Ebberston Moor South – late objections are still valid

PLEASE SEND YOUR OBJECTIONS TO THE NYMNPA and the NYCC AS SOON AS POSSIBLE.

THE OFFICIAL DEADLINE HAS PASSED, BUT LATE OBJECTIONS ARRIVING BEFORE 8th NOVEMBER WILL ALSO  BE CONSIDERED.

We have been told by the North York Moors Planning Officer that objection received before 8th November should still be included in the report that is sent out to the Planning Committee, and any objections after that date will be precied and reported on the day of committee. So, if you haven’t done your objection yet, there is still time!

You can also read Frack Free Ryedale’s objection and the indpendent hydrogeologist’s report that we have commissioned here.

General guidelines for your objections

You can register your objections as a private individual, or as a representative of a business, charity, school, local group or any other organisation. Please don’t submit objections on behalf of Frack Free Ryedale, as we have submitted our own detailed document separately.

The quickest way to do this is to download these letter templates, then complete them and email them to the email address shown below. PLEASE PUT THE REFERENCE NUMBER IN THE SUBJECT LINE.

NORTH YORK MOORS NATIONAL PARK AUTHORITY – LETTER TEMPLATE

Ref: NYM/2014/0587/EIA  – send to m.hill@northyorkmoors.org.uk

NORTH YORKSHIRE COUNTY COUNCIL – LETTER TEMPLATE

Ref: NY/2014/0275/ENV – send to alan.goforth@northyorks.gov.uk

SENDING BY POST

We have also included the same information below, in case you want to do your own handwritten letter, or object by email or on the planning department’s website. Note that both these options are only available for the North York Moors National Park Authority and the North Yorkshire Planning Authority. (The Environment Agency requires a written letter to be posted to them.)

THE NORTH YORK MOORS NATIONAL PARK AUTHORITY (NYMNPA)

The planning department of the NYMNPA will decide on the section of the planning application that lies within the North York Moors National Park, in particular the Ebberston South drilling site and re-injection well.

To make your objection, please write to: Director of Planning, Planning Department, North York Moors National Park Authority, The Old Vicarage, Bondgate, Helmsley, YO62 5BP.

You can email the objection to this address: planning@northyorkmoors.org.uk

Please quote the planning application reference NYM/2014/0587/EIA on all correspondence.

You can also make objections on their website. If you use this method, please don’t write ‘Frack Free Ryedale’ in the organisation box in the online form, as we have submitted our own detailed document separately.

Don’t forget to include your full name, organisation name (if applicable), address and postcode on your objection. If you are from outside the North Yorkshire area, please state why this is of particular interest to you, for example, you often visit the National Park as a tourist, you have family in the area, etc.

Here are some points you might wish to make in your objection. Please use your own words if possible and feel free to change the order of the points, or add ones of your own.

Waste water re-injection wells

The application includes a plan to re-inject over 10 million cubic metres of radioactive waste water into the ground without any on-site treatment. Reasons you may wish to object to this are as follows (note that these are the same as the points listed above for the Environment Agency, but it’s important that you make these points to the NYMNPA too):

