OBJECTION to Fracking in Ellesmere Port
NW England SPECIAL REPORT SEPTEMBER 2017 Robin Grayson MSc Member of the Association of Liberal Democrat Councillors
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SUMMARY A major play for fracked gas is the current focus of intensive onshore exploration in North-West England. The author is concerned about several issues, in particular the rapidly increasing political risk to investors in the wake of the Liberal Democratic Party pledging to oppose fracking, leaving the minority Conservative Government isolated as the only mainstream party continuing strong support for the nascent onshore fracking industry. Therefore the firm stance by the Lib Dems is a prelude to a difficult time for many fracking projects, as it now requires only a small shift in Parliamentary support to indefinitely suspend fracking in the United Kingdom. This article describes an objection by the author to a planning application submitted to Cheshire West and Chester Council (CWAC) by IGas Energy plc (AIM: IGAS) for its Ellesmere Port #1 wildcat well in Cheshire "to mobilise well testing equipment, including a workover rig and associated equipment, to the existing wellsite to perform a workover drill stem test and extended well test of the hydrocarbons encountered during the drilling of the Ellesmere Port #1 well, followed by well suspension". According to the Applicant “The proposed project is to carry out further tests on the rock formation called the Pentre Chert, including a flow test, to better understand the volumes of gas it contains. Subject to the receipt of planning consent and the relevant environmental permits, this operation will utilise the existing well and no additional drilling will be required.” The purpose of the present article is to present compelling new grounds on behalf of the Liberal Democrats for rejecting the planning application or justifying lengthy delays to allow major matters to be thoroughly investigated before the Planning Authority can make an evidence-based determination of the application. #1: Recent Release of Relevant Data: Recently the author released into the public domain Report 84/4 on ‘Prospects and Plays of the East Irish Sea and Solway Basin’, which is arguably the biggest voluntary release of onshore data by the oil and gas industry in NW England. Delay in determining the planning application is warranted as the release has some bearing on the current application. #2: Threat to Geothermal Potential: Neither the Applicant nor the Planning Authority have given due consideration to the risk of fracking permanently sterilising a potentially large, deep, sustainable permanent Geothermal Resource in an area of high heat demand for industrial purposes. Determination of the application should be deferred to enable this exciting possibility to be carefully evaluated by all parties. In the event that the planning application is approved, a planning condition should be applied requiring the Applicant to conduct detailed downhole geothermal measurements. #3: Insufficient Information: The Applicant has presented insufficient information to show how the results of the Ellesmere Port #1 Wildcat to be integrated with existing seismic lines, nor indeed to monitoring points for soils and shallow groundwater. #4: Failure to Submit Risk Assessments for H2S or Methane: The Applicant has failed to present Risk Assessments on: a) uncontrolled hydrogen sulphide (H2S) emissions which are known to occur in NW England such as Stinky Bottoms; and: b) uncontrolled methane (CH3) emissions which are also known to occur in NW England as “Burning Wells”. #5: Lack of Appropriate Expertise: With due respect to the planning officers, they cannot be expected to possess knowledge of deep drilling or detailed geology of North-West England and therefore cannot make an evidence-based decisions on the merits and demerits of the planning application. #6: Lack of Transparency: It is impossible to make an evidence-based determination of an application of this nature when the Applicant has chosen to withold essential information from public scrutiny which has a direct bearing on the decisionmaking process including the Health, Safety and Environment (HSE) the operatives, residents and neighbouring industries. It would be inappropriate for the public purse to be used to drill a second deep hole in order to verify the confidential results of the deep hole already drilled by the Applicant who holds the data confidential. It is incumbent on the Applicant to release information into the public domain if the Applicant wishes the application to be determined. #7: British Geological Survey: In making a determination of the application, for the absence of doubt it would be inappropriate for the Planning Authority to accept as fact the opinions of the British Geological Survey (BGS). #8: Risk of Contamination by Lead and other Toxic Heavy Metals: The applicant has failed to present evidence regarding the Flintshire lead-zinc mineralisation field which may extend down-dip in the subsurface in an easterly direction. This field, or a parallel field, may be present in or near the Ellesmere Port #1 Wildcat. If so then it is reasonable to expect that fracking will encounter metal lodes containing large tonnages of galena (PbS) and sphalerite (ZnS) plus poisonous witherite (BaCO3) and mercury minerals such as cinnabar (HgS). In this quite plausible set of circumstances, drilling, well testing or fracking would risk producing, releasing and mobilising unacceptably high concentrations of toxic heavy metals in the groundwater. #9: Frequency and pattern of Faults: The Applicant has failed to present accurate evidence on the faults in the vicinity of the Ellesmere Port #1 Wildcat. This is of public concern in the light of microseismic events in the Fylde and the Manchester Swarm. #10: Breach of Planning Consent: The Applicant drilled the Ellesmere Port #1 borehole a kilometer deeper than envisaged in the original planning permission to test for Coal Bed Methane (CBM) in order to test the Pendleian Pentre Chert for methane. To restore public confidence, the applicant should be instructed to backfill the final kilometer of the hole with cement.
