Our friends at Frack Free Ryedale have put together a fantastic & easy to follow guidance sheet explaining how concerned members of the public can object to Third Energy’s KM8 planning application;
Third Energy have applied to frack their existing KM8 well at the company’s Kirby Misperton well-site. You can view the application documents on the NYCC Online Planning Register – Application No: NY/2015/0233/ENV.
What have Third Energy applied to do?
The planning application consists of five separate phases:
1 Pre-stimulation Workover This is the preparation stage, where they get the existing KM8 well ready for fracking. Duration: 2 weeks (working 24 hours a day)
2 Hydraulic Fracture Stimulation/Well Test This is a ‘test-frac’, or ‘flow-test’, which involves fracking at five different depths to see if the Bowland Shale will produce gas in commercially viable quantities. Duration: 2 weeks (working 24 hours a day)
3 Production Test This will check gas flows over a longer period of time (up to 90 days), with the gas piped to Knapton Generating Station. Duration: 13 weeks (working 24 hours a day)
4 Production If the production test is successful, the KM8 well will be permanently hooked up to the existing production equipment and commercially produce gas. Duration: up to nine years.
5 Well Abandonment and Restoration When the well reaches the end of its life, it will be decommissioned and restored. Duration: 6 weeks
I thought they were only applying to do an eight-week test-frac, not nine years of production.
That’s an interesting point. You must have read Third Energy’s Residents’ Brochure or their Public Consultation Booklet, which were given to local residents earlier in the year – in which a nine-year production phase was never mentioned.
Hmm. That’s a bit odd. Is there anything else that’s different in the planning application?
One very big difference is that they claimed there would only be 266 HGV movements during the first eight weeks, but in the Planning Application there are actually 910 HGV movements, plus 600 LGV/car movements – making a total of 1,510 traffic movements in total.
You can read a fully referenced analysis of the traffic movements on our KM8 Traffic Movements page.
That’s quite a big difference. Third Energy don’t sound like very good neighbours.
You might say that, we couldn’t possibly comment. However, you might like to see our analysis of the differences between the consultation documents and the planning application on our Good Neighbours? page.
OK, so how can I object to this application?
You can either follow the guidelines on our website below, or download this guideline template letter, which includes the same information in a form you can easily customise and personalise.
When’s the deadline for objections?
The deadline for objections is TUESDAY 14th OCTOBER.
Better get on with it, then. How should I start my objection?
We suggest you begin by saying that you are writing to object to the application, and add a couple of sentences about yourself, e.g. where you live, what you do for a living, what your interest is in the application, why you are concerned, etc.
For example, If you live in one of the towns or villages near the KM8 well-site, you could say something about how worried you are about how this work will impact on your daily life.
If you live elsewhere in Ryedale or North Yorkshire, you can mention the wider effects of fracking would have on the region, particularly on its reputation as a top tourist destination and the effect extra traffic .
If you live in another part of the UK (or in another country) you can mention any connection you have with North Yorkshire – for example, you might visit the area regularly on holiday, or because you have family or friends in the area. If you think that fracking in Ryedale would make you less likely to visit the area on holiday, then you might want to mention that too.
OK. What are the key points I can include in the main body of my objection?
Here are some topics for your objection. You don’t need to mention them all – choose the topics that you feel most strongly about. And of course, please add any other comments of your own.
Please put these ideas into your own words if possible – the more personalised the objection, the more powerful it will be.
TRAFFIC The planning application states that there will be at least 910 HGV Movements and 600 LGV/car movements in the first eight weeks, making 1,510 traffic movements in total. (That’s compared to just 266 HGV movements promised in Third Energy’s Residents’ Brochure and Public Consultation Booklet.) This traffic will travel through Kirby Misperton village and along country roads, resulting in increased noise pollution, vibration damage to homes, air pollution from traffic fumes, damage to verges and pavements, etc. There is also a increased risk of traffic accidents, and children, pedestrians, cyclists and horse riders will be particularly vulnerable.
For more information and a map of the traffic route, go to our KM8 Traffic Movements page.