• the proposed re-injection wells pass through aquifers that supply local drinking water. If and when the well casings fail – and all wells fail eventually – radioactive waste water could pass into the water supply.
• Ebberston South is located within various protection zones of the Corallian Limestone aquifer, and Yorkshire Water have already stated that the re-injection wells might ‘directly affect their asset’.
• Third Energy’s claim that re-injection is the Best Available Technology is driven by financial considerations, not because it is the best available environmental option. Detailed comparisons, both practical and financial, with other alternative disposal methods are not included in the application, and the re-injection option seems to have been chosen on the basis that it maximises profitability for the company.
• There is no proposed treatment process for the waste water before it is re-injected into the ground, which again does not constitute the best available environmental option.
• Studies in the USA indicate that waste water re-injection is a major cause of seismic activity, and is thought to be responsible for an exponential increase of earthquakes in Oklahoma (In 2007 there were only two per year, whereas there have already been 253 in 2014).
• The North York Moors National Park should not be used as a testing ground for potentially dangerous new procedures, particularly if there is any chance these might cause water pollution or earthquakes in the area.
• Third Energy’s proposals are based on a conceptual model using third party information and water analysis from Kirby Misperton, which is 9 miles away and from Ebberston B, which is nearly 3 miles away. No recent geological or water testing has been carried out at the Ebberston South site in order to assess the risks of produced water disposal.
• Third Energy cannot be 100% certain that waste water won’t travel into nearby aquifers over time, particularly after such a huge amount of water has been injected into the Sherwood Sandstone layer under pressure.
• The company’s argument that ‘the natural geology controls risk’ is unproven.  Third Energy’s consultants, Barton Willimore, state that ‘drilling in the Ebberston area is more difficult than in many other areas due to faulting and associated extensively fractured rocks’.
• The company argues that the re-injected waste water can’t migrate laterally due to ‘significant geological faulting’, while at the same time claiming that re-injected waste water can’t migrate upwards due to an unbroken layer of impermeable rock. These two positions are clearly contradictory.
• The Environment Agency have failed to conduct any independent survey or analysis of the geology or water composition in the area, and are simply relying on clearly flawed data that is presented to them by the applicant.
• No alternative sites for these wells have been submitted to the authorities for consideration outside the National Park.
• Waste water re-injection into an existing aquifer is untested on the UK mainland. Given the untested nature of this technology, the precautionary principle should be applied and no waste water re-injection wells should be allowed in a National Park.
• Allowing a re-injection well in such a sensitive area could set a precedent for further injection wells in the park, and other National Parks in the UK. These may be used to dispose of toxic waste water from fracking extraction in the future.

Other points you might like to make in your objection to the NYMNPA are:

• National Parks are havens for nature and wildlife, and should be free from any such development and remain free of industrial works of any kind.
• The drilling of the proposed wells will continue for 24 hours a day, 7 days a week for three months, This will create constant noise and light pollution for three months and have a damaging effect on wildlife, in particular birds, bats, badgers and other nocturnal creatures, which may be in contravention of the Wildlife and Countryside Act 1981.
• The pipeline to Knapton crosses the River Derwent, which contains otters and water voles, both of which are protected species.
• These works are in close proximity to Dalby Forest, one of the main tourist attractions in the National Park. The increase in traffic, noise and general disruption, particularly during the construction phase of the project, will have a damaging effect on tourism in the area.
• The application also requires moving a public footpath, which is part of the popular Moors to Sea Cycle Network, again adversely affecting tourism in the area.
• The pipeline is to be builtin the same area as an archaeologically important earthwork remains of the prehistoric period, and these have not been adequately researched or documented. English Heritage have requested that the decision is deferred until a full and complete study has been done on the archaeology of the area.
• The development of a new gas field at Ebberston Moor is incompatible with the government’s legal obligation to ensure that the net UK carbon account for the year 2050 is at least 80% lower than the 1990 baseline. According to the National Planning Policy Framework 2012, the planning system “has a key role to play in helping shape places to secure radical reductions in greenhouse gas emissions“.

THE NORTH YORKSHIRE COUNTY COUNCIL (NYCC)

The application has also been registered at the NYCC as some of the works – i.e. the pipeline and the works at Knapton Generating Station – are within their jurisdiction. Planning permission would need to be granted by both Authorities for the development to proceed.

Please therefore also send a copy of your objections to both the NYMNPA and to the NYCC, so that both authorities have registered your comments.

You can make the same comments to both authorities, or send different versions, up to you! Please see the section on the NYMNPA above for points you can make in your objection.

Send your objections to the NYCC by post to: Chief Planning Officer, Planning Services, County Hall, Northallerton, DL7 8AH

You can also send your objections by email to: planning.control@northyorks.gov.uk

Please quote the planning application reference NY/2014/0275/ENV on all correspondence.