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Contents SUMMARY .......................................................................................................... 2 Subject: Comments for Planning Application 17/03213/MIN .............................. 4 Application Summary ......................................................................................... 4 Objection by Robin Grayson ............................................................................... 5 Comments: ..................................................................................................................................... 5
GROUNDS #1 – Release of Important Data.......................................................... 8 Argument #1 .................................................................................................................................. 8 Recommendation #1 ...................................................................................................................... 8
GROUNDS #2 – Threat to Geothermal Potential.................................................. 8 Argument #2 .................................................................................................................................. 8 Recommendation #2 ...................................................................................................................... 8
GROUNDS #3 – Insufficient Information.............................................................. 9 Argument #3 .................................................................................................................................. 9 Recommendation #3 ...................................................................................................................... 9
GROUNDS #4 – Surface Outbursts of Methane & H2S ........................................ 10 Argument #4 ................................................................................................................................ 10 Recommendation #4 .................................................................................................................... 10
GROUNDS #5 – Lack of Appropriate Expertise ................................................... 10 Argument #5 ................................................................................................................................ 10 Recommendation #5 .................................................................................................................... 10
GROUNDS #6 – Lack of Transparency ................................................................ 11 Argument #6 ................................................................................................................................ 11 Recommendation #6 .................................................................................................................... 11
GROUNDS #7 – BGS Interpretation ................................................................... 11 Argument #7 ................................................................................................................................ 11 Recommendation #7 .................................................................................................................... 12
GROUNDS #8 – Risk of Lead & other Heavy Metals ........................................... 12 Argument #8 ................................................................................................................................ 12 Recommendation #8 .................................................................................................................... 12
GROUNDS #9 – Frequency and Pattern of Faults ............................................... 13 Argument #9 ................................................................................................................................ 13 Recommendation #9 .................................................................................................................... 13
GROUNDS #10 – Breach of Planning Consent .................................................... 14 Argument #10 .............................................................................................................................. 14 Recommendation #10 .................................................................................................................. 14
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Subject: Comments for Planning Application 17/03213/MIN https://pa.cheshirewestandchester.gov.uk/onlineapplications/applicationDetails.do?activeTab=neighbourComments&keyVal=OTG0L0TE0I800& neighbourCommentsPager.page=2 Mr. Robin Francis Grayson, You have been sent this email because you or somebody else has submitted a comment on a Planning Application to your local authority using your email address. A summary of your comments is provided below. Comments were submitted at 2:25 AM on 26 Aug 2017 from Mr. Robin Francis Grayson.
