EA Permit Comments - more inspiration

The EA Permit Application for West Newton is open for comments until the end of today.
The application for  Crawberry Hill is open until 11th March.
(note the end time of 12/3/2014 00:00 is midnight on the 11th)

Please comment here.

Not sure what to write?
The comments below may help.
There are also detailed concerns about water contamination here.

________________

Lack of Clarity

It is not at all clear to the local people yet whether or not this application is for fracking, which questions whether the public consultation can be effective.  There has been local media on this story (TV, radio & newspaper) and we do not know whether or not this application is to frack, or to test frack, or to test for possible future fracking.

This definition is crucial, not only for effective regulation by the EA and for the consultation process, but also because of Planning Condition 15- 'no fracking'.

Rathlin say it's not for fracking; yet the well goes into the Bowland shale.
Rathlin have gone further though, and repeatedly and categorically stated that they have "no intention of fracking" in the Community Liaison meetings, but in this application state, "The information gathered during the mini fall-off test
will help determine whether the formation is capable of being hydraulically fractured" which is in direct contradiction.

Climate Change

Further exploration for hydrocarbons will result in future greenhouse gas (ghg) emissions from fossil fuels that would otherwise stay in the ground.
Drilling for hydrocarbons inevitably leads to some escape of methane, a ghg many times more potent than CO2, released when the methane is burnt (over short & medium term), as well as leaks from the storage, distribution & delivery system.
Studies report that if leakage >3.2% the ghg pollution is even worse than emissions from coal.
Bearing in mind the IPCC reports this represents an unacceptable level of environmental damage, even if operations go according to plan.
It is totally incompatible with government ghg reduction targets (eg; 80% by 2050).

Water

This area does not have reservoirs so the entire region entirely relies on the underground aquifer for it's tap water.

Well casings can fail for various reasons, and injecting liquids at pressure can only increase the likelihood.
If the well casing should fail there is risk of contamination of the aquifer, either with chemicals inserted into the well, or with naturally occurring hydrocarbons including oil, that includes BTEX, or methane, or NORMs.  Rathlin admits the levels of NORMs are still unknown.
This in itself would be a catastrophe.
But chlorination treatment by Yorkshire Water could then lead BTEX to form chlorinated organics, and methane to form TCP, CHCl3 etc.

Conclusion

I urge that this application be declined due to:
- lack of clarity on Rathlin's plans in the local community, and whether this application contradicts what Rathlin has stated to the local community
- lack of clarity on what this permit is for, ie; whether it is to frack, or to test frack, or to test for possible future fracking.
- unacceptable level of ghg pollution
- risk to the essential aquifer

If a permit is granted it should only be on condition that Rathlin pays:
- a deposit sufficient to cover the costs of supplying clean & safe tap water (for drinking, bathing & washing) to the entire population of the region that rely on the aquifer, in the event of contamination
- costs to cover other externalised impacts including from increased extreme weather events due to climate change, eg; flooding & storm damage