You can send the

THE ENVIRONMENT AGENCY

If possible, please also send a late objection to the Environment Agency, which will decide on whether to grant a radioactive injection permit. The deadline has passed, but please keep sending them in as they will accept late objections.

THE ENVIRONMENT AGENCY – LETTER TEMPLATE

This is the government department that will have to give permission for the Radioactive Substances Activity (RSA) permit, which Third Energy requires to be allowed to re-inject over 10 million cubic metres of contaminated radioactive water back into the ground without treating it first. (NOTE: If you’re looking for the application itself, go to our Planning Application Briefing page and scroll down till you see the Ebberston Moor RSR-A Permit EA Application links.)

Please send your objections to: RSR.Rotherham2.NE@environment-agency.gov.uk

quoting application number EPR/NB3595DJ/A001.

The official deadline has passed, but they will accept late objections so please keep sending these.

Don’t forget to include your full name, organisation name (if applicable), address and postcode on your objection. If you are from outside the North Yorkshire area, please state why this is of particular interest to you, for example, you often visit the National Park as a tourist, you have family in the area, etc.

In your objection, you may wish to make some of the following points:

• the proposed re-injection wells pass through aquifers that supply local drinking water. If and when the well casings fail – and all wells fail eventually – radioactive waste water could pass into the water supply.
• Ebberston South is located within various protection zones of the Corallian Limestone aquifer, and Yorkshire Water have already stated that the re-injection wells might ‘directly affect their asset’.
• Third Energy’s claim that re-injection is the Best Available Technology is driven by financial considerations, not because it is the best available environmental option. Detailed comparisons, both practical and financial, with other alternative disposal methods are not included in the application, and the re-injection option seems to have been chosen on the basis that it maximises profitability for the company.
• There is no proposed treatment process for the waste water before it is re-injected into the ground, which again does not constitute the best available environmental option.
• Studies in the USA indicate that waste water re-injection is a major cause of seismic activity, and is thought to be responsible for an exponential increase of earthquakes in Oklahoma (In 2007 there were only two per year, whereas there have already been 253 in 2014).
• The North York Moors National Park should not be used as a testing ground for potentially dangerous new procedures, particularly if there is any chance these might cause water pollution or earthquakes in the area.
• Third Energy’s proposals are based on a conceptual model using third party information and water analysis from Kirby Misperton, which is 9 miles away and from Ebberston B, which is nearly 3 miles away. No recent geological or water testing has been carried out at the Ebberston South site in order to assess the risks of produced water disposal.
• Third Energy cannot be 100% certain that waste water won’t travel into nearby aquifers over time, particularly after such a huge amount of water has been injected into the Sherwood Sandstone layer under pressure.
• The company’s argument that ‘the natural geology controls risk’ is unproven.  Third Energy’s consultants, Barton Willimore, state that ‘drilling in the Ebberston area is more difficult than in many other areas due to faulting and associated extensively fractured rocks’.
• The company argues that the re-injected waste water can’t migrate laterally due to ‘significant geological faulting’, while at the same time claiming that re-injected waste water can’t migrate upwards due to an unbroken layer of impermeable rock. These two positions are clearly contradictory.
• The Environment Agency have failed to conduct any independent survey or analysis of the geology or water composition in the area, and are simply relying on clearly flawed data that is presented to them by the applicant.
• No alternative sites for these wells have been submitted to the authorities for consideration outside the National Park.
• Waste water re-injection into an existing aquifer is untested on the UK mainland. Given the untested nature of this technology, the precautionary principle should be applied and no waste water re-injection wells should be allowed in a National Park.
• Allowing a re-injection well in such a sensitive area could set a precedent for further injection wells in the park, and other National Parks in the UK. These may be used to dispose of toxic waste water from fracking extraction in the future.

 

Thanks for helping to protect the North York Moors National Park!