Lynchmere Parish Council have produced the following in response to the South Downs National Park Authority scoping opinion for the proposed drilling in Fernhurst.
Attention: Lucy Harding
South Downs National Park Authority
Dear Mr Slaney,
Celtique Energie Weald Ltd: Scoping opinion SDNP/13/02126/SCOPE
Thank you for your letter of 17th June. Lynchmere Parish Council would expect to see the following information covered in the Scoping Opinion.
1. Type of baseline Data and methodology
We would expect to see full baseline surveys for the existence and population numbers of all flora and fauna on the proposed site and within such minimum radius as is established by the relevant scientific bodies. We would expect the surveys to be carried out by accepted methodologies for each species.
We would expect clear information on underground aquifers, the current sources, pressures and quantities for local supply and the current pattern of groundwater dispersal on the proposed site to the furthest extent of its dispersal. We would expect the data to show the sufficiency of the water source required for operations should they commence.
Geological conditions and Seismic movement
We expect a comprehensive report on the current geology of the site and within 5KM including information on fault lines. We would also expect detailed records of any past seismic activity.
We expect comprehensive surveys of current air quality both on the site, within 5Km of it and along the entirety of the proposed route for traffic associated with the proposal.
Landscape, visual and domestic amenity
We expect a record to be made of the current landscape, including but not limited to roadside verges and vegetation and any trees which may be removed if the proposal were to go ahead. There should be a comprehensive survey of land use within a radius of 5 Km of the site. Additionally we would expect a structural survey of the bridge on Vann Road, the old iron works at the Fernhurst Furnace and of any buildings whether for human habitation or otherwise within a 2Km radius of the site. Surveys should cover current light use at night and noise levels. We expect comprehensive surveys of current traffic use along the entire route to be taken by all vehicles which would be required by this proposal. We would expect any landowners within 5Km of the site to be able to request current valuations of their properties as a baseline in the event of any future planning blight.
We expect to see the following; the exact terms of the lease for this site with regard to what operations are covered by it, both immediately by way of exploration and in future; clear evidence of the right of access to the site; a clear line of corporate responsibility between Celtique, Magellan and any and all further associated companies, whether incorporated in the UK or elsewhere, their financial soundness including the ability to make good on guarantees or indemnities given in respect of temporary or permanent damage done if this project goes ahead; a clear statement regarding liability in the event of negative impacts of both normal, accidental and negligent operations, and the ultimate destination of any profit the proposal may yield.
We expect to see evidence of competence, by way of clear examples of similar operations carried out in the past by the current applicants, in a similar environment, and their outcomes. In the absence of such examples we would expect to see an independently verified opinion as to how the applicant is competent to undertake such operations. We expect to see a full plan of operations including the direction of any proposed horizontal drilling, the exact composition of drilling lubricants, water and other such materials to be used and in particular the method, materials and quality of the proposed well lining.
We expect to see surveys of current visitor numbers and visitor appreciation to this area of the Park. We expect to see a clear statement by government that such a proposal within the SDNP is in the national interest and why.
2. The prediction of impacts
We would expect to see predictions of any changes to any of the baseline data. Such predictions should cover the potential effects of chemicals, water, traffic, light and noise used or created by operations, both under normal conditions and under unforeseen emergency events such as spillage, fire and traffic accidents. We expect to see the predicted outcomes for the delivery to and removal from the proposed site of any materials and water brought to it. We expect the predictions also to address the totality of the effects of operations on the wildlife, landscape, health and human amenity of the area. The predictions should take into account examples from similar operations in other locations, both in the UK and elsewhere, with particular emphasis on those locations with similarly close human populations and within a National Park. We expect to see predictions of financial impacts, to include taxable revenues and any predicted effect of the proposed operations on both national and local energy prices.
3. The assessment of impacts
Should this application go ahead we would expect to see a continuing, independently verified assessment of the status of all of the baseline data, including periodic re surveys. We expect to see proposals for a clear system for reporting any change to that data, however slight, to the local community. We expect to see clear lines of communication and decision making should any emergency arise and an undertaking to stop operations according to a previously agreed list of contingencies.
4. Mitigation measures
For each of the predicted impacts on any of the baseline data we expect to see the applicant's proposed mitigation measures, the cost of such measures, guarantees as to the availability of funds to meet such measures and the speed with which such measures would be applied. Furthermore, we expect to see as part of the assessments plan an emergency mitigation plan, which is fully costed and for which, equally, funds are in place at the outset of operations.
5. Assessment of residual effects
We would expect to see a detailed plan to monitor impacts for an appropriate time period beyond the cessation of operations, whether after the exploration stage or full extraction, with funds in place to cover any mitigation required long term or for impacts of the operations which manifest themselves only some time after cessation of the operations.
(Clerk & RFO to Lynchmere Parish Council)