Application Summary Address:
Land at end off Portside North, Ellesmere Port, Cheshire
Proposal: Mobilise well test equipment, including a workover rig and associated equipment, to the existing wellsite to perform a workover drill stem test and extended well test of the hydrocarbons encountered during the drilling of the EP1 well, followed by well suspension Case Officer:
Mr Robert Charnley
Name:
Mr Robin Francis Grayson
Email:
[email protected]
Commenter Type: Member of the Public Stance:
Customer objects to the Planning Application
Reasons for comment: Contrary to stated policy Detrimental to public interest Likely to set precedent Other or non-specific reason
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Objection by Robin Grayson MSc Geology Comments: I am independent technical adviser to the Liberal Democratic Party, and to the national headquarters of the Association of Liberal Democrat Councillors (ALDC) in Manchester. I was a Liberal County Councillor on Greater Manchester County Council and served on the GMC Transportation Strategy Committee, and the GMC Planning and Development Committee which included the Local Minerals Plan and determination of planning applications for mineral extraction, including oil and gas. I was Leader of the Opposition on Wigan Metropolitan Council. I was Liberal candidate for the Makerfield Constituency. I was Secretary of Wigan and District Geological Society. I was a member of Manchester Geological Association. I am a member of the Petroleum Exploration Society of the United Kingdom. I have advised government officers on major groundwater issues of the then-Top Secret Guardian Underground Telephone Exchange (GUTE, aka The Bunker) under central Manchester. I have contributed significant technical expertise to assisting the British Geological Survey in mapping halite and gypsum collapse breccias of Triassic Cheshire Salt under the River Bollin and parts of Manchester International Airport. I was Wellsite Geologist for the Holme Chapel #1 Wildcat deep well for oil and gas. I was adviser to BP for evaluation of its entire portfolio of onshore UK petroleum exploration licenses. I have negotiated with the UK government for onshore petroleum exploration licenses in NorthWest England, Wales and the East Midlands. I was a leading Expert Witness for Cheshire Wildlife Trust in the marathon Manchester Airport Second Runway Public Inquiry in geology, geomorphology, amphibians, pondscape, historic landscape, Regionally Important Geological Sites (RIGS) and Potential Sites of Biological Importance (SBI grade A, SBI grade B and SBI grade C). I am author of the NCC Salthill Quarry Geology Trail in the Salthill Quarry SSSI. I am joint author of the Geology and Industrial Archeology Trail in Haigh Hall Country Park. I have produced evidence of significant errors in 1:50,000 scale maps of the British Geological Survey (BGS) in parts of Cheshire, Greater Manchester, Lancashire and elsewhere regarding positions of faults, folds, coal seams, groundwater, superficial deposits and the bedrock surface. I have mapped faults in coal-bearing strata of a multitude of types including vertical faults, but also inclined ‘normal’ faults, ‘reverse’ faults, ‘wrench’ faults.
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I have detected the remarkable presence and persistence of bedding plane faults each following a particular geological horizon in the Namurian and Westphalian across the region. These are visible in surface outcrops but are barely detectable by seismic and cannot be expected to be detected in boreholes unless drilling is conducted by continuous coring. Each of the bedding plane faults is tectonic in origin and exhibits distinctive signs of bedding plane movement. If the beds are horizontal then these faults are horizontal; if the beds are inclined or vertical, then these faults are correspondingly inclined or vertical. It follows that some, most or all of the target fracking intervals are part of a stacked sandwich of thin tectonic detachment intervals i.e. stacked thin nappes. Each thin nappe will be a prospective so-called 'horizontal' fracking but in reality 'bedding plane' fracking following the ups and downs of a target shale layer. As a consequence the fracking drill will progress in close proximity to a regionally persistent bedding plane fault. The risk of reactivating a regionally persistent bedding plane fault is therefore likely to be high, and the consequence of disturbing such a fault is not known, but demands investigation prior to any fracking as the consequence may be or not be the reactivation of the bedding plane fault. Any such reactivation movement would be expected to translate into not only cleats and joints (assisting fracking) but also possibly translate into reactivation of master joints, small faults and larger faults. This would risk creating microearthquakes and damage seals that otherwise might successfully prevent upward escape of fluids. Once a seal is so-breached it would be technically challenging or impossible to reseal the breach. I am a recognised expert on the buried bedrock surface of the Mersey estuary, Merseyside, North Cheshire and Greater Manchester. I am a recognised authority on the Burning Wells of NW England associated with faulted coal deposits. I am author of Environmental Impact Assessments (EIAs and ESIAs) including large opencast coal mines. I was Environmental Adviser via The World Bank to the Minister of Mines and Petroleum of Afghanistan. I am author of the Amphibian Atlas of Greater Manchester. I am author of the Pondscape Map of NW England including the Wirral Pondway of Merseyside and Chester and West Cheshire. I was Geologist and Team Leader via the World Bank of projects in coal, copper, cobalt, gold, chromite, lapis lazuli, emeralds, rubies, jade etc. Currently I am Team Leader via the United Development Programme (UNDP) of a study of the supply chains of talc, lapis lazuli and jade from the Hindu Kush Mountain Chain. I was Environmental Adviser to the Welsh Office regarding river crossings and road widening. I was Environmental Adviser regarding the removal and dismantling of the Brent Spar Oil Storage Facility in the North Sea. I was Technical Author of Environmental Impact Assessments (EIAs) for private sector developments in Shropshire and Scotland, including water abstraction from rivers and water abstraction wells in red Permo-Triassic sandstones.
