The case against fracking in West Sussex

Here is my response to the public consultation on the draft West Sussex Joint Minerals Local Plan.

B3. If you consider the West Sussex Joint Minerals Local Plan to be unsound and/or not legally compliant, please explain why in detail in the box below. Please be as precise as possible.
    I am dismayed at the County Council's intention to permit hydraulic fracturing in West Sussex and shocked at the apparent ignorance of the gravity of the dangers this would pose. The people of West Sussex ought to be able to depend upon the Council to protect our interests, our environment and our health - Policies M7a and M7b are a gross betrayal.
    I note with distaste the cynical reclassification of operations that plainly involve fracking to make it appear that they do not. For example, setting a fluid volume threshold and removing certain geologies from the 'unconventional' category. These are deliberate attempts to mislead and I imagine this was done at the behest of oil and gas industry lobbyists.
    Fracking is inherently dangerous - there is NO SAFE WAY to do it, as those states which have permitted it are now discovering to their great cost. Here's a non-exhaustive list of highly deleterious consequences:

- Chronic human and animal health complaints resulting from constant exposure to toxins and carcinogens such as methane, benzene, methanol, mercury, ethylene glycol, radon, lead, cadmium, silicon and other fracking by-products in the air, the water and the soil.
- Aquifers polluted with fracking chemicals and by-products, rendering the water undrinkable.
- Constant noise and exhaust pollution from heavy vehicles and plant, compressors, gas flaring.
- Animals and plants dying off because the air and soil have been poisoned.
- Damage to property from dramatically increased seismic activity even in hitherto stable geology.
- Billions of gallons of precious fresh water irreplaceably lost from the hydrological cycle.
- Landscapes scarred with vast networks of thousands of pads and service tracks.
- Legal injunctions served on people thus affected, to prevent the truth becoming widespread knowledge.
- Much else besides - a web search for 'fracking dangers' will yield hundreds of hits.

West Sussex Joint Minerals Local Plan, Policies M7a and M7b are unsound on the following grounds:
- Does not apply the well-established Precautionary Principle concerning potential risks to human health and the environment.
- No provision for Human Health Impact Assessment.
- No provision for Environmental Risk Assessment.
- No provision for environmental baselines and subsequent monitoring of biodiversity indices and pollutant levels.
- No definition of unacceptable impact.
- No recognition of the particular difficulties posed by the highly faulted geology of the Sussex Weald.
- No analysis of transport infrastructure, requirements, capacity and impact.
- No assessment of whether the county has the capacity to supply the necessary volume of fresh water without negatively impacting its availability to other vital usages such as agriculture.
- No provision for treatment of the extremely large quantities of polluted 'flow-back water'. Indeed, according to the Environment Agency, no suitable facilities for treating waste exist at all in Southern England.
- Burning fossil fuels is not sustainable and fracking for natural gas is far worse, releasing as it does large quantities of methane, a greenhouse gas many times more potent than carbon dioxide.
- No evidence presented to support the assertion that lateral drilling and fracking beneath the SDNP and AONBs could be conducted without unacceptable consequences.
- No provision for protection of Dark Night Skies designated areas from the effects of 24 hour drilling, flaring, compressing operations.

Please, please, listen to the residents of areas of the world where fracking has occurred and learn about the health and environmental catastrophes they have suffered. Watch 'Voices from the Gasfields', which documents fracking in Queensland, Australia. Search the Internet.

B5. Please explain in the box below what change(s) you consider necessary to make the West Sussex Joint Minerals Plan legally compliant and/or sound. Please be as precise as possible.

Most people, when fully informed about the risks, would not wish fracking to occur anywhere in the United Kingdom. I certainly feel that way about West Sussex and strongly urge the County Council to reverse its decision and ban fracking altogether.

Failing an outright ban, to mitigate the worst shortcomings of the draft WSJMP and before granting any further licences, the following changes are necessary:

- Require a Health Impact Assessment (HIA). There are 750 peer reviewed studies pointing to detrimental health impacts.
- Require an Environmental Risk Assessment (ERA).
- Require full baseline indices of methane and other possible contaminants in air, water and soil, together with independent monitoring of levels in relevant locations after each phase of the oil/gas exploration-extraction-recovery life cycle. This industry cannot be trusted to self-monitor or police itself.
- Require independent and ongoing inspection of well integrity.
- Identify whether and how waste water is to be treated and assess whether it is even possible to do this economically. The danger, of course, is that the waste will be illegally disposed of if the costs are prohibitive, with further potential for environmental calamities.
- Provide for licences to be rescinded if conditions are breached.
- The policies must mandate restoration and aftercare including ongoing continuous monitoring.
- Licensees should be required to deposit a bond against liabilities, as insurance against their possible insolvency or to cover the costs of rectifying spills, leaks and other eventualities.

Your response has been submitted
Thank you for providing a representation on the Proposed Submission Draft West Sussex Joint Minerals Local Plan.

The Proposed Submission Draft Plan was published prior to its submission to the Secretary of State to allow for representations on the Plan’s 'soundness' and legal compliance to be made. After the representations period closes on 13 March 2017 representations will be collated and reviewed. The Authorities are preparing to submit the Plan, alongside the supporting evidence base and representations, to the Secretary of State. If any representations include matters which suggest changes to the Plan the partner authorities will consider the appropriate way to proceed before the Plan is submitted.

The Plan is expected to be heard at an examination between July and October 2017 in line with the West Sussex Minerals and Waste Development Scheme. If the document is considered ‘sound’ by the Inspector it is anticipated that the Authorities will adopt the Plan in May 2018.

For further information about the Plan please visit: www.westsussex.gov.uk/mwdf

I urge you to watch Voices from the Gasfields, which documents fracking in Queensland, Australia. Visit the Frack Free Sussex website. Search the Internet.