NOISE The levels of noise at the site during the first two stages will be very much higher than would normally occur in this quiet rural location (up to 90 dB on site – as loud as a nightclub). The noise will be very audible within the village, and excessive in nearby properties, caravan parks and camp sites, and will also carry across country for many miles in all directions (despite the ‘Noise Attenuation Barrier’ – basically a wall of shipping containers – that Third Energy propose to build around the well).
NIGHT-TIME DISTURBANCE Work will take place 24 hours a day for the first five months, and will be particularly noisy during the first two months, subjecting local residents to excessive and unreasonable disturbance. Work should not be allowed to take place at night in such a quiet, peaceful area. The use of bright lights during darkness hours will be intrusive and unacceptable to residents in what is an unlit area, particularly during the autumn/winter months.
VISUAL IMPACT The site is very visible from the public footpath that runs along the edge of the site. The shipping containers and drill rigs will be completely out of keeping in this landscape and, along with the high noise levels, will spoil the amenity, quiet use and enjoyment of the public use of the footpath.
EFFECT ON WILDLIFE There is a wide range of wildlife in the immediate area, including deer, newts, badgers, brown hares, barn owls and bats. Many of these are protected species All these species will be adversely affected by light pollution, noise and vibration. This disturbance to their habitat could lead to some species leaving the area permanently, which would affect the delicate ecological balance of the area. Vibration will impact adversely on certain species such as owls and other small mammals. Depending on the time of year, this can also cause problems with breeding and hibernation.
ACCIDENTS Toxic waste water containing NORM (Natural Occurring Radioactive Materials) and dangerous chemicals in concentrated form (such as sulphuric acid) will be transported through Kirby Misperton village and stored on-site. Any accident where a spillage occurs could be extremely damaging to the environment, and this presents an unacceptable risk to the local community.
GROUNDWATER POLLUTION RISKS If any fluids used for fracking, such as sulphuric acid, escape from the site they could contaminate the surrounding area and contaminate local farmland and groundwater. Pollutants could also enter the local water network via the site drainage system if there was a spill on the site. These pollutants could contaminate the local becks and rivers, killing fish and other aquatic species.
GROUNDWATER MONITORING The Baseline Water Monitoring Plan is not fit for purpose because the applicant does not intend to monitor the water for 12 months prior to fracking taking place. This is despite 12-month monitoring of methane in groundwater being a requirement under the Infrastructure Act 2015. Inadequate monitoring of fluctuating groundwater conditions will result in a lack of baseline data, which means the risk of pollution to water, the environment and public health cannot be correctly monitored and assessed.
AIR POLLUTION RISKS The exhaust emissions from HGV traffic, diesel generators and compressors will create increased air pollution near the site. These will expose local people (and workers at the site) to substances that are harmful to health and increase their risk of developing serious health problems in the future. There is also a significant health risk due from silicosis due to the large quantities of sand used in the fracking process.
CUMULATIVE IMPACT There are already several gas wells in the area, including three on the Kirby Misperton site, and fracking would have a negative cumulative impact on what is a rural and peaceful area. Third Energy have already been given permission to produce gas at Ebberston Moor, which will involve extra traffic and other disruption involved in the pipeline construction, and are applying to expand their operations in nearby Pickering. From a wider perspective, expansion of the gas industry is changing the character of the area and resulting in the industrialisation of the Vale of Pickering, which will affect the tourist industry in the region.
PRODUCTION PHASE There is very little detail in the planning application about the Production phase, which is due to last nine years or more. It is extremely unlikely that a small test frac will be able to release enough gas to produce commercially viable quantities of gas for nine months, let alone nine years, so the company will probably need to re-frack the well a number of times to continue production. However, there is nothing in the planning application about this phase.
Third Energy also say in its Public Consultation Brochure that they have a longer term development plan which “will require three or four more wells – probably a combination of our existing and new well-sites. We will need to drill lateral wells and hydraulically fracture the Bowland section.”
The applicant must be asked to provide extensive details of this production phase and clarify its long-term plans for the wellsite, including how many new wells are to be drilled and an estimate of how much fracking would be required, before this application can be considered.
(There is more information on this point on our Good Neighbours? page.)
