Fernhurst drilling objection 'letter of the week' - a must read!

Dear Sirs

SDNP/13/05896/CM
The installation of a well and associated infrastructure, including access road and soil bunds,
for the drilling of a vertical borehole and contingent horizontal borehole from the same well for the exploration, testing and evaluation of hydrocarbons for a temporary period of three years

The use of the word temporary in the proposal is both wrong and entirely misleading. The proposal actually covers three different time periods

1. 3 years - the period during which the site would be constructed, drilled and explored, on expiry of which the Applicant (Celtique Energie) ’CE’ would remove the portable equipment and machinery

2. indefinite/ permanent – the period during which the tarmac access road, the stone surface, the earth bunds and the security fencing would remain, such period being entirely at the discretion of CE and with no defined end date.

3. permanent – the period forever that the vertical and horizontal bores and their structure would remain in the ground

Throughout the application , CE, makes liberal use of the assertion that the proposal is only temporary, justifying any impact on local residents, local amenity, landscape, air quality, traffic and noise on that ground. Yet it is quite clear that CE has every intention of retaining the site long term and developing it further if it is in their interest to do so. The lease of the land will be for a period of at least 30 years, it is believed, no doubt with an option to extend should further time be required.

It would be quite wrong for this proposal to be judged only according to CE’s assertion that it is temporary.

Proposed site

1. Visual impact The assertion that the site is well screened and has no visual impact is wrong. The ancient woodland adjacent to the site is mainly deciduous, as are the hedgerows, which means that, for at least 6 months per year, the site will be visible from the road, from footpaths 1265 and 1264 ( which run west and south of the site) and from the nearest residential properties. Whilst the rig is in place, it will be visible from all around the area as it will tower over the tree tops.

The access track is currently in keeping with the rural landscape as it runs between arable fields, bordered by a hedge on the east side and the ancient parish boundary on the west side. CE proposes to turn that rural semi-grassed track, crossed occasionally by an agricultural vehicle, in to a tarmac road up and down which HGVs, delivery lorries, vans and cars will drive regularly for at least 12 hours per day (on the basis of the working hours proposed). This would be a significant change to the landscape.

CE proposes to crown lift a number of the trees in the parish boundary line to enable its HGVs to pass below. Oak trees in hedgerows are an iconic part of the low Wealden landscape. Not only will the proposed cutting alter the shape of those trees in the landscape but it will also make them chronically unstable (heavier on one side than the other). So, again, the proposal will have a visual impact.

CE is also proposing to festoon the countryside along Vann Road with signs warning about the site and its traffic. Such street furniture will have an industrialising visual impact.

The entire site will provide an industrialising visual impact on the countryside.

2. Access - The entrance to the track is narrow, the gate being approximately 12’ wide, as is the track itself, with no room to increase that width as the land on either side is owned by other landowners.

The drawings supplied by CE state ‘widen entrance’ and ‘existing track widened’ but, when questioned, CE have been unable to say how they will widen the entrance and track given that the east side is bordered by a hedge which does not belong to CE (or its landlord) and the west side is bordered by the hedgerow of the parish boundary and a ditch, the land adjoining also not belonging to CE( or its landlord). Neither adjoining landowner will give permission for CE to encroach on their land.

There is no space on the existing track for a passing place. This means that only one vehicle can drive up or down at any one time. If a vehicle is on the road and another is exiting, the vehicle on the road will have to wait – thereby blocking the west bound carriage way.

Since the entrance is insufficiently wide, no HGV will be able to turn in without first encroaching on the eastbound carriage way. CE’s advisers, Royal Haskoning, admit that this may give rise to accidents but dismiss the risk as negligible. If, say, an HGV is first waiting on the road to turn in, then crossing the centre line to actually effect that turn, there is a high risk that an impatient west bound vehicle will try and pass and possibly hit an east bound (or site exiting) vehicle. Since, during construction, CE is envisaging 70+ vehicles per day in and out of the site, the risk must be more than negligible. Even after construction and during operation, there will be many vehicles turning in and out – workers cars and vans; water, waste (human and mineral)and fuel lorries as well.

The entrance to the site is not quite directly opposite the road down from Lynchmere so the issue of vehicles tuning in and out, as well as waiting on the road, is further complicated by vehicles using that road as well.

3. Traffic - CE proposes that all traffic comes from the A286 along Vann Road. CE emphasises how it plans to make all the HGVs supplying the site use the ‘West Sussex preferred lorry route’ but makes minimal reference to the fact that the last section of any journey to the site is along Vann Road, an unrestricted country lane with narrow pinch points.

Paragraph 2.3.1 of LTP3 Chichester District states that HGVs should be discouraged from using unsuitable roads. NPPF P.32 provides that safe and suitable access to a site should be achieved for all people.

