para.2.4 of the Environmental Statement presents the proposal as an opportunity rather than as a necessity. The 2013 study by the British Geological Survey suggested that ‘potentially significant’ gas resources existed in Northern England. However, these are not quantified, and it is not clear or proven how far this small area of proposed exploration might contribute to a ‘significant’, and usable, resource. The application suggests the prospect of oil as well as gas: but oil appears not to have been considered by the BGS study.
3. Failure
to preserve openness.
The application does not meet the requirement to ‘preserve openness’ of
the Green Belt.
3.1 The
openness of the location
The location consists of Grade 1 Agricultural Land in a large area of flat
coastal plain and is open for many miles around
http://publications.naturalengland.org.uk/publication/144015?category=5954148537204736
Lancashire County Council’s Character Assessment study, part
of “A Landscape strategy for Lancashire”, describes the location as being
“characterised by the flat or gently undulating farmland of the Coastal Plain”.
https://www.lancashire.gov.uk/media/152746/characterassesment.pdf
(indeed photograph number 1 in the above publication is of
this area)
It is described in the documents accompanying the application as “flat open
landscape” (pt5 in the “Non-Technical Overview” document).
3.2 Impact on Openness
The application contains the admission that “The proposed
development would be visible from a relatively wide area, particular during the
drilling phases” (pt5 in the “Non-Technical Overview” document).
We feel that the following aspects of the development do not “preserve the openness”,
including, but not limited to:
- A 12m high ground gas flare in the 24hr a day working phase of the development.
- 13m High Silos
- A 37m workover rig
- 18m lighting towers
- A 5m wide X 815m wide road
- A 3m Steel Fence
- 100+ daily journeys with over 50% being Heavy Goods Vehicles.
3.3 Response to openness mitigation statement
In regards, to the statement that “The flat open landscape is interrupted in places by frequent transmission line towers”.
The pylons have been part of the landscape for more than 40 years, were justified by government upon the reasoning that they delivered a direct local benefit, they are largely framework structures and are not visible at night
3.4 Response to the mitigation that Hillhouse Waste Water Treatment wind turbines are tall structures that are visible above the skyline.
Justification for the wind farm developments cited ministerial statements by The Secretary of State for Energy and Climate Change (Amber Rudd) in June 2015 and argued that the impact on the landscape needs weighing against the aims of cutting carbon emissions and renewable energy.
In both the above points special dispensation was argued at the time of planning, weighing the public benefit against the impact on the landscape. It does not follow that their presence alone is justification for further developments.
4. Other Forms of Harm
In addition
to the harm to the Green Belt, the proposed development would bring about other
forms of harm. The Applicant must
demonstrate that the need for the development would be sufficient to outweigh
not only the harm to the Green Belt, but also the other forms of harm.
4.1 Harm
We consider that the proposed development has the potential to cause harm in a number of other ways, including but not limited to
- Potential for contamination of groundwater sources.
- Potential for harmful impact on wildlife and habitat and effect on Grade One Agricultural Land
- Increased wear and tear of traffic on rural roads
- Flood risk
- Noise pollution
- Seismic activity
5. Inadequate benefit given level of harm and risk
We feel that the potential long-term harm far outweighs the unproven “need” and benefit of this exploratory exercise.
5.1 Potential for contamination of groundwater sources. The lack of detailed adequate safeguards in the application and lack of experience of the applicant in undertakings of this nature are at odds with the “Precautionary Principle” and “Risk Based Approach” of the Environment Agencies Groundwater Protection.
5.2 Potential for harmful impact on wildlife and habitat,
and effect on Agricultural Land.
The adjacent Downholland Moss is a Site Special Scientific Interest
https://data.gov.uk/dataset/5b632bd7-9838-4ef2-9101-ea9384421b0d/sites-of-special-scientific-interest-england
The location consists of Grade 1 Agricultural Land http://publications.naturalengland.org.uk/publication/144015?category=5954148537204736
The
application fails to adequately address the potential of harm due to a failure
of the protection measures in place, taking one example of the “formation
integrity tests” that the application states will “confirm that a good cement
seal exists” (p42) but does not detail any actions that would be undertaken as
a result of a failure. There is no evidence of contingency, clean-up plans or
mitigation of harm procedures in the event of a failure.
We would agree with the statement that “A failure to meet the above criteria
requires a further, more detailed, consideration of ecological impact” (p84)
The claim that “planning for major accidents and disasters has been undertaken”
is not qualified and no evidence provided.
6. Response to mitigation that the works are
temporary.
We do not feel that the site being “temporary” is adequate mitigation to
these issues and risks given the length of the proposed works.
While we understand that consideration of the application is limited to this development
only, its stated purpose of being “exploratory drilling” would imply that the impact
will be far from temporary.