JOBS AND TOURISM The application does not create a single new job for local people, but if fracking is allowed in Ryedale, it will threaten the jobs of thousands of people in the key local industries of tourism and agriculture. People will be less likely to come and visit the area if they feel that the peace and quiet will be compromised by fracking wells, their health is threatened, or that they will have to cope with large increases in HGV traffic. This is confirmed in the Draft DEFRA Report “Shale Gas Rural Economy Impacts Paper”, which says: Fracking “may reduce the number of visitors and tourists in the rural area, with an associated reduction in spend in the local tourism economy.”
EFFECT ON OTHER KEY RURAL ECONOMY INDUSTRIES It is clear that fracking will have a negative effect on other key industries in Ryedale, threatening thousands of people’s jobs and livelihoods. This is confirmed in the government’s Draft DEFRA Report “Shale Gas Rural Economy Impacts Paper”, which says “Shale gas may transform a previously pristine and quiet natural region, bringing increased industrialisation. As a result, rural economy business that rely on clean air, land and water and/or a tranquil environment may suffer losses from this change, such as agriculture, tourism, organic farming, hunting, fishing and outdoor recreation.”
EFFECT ON HOUSE PRICES The Draft DEFRA Shale Gas Rural Economy Impacts Paper states that “House prices in close proximity to the drilling operations are likely to fall. There could be a 7% reduction in property values within one mile of an extraction site.” and “Properties located within a 1-5 mile radius of the fracking operation may also incur an additional cost of insurance to cover losses in case of explosion on the site.” Who will compensate local residents for these losses?
PRECEDENT – If this application is approved, it may be harder for the Council to reject future fracking applications as a precedent will have been set. This could result in hundreds of fracking wells across Ryedale and North Yorkshire. Third Energy stated on 10th March that they were planning to establish 19 well-sites across Ryedale, with between 10 and 50 wells per site – and now there are PEDL licences across the whole of North Yorkshire. Allowing fracking at Kirby Misperton could open the door to this damaging and destructive industry across the rest of Yorkshire and other parts of the UK.
CLIMATE CHANGE The UK urgently needs to reduce our CO2 emissions to combat climate change, and starting a new fracking industry will lock us into using fossil fuels for decades to come, and also delay the move to clean renewable energy. The Council has a responsibility to take climate change into account when ruling on planning applications.
It’s worth noting that the gas generated from this application will not be used as gas to heat people’s homes, but will be sent to Knapton Generating Station to produce electricity. There are other, greener, cleaner ways to generate electricity that will not cause climate change.
If there are other fracking-related issues you want to mention, then please do so. The more personalised your objection is, the more powerful it will be.
And at the end of your objection, please remember to ask the County Council to reject the application.
OK, that’s done. Where do I send it?
Emails should be sent to the following email address: email@example.com
Please put the application number in the subject line: NY/2015/0233/ENV
You can write your objection in the body of the email, or attach it as a Word document.
You can also object by post. Please send your letter to the following address:
Planning Services, County Hall, Racecourse Lane, Northallerton, DL7 8AH.
Please put the application number in body of the letter: NY/2015/0233/ENV
DO include your surname, first name/initials and address (anonymous comments are not considered)
DO NOT include your signature, phone number or any other information you don’t want to make public.
Note that objections from groups are usually posted on the NYCC Online Planning Register, but those from individuals and businesses are not. If you would like your comments to be included on the Planning Register, please include this request in your objection. You can also ask for your name, address and other personal information to be removed before they post it on the website.
Anything else I can do to help?
Third Energy are 97% owned by Barclays Bank. Please email Barclays Chairman John McFarlane to ask him to divest from fracking by going to this Friends of the Earth action page. If you can personalise the email, it will have more impact.
We are also raising money to hire expert consultants to fight the application. Please donate via our KM8 fighting fund page.
And if you haven’t heard about the 14th round of PEDL Licences, which will open up most of Yorkshire, Lancashire and many other parts of the country to potential fracking, then check out our PEDL Licences page.
Finally, please share this page on Facebook and Twitter using the links below.
IT ALL STARTS WITH JUST ONE WELL …