Advice on grounds of complaint to test drilling applications

There are numerous difficulties in fighting test drilling applications, which will not involve fracking. The planning regime as it stands does not currently give much scope to consider the bigger indirect picture and the follow on consequences of what might be seen as a relatively benign test drilling application. Nonetheless, it is vital to muster as much opposition as possible, as early as possible, so that we can make life as difficult as possible for the planners and the applicants and thereby build momentum and pressure for the nationwide moratorium that should be our ultimate goal.The two principle issues that fall within the existing planning framework that apply to a purely test drilling application are:

NOISE ISSUE –
This is an obvious ground for opposition, but one fraught with difficulties. Turn these difficulties to our advantage.

The advertised noise from the drilling equipment is not really the key issue. The stated 74dB, by CO&G, is noisy enough. The issue is how well controlled the noise is and environmental factors such as prevailing winds, surrounding topography and land use etc. The reality is that no-one can really predict exactly what the impacts will be. We can all conjure lies, damned lies and statistics when it comes to noise surveys before the event.

With background noise measured at c.20 dB, the noise predicted from the drills (by the CO&G commissioned survey) at the key properties has been contrived, by the assumptions underpinning the survey, to look acceptable. It is a best-case scenario. We could make a case for changing most of the assumptions and generate a worst case scenario in riposte.

My tack with the planners would be to emphasise that the assumptions made in any analysis are unlikely to match the reality on a consistent basis and that you want assurances that the drillers will be forced to take whatever remedial action may be necessary to eliminate any noise nuisance should it occur at any point during operations. This ought to be a perfectly reasonable condition for the planners to impose. It would probably be a fairly worrying one to the drillers, however, as they would have to take expensive precautions and face the fairly catastrophic (from their perspective) prospect of a shutdown if it were breached.

Noise nuisance should include secondary noise as well as the primary noise from the drill itself.

Related to noise is possible vibration issues that could be a significant impact to adjacent properties in particular. Again, this is extremely hard to predict, but it is entirely possible that resonances could occur within neighbouring properties that could generate secondary noise nuisance within the buildings, as well as issues from vibration disturbing people and equipment.

Another secondary noise impact could be from impacts on animals, such as the nearby dog kennels in the Llandow case. Noise surveys only generally consider the frequencies audible to humans. This sort of drilling could well generate frequencies that disturb animals – who could then disturb humans.

TRAFFIC ISSUE –
Again, there is a best and worst case scenario to be considered. Stress your opposition on the grounds of additional HGV traffic generated by the construction (heavy equipment) and drilling phases (water tankers) in terms of road safety, noise and damage to properties, accident potential, existing local traffic problems. Insist that, if approved, strict conditions be placed on permissible routes (this has been imposed in Bridgend) and times of movements.

OTHER RELEVANT ISSUES –
Potential inadvertent release of methane into water supplies – they are drilling into gas bearing rocks even if not commercially extracting it at this stage.
Use of scarce water supplies – where is it being taken from?
What is to happen to the polluted produced water from the drilling?
The myth of any local employment from this – Bridgend based CO&G sub-contact drilling work to a Sunderland based company (Drillcorp) that supplies the drilling equipment and hires its own labour (from places like Liverpool in the case of one operation in Bridgend).

COMPETENCY OF THE PLANNING AUTHORITY – If the Leader of the Vale Council, Coun Gordon Kemp, acknowledges that the whole issue is beyond the scope of the planning system, then how can a decision by his own Planning Department (or indeed any Local Authority planning department) have any credibility?
See second half of this: http://www.bbc.co.uk/news/uk-wales-13983360 and
http://www.walesonline.co.uk/cardiffonline/cardiff-news/2011/06/15/calls-for-welsh-government-to-take-control-of-south-wales-gas-reserves-91466-28880099/#ixzz1PMlQpIqG

I hope this is helpful.

Andy Chyba

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