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Most relevant to this planning application: I am a professional exploration geologist for oil and gas, and have advised more than 20 oil and gas exploration companies in onshore NW England (including the application site, north Cheshire, Greater Manchester, Lancashire, Cumbria, Vale of Eden and the Solway Basin; including adjacent areas of inshore and offshore Irish Sea Basin). I am co-author of numerous strictly confidential exploration reports of which an initial 21 were released into the public domain on 28 June 2017. These 21 reports are now for the first time freely available to download from the portal of the United Kingdom Onshore Geophysical Library (UKOGL) https://ukogl.org.uk/oldham-associates-regional-report-on-line On the UKOGL site note the acknowledgement of the significance of the newly released data: “We are pleased to announce the addition to our Regional Reports archive of a key legacy study undertaken by Oldham Associates in 1984 over landward areas of Northern England.” “The report, entitled ‘Prospects and Plays in the East Irish Sea and Solway Basins’, provides a geological framework along with a detailed assessment of 13 identified prospects throughout the region.” “The report can be accessed via the Regional and Government Studies link (Northern England) on the UKOGL front page or through the 'catch all' search function on the on-line map.” “We wish to extend our gratitude to both Les Oldham and Robin Grayson, co-authors of the report, for their kind permission to allow this resource to be made freely available through the UKOGL website.” I believe this to be the largest-ever single release of private sector data on the oil and gas potential of North-West England.
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I HEREBY OBJECT to the application on the following grounds:
GROUNDS #1 – Release of Important Data Argument #1 Neither the Applicant and its advisers, nor the planning officers, safety experts, local planning authorities, statutory consultees, groundwater experts, geologists, geophysicists, local residents, local businesses, local industries, NGOs, anti-fracking groups, landowners and leaseholders etc have had the opportunity to read, digest, discuss or consider the exceptionally large volume of relevant technical information.
Recommendation #1 DEFER consideration for a period of 3 months in order that the freshly released technical data can be fully considered in a proper manner by all and any interested parties.
GROUNDS #2 – Threat to Geothermal Potential Argument #2 Granting permission would pose a threat to permanently sterilising the potential of a wide area for future consideration of deep geothermal energy resources. This is particularly important in an area with a need for guaranteed long-term supplies of sustainable permanently renewable clean energy for industrial, commercial, agricultural sectors. Geothermal energy enables district heating without the need to extract, produce, store, refine or transport hydrocarbon chemical products for this purpose which release pollutants which impact on health, environment, climate change as well as tourism, farming and regional corrosion and dissolving of cement, steel, facing stones, wiring etc.
Recommendation #2 DEFER consideration for a period of 12 months in order that the Applicant can verify to the satisfaction of the Planning Authority the presence or absence of a valuable geothermal prospect at or below the borehole. In the event of permission being granted, then the Applicant should be required to conduct detailed geothermal measurements down the Ellesmere Port #1 Wildcat to the satisfaction of the Planning Authority and of the British Geological Survey.
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GROUNDS #3 – Insufficient Information Argument #3 Insufficient information is available to allow the Planning Authority, consultees or third parties to enable the results of the Ellesmere Port #1 to be properly integrated with existing 2D seismic lines or the required new 3D seismic lines and mag-grav lines, nor indeed to monitoring points for soils and shallow groundwater.