The proposal refers to Vann Road as being 6m wide. Whilst that may be the case at the start of Vann Road just off the A286 (although there are parked cars there reducing the width), the road is considerably more narrow along the rest of its length to the site. Vann bridge is 5m wide (maximum, not usable width) and the road at Highbuilding pond is 4.8m wide (again, maximum, not usable width).

4.8m is the minimum width required for 1 large vehicle and a car to pass.
5.5m is the minimum width for 2 large vehicles to pass.

So, for much of the length of Vann Road there will be problems with 2 large vehicles passing and, in places, it will be impossible. In their traffic survey, CE have imaginatively classified any vehicle over 1.5 tons ( equivalent to a Volvo estate) as an HGV and so have come up with an HGV traffic increase of less than 30% which they maintain will have no, or a negligible, impact on the road and local residents. If an HGV is properly classified, then a recent independent traffic survey shows that the increase of such vehicles along Vann Road would be 2000% if the proposal were permitted. So, in truth, the impact on the local community will be enormous.

The structure of the road itself is poor. There is a thin layer of tarmac on a thin layer of hardcore on top of clay. It was not built to take the weight of HGV traffic which will be generated by the proposed site.

Since no traffic management plan has yet been supplied, it is impossible to judge how CE might or might not manage to adequately supervise their traffic or how they would deal with the problem of HGVs or other vehicles queueing on the road to access the site.

Vann Road is regularly used by walkers, cyclist and horse riders. After Vann bridge westbound, or before Vann bridge east bound, there is no pavement and, in places, no verge. There are a number of residential properties along this stretch of Vann Road and a number of those residents do use the road to walk, cycle and ride along as well as attracting people from other places. A 2000% increase in HGV traffic will have a significant impact on the local community using the road.

The valley has a large network of public rights of way, all of which are regularly used. No less than 6 PROWs exit on to Vann Road between the A286 and the proposed site.

On the north side of Vann Road, PROWs 1256,1252,1249,1258 and, on the south side, 1264,1263.

These PROWs do not all join up directly across Vann Road and, in certain places, it is necessary to walk along the road without a verge. The only bridle ways are the BOAT track up Vann Common and 1265 at Lower Lodge Farm, so if you ride a horse, you have to ride along the road. A number of properties along Vann Road have equestrian facilities as well as livestock in the fields which are accessed from Vann Road. This is still a working agricultural area.

The SDNPA is promoting walking and cycling in the South Downs National Park. The huge increase in traffic proposed by CE would heavily impact on the use of this area by walkers and cyclists. Haslemere station is proposed as a gateway station. Fernhurst is the first village south of Haslemere in the National Park. It would be highly ironic if Fernhurst became industrialised by the permitting of this proposed site and its roads became too dangerous for walkers and cyclists.

This proposal pushes HGVs on to unsuitable roads and the narrow entrance makes the area around the entrance unsafe for other road users

4. Noise At present, the only sounds at the proposed site are from birds and sheep. If this proposal is allowed, the noise will be human voices, machinery, diesel generators, vehicle engines, HGV air brakes and the reversing beepers of HGVs and heavy machinery, and once the bore hole is drilled, the noise of gas being flared off.

CE proposes that the site will be worked for 24 hours per day without respite. People who have lived close to a similar drilling site say that the noise is persistent and can be easily and uncomfortably heard over half a mile away.

In its noise testing, CE has made no allowance for the fact that the site is in a valley and that noise travels a long way in this valley.

This proposal turns peaceful countryside in to an industrial zone.

5. Light - At present, there is no light at night at this site. The local community, and visitors to the area, are able to enjoy the night skies. On a clear night the constellations are beautifully visible. CE proposes that the site will be lit whenever it is dark. This will effectively destroy the dark skies in the area as even downlighting sets up a glow which affects the visibility of the stars.

The rig, at 45m high, would be lit and visible from miles around.

6. Ground water - The proposed site is on the floor of the valley. Except following several consecutive dry summers and winters, the ground water levels in the valley are very high such that the fields in winter are usually saturated and often have standing water. The soil is clay but the upper levels to the north and south are greensand. This means that the water quickly drains off the hills down in to the valley adding to the saturation of the land. Indeed, much of the land around was once classed as marsh land.

If the proposed site goes ahead, the clearing of the land, removal of the topsoil and creation of earth bunds will affect the surrounding land. The displaced water will have to go somewhere. At present the surface water from the site drains off the east side in to the stream behind. How will the stripping of the land and putting down of stone affect the water levels around?

Unless the site were constructed during a dry period, the ingress and exit of hundreds of HGVs on to a clay soil area will mean that clay is tracked out on to the surrounding roads to a dangerous extent.

7. Wildlife - The surrounding ancient woodland and the pond is home to abundant wildlife, all of which will be affected by the noise, air and light pollution. The woods are carpeted in blue bells and orchids abound. The proposal will damage the surrounding with the pollution from the site.

