“Submission to the Petitions Committee of the National Assembly for Wales in response to the Welsh Governments response to the Fracking Petition”

It underlines the points both Gareth Clubb (FOTEC) and I made at the Llandow Public Inquiry, as well as before and since.

It also serves to underline the complete absence of any meaningful response to the issue from Welsh Labour, and Carwyn Jones in particular.

Full document: http://www.senedd.assemblywales.org/documents/s11946/23.11.12%20Correspondence%20-%20Additional%20information%20from%20Petitioner%20to%20Chair.pdf

Summary

1. Friends of the Earth Cymru considers the Welsh Governments response to be deficient and urges the Committee to call for further evidence on this matter.

2. Current planning policy encompasses fracking within a generic minerals planning policy which has been based on the experience of processes for conventional gas extraction. It consequently fails to acknowledge the need for a more cautionary approach to the issues raised by the new processes involved in fracking. The major issues associated with fracking are the current scientific uncertainty as to its impacts; known impacts in relation to climate change; and potential impacts on groundwater. Current policy makes no provision for addressing or considering those issues.

3. Welsh planning policy demands that sound science be used responsibly, which in this context entails a precautionary approach. Policy also demands that fracking be specifically acknowledged as a source of greenhouse gas production (and is a process which therefore runs counter to policy seeking to mitigate climate change). A new policy, or an addendum to Planning Policy Wales (PPW), is the appropriate means of dealing with the specific issues arising from fracking.

4. In view of the urgent need to mitigate climate change, Friends of the Earth Cymru has proposed an additional planning policy that provides for a sound precautionary approach to decision-making:

Planning permission for fracking or shale gas operations (including test drilling and extraction) will not be granted unless

A)

the planning authority is satisfied that all reasonable scientific doubt that there is any risk of adverse impacts including groundwater contamination has been eliminated B)

the proposal will not compromise the planning authoritys duties in relation to climate change mitigation and adaptation; and C)

the proposal is environmentally acceptable, or it can be made so by planning conditions or obligations. 5. In the short term we recommend the Welsh Government adopt a moratorium on fracking until sufficient information is available to determine with a high degree of certainty the likely impacts of fracking on the environment.

6. In addition, the Environmental Impact Assessment Regulations (England and Wales) 1999 should be amended to include the requirement for a full EIA to be conducted for each fracking application. Fracking operations exempt themselves by ensuring they have a surface operation smaller than the 1 ha limit (ordinarily they are 0.99 ha) that would make them subject to these Regulations.