Recommendation #3 DEFER consideration of the application for a period of 12 months in order that the Applicant can address the above issues to the satisfaction of the Planning Authority: a) A grid of say 200 sample points of subsoil to map and monitor the depth, presence and seasonal fluctuations in soil gases including not only methane but also radon, and a range of other indicators of presence of oils and gases, including chemical analyses. b)
Drilling in advance of at least 20 permanent open hole vertical Observation Boreholes to a shallow depth of say 100 metres as a baseline to detect before, during and after drilling of any changes in the gas content observed.
c)
Re-processing and reassessment of deep seismic lines within a radius of say 15 kilometres.
d)
Completion and assessment of 3D seismic lines within a radius of say 5 kilometres.
e)
Completion of a modern mag-grav survey within a radius of say 15 kilometres, in order to reassess the currently available geological maps of the British Geological Survey (BGS) which are demonstrably known to be extremely useful but need to be substantially updated by integrating each map with the substantial existing network of confidential deep seismic lines now generously made public by oil and gas companies and by the coal industry.
f)
Re-assessment of the robustness of the Applicant's prediction of the geological strata already drilled and to be tested; in the light of: i) Integration fully with all the above essential data sources. ii) Recognition that the predicted geology based on the present understanding of the geology is expected to differ considerably from that predicted, as evidenced by my direct experience with the Holme Chapel #1 Wildcat Well that “unexpectedly” proved two major faults, and “unexpectedly” drilled through thick limestone instead of the predicted shales and terminated in “completely unexpected” metamorposed slate basement instead of the predicted Waulsortian reef target; iii) Likewise as evidenced by my experience advising BP for a wildcat well to explore beneath the Egmanton Oilfield in the East Midlands, which “unexpectedly” proved extremely thick Carboniferous strata, sufficient to raise concerns on how deep it was safe to drill, and terminated in a “completely unexpected” Waulsortian reef.
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GROUNDS #4 – Surface Outbursts of Methane & H2S Argument #4 Hydrogen sulphide (H2S) emissions are found in the region, such as Stinky Bottoms. Methane (CH3) emissions occur as “burning wells” in parts of Greater Manchester. These are strong risk indicators of which the Applicant must be aware and should have done a desk study from archives and maps. If not this would constitute evidence to reject the application.
Recommendation #4 DEFER consideration of the application for a period of 6 months so that the Applicant can address the above issues to the satisfaction of the Planning Authority: Concerns about potential outbursts requires the Applicant to install substantial blow-out preventors and fast sensitive detectors for emissions of inflammable methane gas, explosive mixtures of air and methane gas, lethal hydrogen sulphide gas (H2S) and blow-out of the drilling mud and hundreds of metres of the metal drill string and metal casing. While the risk is extremely small, it is not zero, and it would be irresponsible and criminally liable for any geologist or engineer or Planning Officer to claim or infer otherwise. The Planning Authority should request the Applicant to submit within ten working days information from his/her files of data on natural emissions of methane and H2S at the surface in NW England and any spatial relations with known geological faults.
GROUNDS #5 – Lack of Appropriate Expertise Argument #5 With due respect to the admirable professionalism and expertise of the planning officers, they cannot be expected to possess knowledge of deep drilling or detailed geology of North-West England and therefore cannot make an evidence-based decision on the merits and demerits of the planning application.
Recommendation #5 DEFER consideration until such a time as the Applicant provides a full set of information to the planning officers on ‘open file’ with permission for it to be made available to the public on internet and during normal office hours.
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GROUNDS #6 – Lack of Transparency Argument #6 It would be reckless and a dereliction of public duty of care for a Planning Authority to approve an application of this nature when the Applicant witholds information from public scrutiny relevant to Health, Safety and Environment (HSE) of the operatives, residents and neighbouring industries. It would be inappropriate to use the public purse to drill a second hole to verify the confidential results of the hole already drilled by an Applicant who choses to hold the data confidential. It is incumbent upon the Applicant to release requested information into the public domain if the Applicant wishes to enable the application to be determined.
Recommendation #6 DEFER consideration until such a time as the Applicant provides a full set of information.