8. Human life - CE simply dismisses the impact that this proposed site will have on humans and describes it as negligible. The nearest homes are 300 yards away from the site but nearer to the access road. Indeed, the proposal effectively means that these homes will have HGVs thundering along on roads to the north, west and south of their properties. They will be affected by the noise 24 hours per day, for as long as the operation goes on. They will hear the drilling, the diesel generators, the workers talking, shouting, dropping tools and the cars arriving and leaving, the HGVs air brakes and reversing beepers not to mention their engines, the machinery preparing the site, the machinery erecting the rig, the placing of portakabins and all the continuing noises of an operational site.

The noise will be heard from quite some way away. The wind blows from the west mainly so the noise will be blown towards the village.

9. Air - The quality of the air is something much appreciated by those who live in the countryside. The air quality here will be completely destroyed by the emissions from all the machinery involved in the construction and operation of this site. Heavy diesel emissions will pollute the air as will the gases flared off. The diesel fumes from the HGVs will pollute the air throughout the area.

The polluted air will be blown with the prevailing wind towards Fernhurst.

10. Scheduled monument - The remains of the ironworks at Furnace Pond lie just 250m away. The enjoyment of these remains by visitors will be heavily affected by being close to an industrial site as opposed to in the quiet of the countryside. Vibration from the drilling might affect these remains. In particular the causeway damming the pond may be vulnerable to movement particularly if, as in this winter, the volume of water held back is considerably greater than usual putting enormous pressure on the stone and earth works.

11. Waste - There is no information supplied as to how waste will be disposed of. Will the drillings be trucked out by HGVs? If so, how often and to where? If not, how will the waste be stored? And what will happen to it if the site were abandoned?

South Downs National Park

The key objectives of the national park are to

• To conserve and enhance the natural beauty, wildlife and cultural heritage of the area

• To seek to foster the social wellbeing of the communities within the park

This whole proposal is completely at odds with these two objectives. An industrial site In the middle of fields and ancient woodland cannot possibly be said to conserve or enhance the natural beauty, wildlife or cultural heritage of the area. Equally nothing in the proposal fosters the wellbeing of the community. There is no benefit to the community from this proposal only detriment.

Alternative sites

The only reason that CE has picked this site is because the landowner has agreed to lease the land and the land has access to a road. The geology is not specific to this site.

A number of the sites which CE claims to have considered and rejected are rejected on grounds that would equally apply to this site

- Site 1, for example, is dismissed as the access would have to be extended by between 100 and 600m. The access track at the proposed site will be extended by at least that much
- Other sites are dismissed because there is ancient woodland or there are water courses around them or public rights of way nearby. There is ancient woodland and water courses close by at the proposed site as there are public rights of way.
- Criteria that were applied to alternative sites do not seem to have been equally applied to this proposed site.

The fact that CE is unable to find other suitable sites does not mean that this proposed site must be suitable. Equally, the fact that CE has obtained a licence that may be unworkable does not make this site suitable because it is the only one they can find. If the landowner had not consented, then this site would not have been available. The simple fact that it is available does not make it suitable per se.

There is no need for CE to have this site for exploration. The fact that they may want to have it is not the same as need. There is no public benefit in CE exploring this particular site. Hydrocarbons, it is now claimed on behalf of oil and gas companies and the government, lie beneath 60% of the UK. It cannot be claimed therefore that this particular 9 acre site must be drilled as a matter of need.

There is absolutely no local benefit to this site. There is a considerable cost to the local community, however, in reduced quality of life through traffic, air pollution, noise pollution and light pollution. And it is completely contrary to the purposes for which the South Downs National Park was created.

Hydraulic fracturing ( ‘fracking’) CE repeats many times that this proposal does not involve fracking (hydraulic fracturing under high pressure) but it is quite clear that they are looking at this as a possibility in the future. Para2.13 of the Alternative Sites section states:

‘from this evaluation, it will be possible to establish whether hydraulic fracturing might be required in the future’

And, in the Geology section para 5.7:

‘the proposed development is to establish if there is oil or gas…and to establish the unconventional potential’.

So there can be no doubt that fracking is a possibility which is already being considered and which CE would propose to do at this site if it were possible and commercially viable.

Since the constructed site would – if this proposal is allowed – remain in place indefinitely, at the will and discretion of CE, their future plans to keep this site permanently should be taken in to account when considering the suitability of the site.

Future costs - In the event that this site were granted and exploration were to take place, CE is an insubstantial company with no assets, limited liquidity and a handful of employees. CE has never built, explored or developed a site. So most of the work will be subcontracted out. Who will bear the costs if something goes wrong? Who will pay to restore the site if at some stage CE decided they no longer wanted it? Who will monitor and who will pay for the rusting/disintegrating well casings if the site is abandoned?

For all the above reasons, I object to this proposal. I also reserve the right to object further in the event that new information comes to light prior to a decision being made.

Yours sincerely