NOTES FOR A LETTER OF OBJECTION TO THE MARKWELLS WOOD
UKOG APPLICATION FOR THE PRODUCTION OF OIL
Application No: SDNP/16/04679/CM
Location: Markwells Wood-1 Well Site, South Holt Farm, Dean Lane End, Forestside, Rowlands Castle, West Sussex.
Proposal: Appraisal and production of oil incorporating the drilling of one side track well from the existing well (for appraisal), three new hydrocarbon wells and one water injection well, and to allow the production of hydrocarbons from all four wells for a 20 year period.
WRITING A LETTER OF OBJECTION
- Please make it clear in your letter, in the first sentence, that
- you wish to object to the application. You are welcome to use any of the arguments and information given above in your letter.
- Please use your own words as much as possible. A ‘cut and paste’ exercise can end up being ignored.
- Please avoid highly emotional statements. They will be disregarded or, at worst, could be counter-productive.
- Your letter can be sent by email to the South Downs National Park Authority (email@example.com) – quoting the planning number, location and proposal, all at the head of these notes).
- Alternatively you can send a letter by post to: South Downs National Park Authority, South Downs Centre, North Street, Midhurst, West Sussex, GU29 9DH.
- Use a clearly typed and signed closure and ask to be kept informed by the Case Officer.
- SPECIAL PROTECTION FOR THE SOUTH DOWNS NATIONAL PARK
Core purposes of the South Downs National Park:
- To conserve and enhance the natural beauty, wildlife and cultural heritage of the area”.
- To promote opportunities for the understanding and enjoyment of the special qualities of the Park by the public.
- This application conflicts with the core purposes of the National Park
- The enjoyment of the South Downs National Park includes leisure activities such as walking, cycling, horse-riding and bird-watching. These would be limited by the development
- In a National Park, developers are obliged to show that exceptional circumstances for the proposal exist and that the proposal is in the public interest. The applicants have failed to do so.
- In our opinion they must consider other sites outside the National Park. In our opinion they have not done so.
- If oil development were allowed at Markwells Wood, this would set a dangerous precedent for further oil extraction in the Park.
- The increase in Heavy Goods Vehicle (HGV) movements would be detrimental to the first core purpose of the National Park.
- Increases in HGV traffic would pose risks to walkers, cyclists and horse riders who use this road frequently for recreation. Noise related to traffic would cause disturbance to leisure users.
- There are many livery stables and private horse owners close to the site and along the routes to the sites. They are part of the local economy and would be disturbed and / or at personal risk from an increase in traffic.
- The proposed traffic route to connect the site to the A3(M) at Horndean (Emsworth Common Road, the B2148 to Whichers Gate and then north) presents several traffic hazards. The B2148 carries a 7-ton weight limit and contains a ‘blind’ hump-back bridge.
- The rural roads in this area make this an unsuitable site.
- Landscapes and Visual Impact
- During drilling there would be adverse visual impact from several viewpoints both locally and on the South Downs (eg: 37m high drill rig visible).
- Lighting would be used throughout the night during the well testing and production phases. This would have an adverse effect on the residents of Forestside.
- The scheme would have adverse impacts on the landscape and would affect views from public rights of way. This is incompatible with the purposes of the National Park.
- Water and groundwater
- The groundwater from this area flows in a south-westerly direction towards a number of Springs. Portsmouth Water relies on these Springs to supply hundreds of thousands of homes and businesses in the Portsmouth area with water.
- Drilling would go through the freshwater aquifers. This is recognised as one of the most difficult parts of the drilling process. We have concerns about the reliability and longevity of the well casings.
- UKOG admits that “potentially contaminative” chemicals will be stored and used on site. There is risk of spillage and this could affect surface water and ground water.
- The injection well would be used to return large quantities of water, separated from oil, to the strata below ground. This poses risks of pollution and of water migrating in unexpected ways because of the naturally faulted geology.
- Should the water in the aquifers become contaminated by any of these processes the impact on the environment could be long-term or even irreversible.
- The risks of contamination of the water supply from an acid, chemical or oil spillage, however small, are unacceptable.
- There is inadequate information in the application about water use and impacts on water, particularly in terms of transport, extraction, pollution and potential leakage from the site.
- A full hydrogeological survey has not been carried out on the site. This should form part of the public consultation.
- Drilling and extracting oil
- The methods proposed to extract this hard-to-get oil (known as ‘tight oil’) are described as ‘new and innovative’ and is widely considered to be unconventional.
- The company wishes to drill horizontally but insufficient information about this activity is supplied.
- The proposal includes the use of acids and other chemicals which may pose significant risks to the environment. We would like to see a full disclosure of the chemicals used.
- Acidising may involve more chemicals than hydrological fracturing. Our geology is naturally fractured and there is concern than chemicals could migrate into the aquifer either through the drilling process, spillage, oil extraction and the reinjection well.
- If an accident or spillage were to occur, who would pay and what would be the impact on the environment?
- UKOG has not conducted a 3D geological survey and therefore has neglected to prove there are no risks in relation to drilling the proposed wells.
- The National Planning Policy Framework requires local planning authorities to ensure that mineral development does not cause any unacceptable adverse impacts on the natural environment and on human health.
- A report for the European Commission on unconventional fossil fuel extraction identified water contamination, water resource depletion, air pollution, biodiversity impacts, and noise, as high risk concerns.
- Noise & Vibration
- It is unacceptable to have industrial drilling rigs working 24/7 in an area that is currently tranquil and rural. This is not in keeping with the village, nor with the National Park status that it enjoys.
- Wildlife, nature conservation and heritage impacts
- The impacts on wildlife and conservation are in conflict with the first core purpose of the National Park.
- Disturbance to habitats would be likely as would adverse effects on bats due to light spill, noise and vibration. Three rare species have been identified flying in Markwells Wood.
- Drilling is likely to disturb badgers.
- The vibrations will affect reptiles and disturb birds. They would also affect invertebrates which are a vital part of the food chain for these animals.
- There are three Grade 2 listed buildings between 590m and 720m from the site and Stansted Park is 850m to the south. One of these buildings in particular will suffer negative visual impact from the drilling rig and noise from traffic using the access track to the site.
- This proposed development would detract from “the natural beauty, wildlife and cultural heritage of the area” and is therefore at odds with the first core purpose of the National Park.
- Air Quality
- The application contains inadequate information about air quality impacts, in particular fugitive methane emissions, and the risks are therefore unknown.
- Climate Change
- The extraction and use of oil will make it much harder to meet our legally-binding climate change targets.
- The South Downs National Park Authority has an important role to play in tackling climate change and National Planning Guidance affirms that climate change is a core principle.
The deadline for objections is Monday 31st October 2016.
NB: These suggestions have been written by members of Markwells Wood Watch. We have made every effort to be as accurate as possible.