GROUNDS #7 – BGS Interpretation Argument #7 In making a determination of the application, for the absence of doubt it would be inappropriate for the Planning Authority to blindly accept as fact the views of the eminent British Geological Survey (BGS), for two reasons: a)
The impartiality of the BGS governmental organisation is in doubt regarding deep drilling and the nascent UK fracking industry as the BGS now holds a remarkably large volume of information from this industry that remains confidential in the BGS files but is open only to BGS officers.
b)
It is understandable and perhaps necessary that exploration companies give investors and Planning Authorities a rather simplistic presentation of the risks and unknowns. However as the BGS make abundantly clear in their publications and presentations that, while the Bowland Shales appears very promising for fracking, there are numerous unknowns. It follows that a deep borehole such as Ellesmere Port #1 is a wildcat, with seismic lines open to several plausible interpretations, and likewise the borehole log of layers passed through are also open to several interpretations. Regrettably it is inevitable, no matter how experienced seismic interpreters, well-log interpreters and stratigraphers may be, to make gross errors in NorthWest England. For instance due to: i) Environments repeating over time due to sea level oscillations, so producing vertical repetition of sediment types and rocks;
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ii) iii)
Deltas waxing and waning over time, so producing horizontal repetition of sediment types and rocks; Even more confusing, environments varying from seas so deep that the sea floors were in perpetual darkness but alongside reefs and shallow lagoons basked in bright sunlight. It is even possible for a borehole to hit a reef or end up in very deep water.
Recommendation #7 DEFER consideration until such a time as the Applicant provides a full set of information.
GROUNDS #8 – Risk of Lead & other Heavy Metals Argument #8 A source of concern is that the Flintshire Lead-Zinc Field may extend down-dip in the subsurface in an easterly direction and the Field, or a parallel Field, may be in close horizontal and/or vertical proximity to the Ellesmere Port #1 Wildcat. The magnitude of this concern cannot be overstated, for if so then it is reasonable to expect that fracking will sooner or later encounter metal lodes containing large tonnages of lead ores such as galena (lead sulphide PbS) and zinc ores such as sphalerite (zinc sulphide ZnS) plus not only barite (barium sulphate BaSO4) but also poisonous witherite (barium carbonate BaCO3) and mercury minerals such as cinnabar (mercury sulphide HgS), as well as iron minerals such as pyrite (iron sulphide FeS2). In this quite plausible set of circumstances, fracking would be expected to pulverize and mill the galena and sphalerite into a toxic slurry paste containing very high concentrations of lead and zinc and possibly traces of mercury, that will leach easily to creation of unacceptably high concentrations of toxic heavy metals in the fracking fluids.
Recommendation #8 REJECTION by the Planning Authority on the grounds of insufficient information being supplied by the Applicant. It is incumbent upon the Applicant to reveal the geochemistry and temperature of Ellesmere Port #1 borehole and to commission a detailed independent geochemical assessment of heavy metals in the lead-zinc mineralization in the Flintshire Lead-Zinc Field, and in all production and observation wells within say 20-kilometre radius of the Ellesmere Port #1 Wildcat.
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GROUNDS #9 – Frequency and Pattern of Faults Argument #9 A source of concern is the failure by the Applicant to present to the Planning Authority a geological map on a scale of say 1: 50,000 to illustrate the frequency and pattern of faults of the area. Both the Objector (Liberal Democrat Geologist Robin Grayson MSc) and doubtless the Applicant are fully aware of the presence of a network of seismic lines in and around the Ellesmere Port #1 Wildcat, both onshore and in the Mersey Estuary, and that the purpose of the seismic lines is for oil and gas exploration, and specifically to map the presence of faults, folds, dips, source rocks, reservoir rocks and seals. Both the Objector (Liberal Democrat Geologist Robin Grayson MSc) and doubtless the Applicant are fully aware that the 1:50,000 scale Geological Maps of the area are woefully out of date, in failing to take account of the rich sources of geological information visible on the network of seismic lines. Both the Objector (Liberal Democrat Geologist Robin Grayson MSc) and doubtless the Applicant are fully aware that many of the seismic lines are now in the public domain courtesy of the United Kingdom Onshore Geophysical Library and downloadable from the UKOGL website’ However it is incumbent upon the Applicant, not the Objector, to use the public domain UKOGL seismic lines in order to submit a revised geological map of an area of say 15 km radius around Ellesmere Port #1 Wildcat to the Planning Authority in order than the Planning Authority can make an evidence-based determination of the planning application submitted by the Applicant. It is equally incumbent upon the Applicant to place in the public domain sufficient of its CONFIDENTIAL seismic lines in the area as plotted on the UKOGL map, if the Applicant wishes to assist the Planning Authority to make an evidence-based determination of the Application, and to inform the public about the presence of numerous faults crisscrossing the area that may be of concern in the light of fracking-related microearthquakes in the Fylde and the mysterious numerous microearthquakes of the ‘Manchester Swarm’ near Manchester city centre.
