manchester foe logo

Manchester Friends of the Earth submission to Planning Application for Coal Bed Methane operation at Davyhulme

81446/RENEWAL/2013: Land adj to M60 High Level Bridge & Davyhulme WWTW & to south of Trafford Soccer Dome, Urmston

[Page 3: A further letter has been received from Friends of the Earth raising the following concerns: –

1. Environmental Impact Assessment (EIA) If the well is likely to produce more than 500,000 cubic metre of gas per day, EIA would be mandatory. No estimate of the volume of gas expected to be produced is set out in the Committee report.

There is considerable uncertainty in the report regarding the scope and impact of the proposed activities e.g. the reference to “further drilling”. It is well established in case law that insufficient information may fundamentally undermine the effectiveness of screening for EIA.

2. Climate Change The applicant has removed the proposal for CHP, which is contrary to the Council’s policy, SPD1, Climate Change. There is no certainty that CBM will displace imported gas. There is no comparison of the proposed fossil fuel (coalbed methane) extraction to renewable energy or other more sustainable forms of gas (e.g. biogas). It is also unclear whether the carbon emissions assessment includes the contribution from venting and flaring.

3. Inadequate Information The Health and Safety Executive notes that “there is little in the way of information to show compliance with UK legislation for Health and Safety for the design and construction of a borehole”. Borehole design and construction is fundamental to the mitigation of many environmental impacts. It is therefore very important for the Council to be satisfied that the borehole will be designed and constructed to comply with legislation before granting planning permission. It is not clear that the Council knows what chemicals will be used in the drilling process nor whether they will be hazardous. Paragraph 52 of the officer’s report suggests that the control of the site is solely the responsibility of the Environment Agency (EA) rather than through the attachment of planning conditions. In terms of contamination, there is no condition requiring an impermeable membrane and bunding to protect the surface from spillage. There is no evidence in the report to substantiate the claim that the development will make a substantial input into the local economy.

4. Groundwater Despite the fact that the borehole passes through a principal aquifer, the hydrology of the site and the likely impacts on groundwater are not addressed. No application for a groundwater permit has been submitted to the EA. The assumption in the report that other regulatory processes will ensure impacts on groundwater are managed is therefore premature.

5. Venting and Flaring The report also relies unduly on other regulatory processes in respect of venting and flaring. It is not clear that the applicant has provided any detailed assessment of this aspect of the proposals and therefore that the Council can conclude that this is likely to comply with requirements.

6. Lack of Conditions There is no condition to control noise, which is likely to be a significant impact, or drill depth bearing in mind that at Barton Moss drilling took place down to the shale level.

7. Air Quality The report concludes that impacts on air quality will be negligible but the EU Air Quality Directive sets out a duty to ensure that emissions are met “throughout their zones”. The judgement of the Supreme Court in the case of R (on the application of Client Earth) v Secretary of State for the Environment, Food and Rural Affairs (April 2015) held that exceedances of emissions limits must be reversed “as shortly as possible”. It is not clear how the development will comply with this.

Full Trafford Council Planning report available (pdf)

Find us on

Facebook

Support Us

Donate or join us using a standing order or PayPal.

Twitter @foemcr