Recommendation #9 REJECTION by the Planning Authority on the grounds of insufficient information being supplied by the Applicant. Unless and until the Applicant releases sufficient information into the public domain on the pattern of faults that are known by the Applicant to crisscross the area but are not shown on the BGS Geological Maps, the Application should be REJECTED on the grounds that there is insufficient information to make an evidence-based determination of the merits and demerits of the Application.
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GROUNDS #10 – Breach of Planning Consent Argument #10 I was alerted by Liberal Democrat members that the Applicant, by means of this Application, is seeking Retrospective Planning Permission for having drilling the Ellesmere Port #1 Wildcat an astonishing kilometer deeper than envisaged for in the original planning permission which granted permission to drill a vertical hole to test coals for Coal Bed Methane (CBM) in the Coal Measures. The Applicant has claimed in the local media that it was legally entitled to do continue drilling down to a total depth of 1,949 metres. Having drilled through the Coal Measures, the drilling continued to test the much deeper Petre Chert: http://ir1.euroinvestor.com/asp/ir/IGas/NewsRead.aspx?storyid=13658565&ishtml=1 The Petre Chert is the ‘flint’ of Flintshire and nowhere to my knowledge is associated with coals and therefore cannot have been a plausible source of Coal Bed Methane (CBM). Instead’ in my opinion, the only plausible explanation was that the Applicant drilled an extra kilometre deep in order to test the Petre Chert as a target for fracking. In this regard, the Pentre Chert is of Pendleian age, and therefore within the regional fracking target of the Bowland Shales. There is a fundamental difference between exploration for Coal Bed Methane (CBM) and drilling a kilometre deeper to explore for production of methane from rocks by fracking. David Holmes 21:00, 16 AUG 2017 Chester Chronicle on-line newspaper. Probe launched over energy firm's Ellesmere Port test drill. But IGas insists its borehole was in full compliance with planning consent www.chesterchronicle.co.uk/news/chester-cheshire-news/ellesmere-port-test-drill-probe-13482112
A pattern of behavior seems to be prevalent. A rather similar story seems to have happened at Ince Marches towards Frodsham. Here Nexen Exploration UK Ltd, now owned by IGas was granted planning permission to drill two exploratory boreholes for coal bed methane (CBM) appraisal, production and extraction in April 2010. The council was told the average depth would be 762 metres, but in fact the company drilled to 1,469 metres and found shale around that depth.
Recommendation #10 REJECTION by the Planning Authority on the grounds of the Applicant grossly exceeding the stated purpose of the planning permission being granted solely to test for Coal Bed Methane (CBM) and instead drilling an additional kilometre deep to the test the Pentre Chert which has no coal and therefore cannot have any CBM, but instead has is of the same age as the Bowland Shales which are a regional target for fracking to produce methane. PROSECUTION by the Planning Authority of the Applicant for the gross breach of the original Planning Permission, and in order to restore public trust in the planning system and to serve as a deterrent to future gross breaches of a similar nature by the nascent fracking industry. INITIATE PLANNING ENFORCEMENT by the Planning Authority on the Applicant to remedy the breach of the original Planning Permission within 90 days, by backfilling the final kilometre depth of Ellesmere Port #1 Wildcat with cement to the satisfaction of the Planning Authority.
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