The village of Marsh Lane from Bramleymoor Lane where Ineos proposes to explore for shale gas. Photo: DrillOrDrop
The first shale gas exploration scheme in Derbyshire has been approved.
In an announcement today, Planning inspector, Elizabeth Hill, gave permission to Ineos Upstream to drill and test for shale gas at Bramleymoor Lane in the village of Marsh Lane. The site could also be used to monitor fracking nearby. Ineos Bramleymoor Lane Appeal Decision (pdf)
The decision follows an eight-day public inquiry in June at which Ineos was opposed by Derbyshire County Council, Eckington Against Fracking and more than 30 members of the public, including the MP, Lee Rowley, and local headteacher.
Ineos Upstream welcomed the decision and hoped it would set a precedent for what the company described as “timely decisions on future applications”.
Eckington Against Fracking and Mr Rowley said the fight to stop fracking at Marsh Lane was not over. Mr Rowley told PeakFM:
“We have to see where there is the potential for us to ask for it to be looked at again. There may be that opportunity, there may not. We have to work this through over the next few days.
“We have all got to pull together. We have to pick up ourselves back up and carry on the fight because fracking can’t happen at Bramleymoor Lane. The community is united in that. What we now have to do is make sure that doesn’t happen.
“Fracking is a long way off. We are going to win the war even if we don’t win every battle.”
This is the second appeal won by Ineos Upstream. In June it was granted permission for shale gas exploration at Common Road, Harthill in South Yorkshire. For both sites, the company had appealed against what it said was unacceptable delays in deciding the applications.
Mrs Hill ruled today that planning permission was granted subject to 37 conditions. She said there would be “slight harm” caused by night-time noise to people living nearby.
But she said this was outweighed by the benefits of exploration from “its potential to improve resources for energy supplies”.
At Bramleymoor Lane, Ineos sought to drill a well to a depth of 2.4km using a 60m rig. The site is about 400m from homes. Ineos also proposed to use the borehole as a listening well for fracking within 500m.
Derbyshire councillors voted in February by 9-1 to oppose the Bramleymoor Lane plans. At the inquiry, the council argued that heavy vehicles visiting the site would have an unacceptable impact on rural roads, the proposal would affect the openness of the green belt and local people would be disturbed by night-time noise.
The inquiry also heard there was no evidence that Ineos had considered sites outside the green belt and that the development was contrary to local planning policy. Parents of children at the local school had said they would remove their children if the scheme went ahead.
But Mrs Hill concluded:
“I have found that there would be slight harm in terms of the living conditions of neighbouring occupiers, in terms of night-time noise, to which I give limited weight.
“However, this would not outweigh the benefits of the exploration in terms of its
potential to improve resources for energy supplies to which I give substantial
weight. On all other matters I consider that the impact is neutral overall. The
conditions following this decision would ensure the development would be
carried out in an acceptable manner.“Whilst I have found that the proposal would not comply with policy MP1(1) of
the DDMLP [Derby and Derbyshire Draft Minerals Local Plan], it would be in accordance with the other relevant policies of development plan read as a whole, especially the specific policies covering this type of development, MP13 and MP35.“In any event, the minor harm in this case is outweighed by other material considerations.”
Key issues
Green belt
The inspector said:
“The openness of the Green Belt has to be regarded in the context of its
permanence and the long-term maintenance of its existing condition. In
following the approach to considering minerals development in the Green Belt
in the legal cases of Sam Smith and Europa, I find that there would be no harm
the Green Belt. The proposal would not be inappropriate development in the
Green Belt and it would not be harmful to the openness of the Green Belt and
the purposes of including land within it. As such, it would comply with
paragraph 146 of the NPPF [National Planning Policy Framework]”.
Night-time noise
The inspector said:
“I conclude that there would be minor harm from the proposed
development to the living conditions of neighbouring occupiers in terms of
night-time noise, due to the likelihood of complaint. This would be contrary to
policy MP1(1) of the Derby and Derbyshire Minerals Local Plan (DDMLP) which
concerns noise.
But she said it would be possible to control overall noise levels to those set out in minerals planning guidance and she gave “significant weight” to this.
Traffic
The inspector concluded the proposal would have no harmful impact on the safety and convenience of users of the highway network and the proposed access route.
Other issues
On seismicity and old mine workings, Mrs Hill concluded:
“Although the appellant [Ineos] considers that the likelihood of the risk of any seismic effect is low, there are adequate procedures in place to deal with such an
eventuality.“I also consider that there are sufficient measures to ensure that
the site is properly restored and not abandoned. As such, I do not consider
that the appellant should be required to insure or lodge a bond against such
events.”
She said she could not take into account the effect on house values.
The Environment Agency, Public Health England and the Health and Safety Executive would “protect human health“, the inspector said, and there was no evidence that a health impact assessment was needed.
Potential impacts from well design, construction and operation would be “adequately managed by the relevant regulatory bodies”, she added.
On landscape impacts, the inspector said there would be no permanent impact on sensitive wooded slopes and valleys nearby.
She added that air quality would be protected by the environmental permit. She also said the proposal did not breach local or national planning policies on historic environment, ecology, agricultural land or surface water.
On the local economy, the inspector said shale gas drilling at Bramleymoor Lane would “not be detrimental” to the economic strategy of the area and “would provide a small benefit in this respect”
Reaction
Ineos Upstream
Ineos Upstream, also known as Ineos Shale, tweeted this afternoon that it was pleased with the decision. It added:
“It is disappointing that a Planning Inquiry was needed for what is a straight-forward project – leading to an unjustifiable waste of public money. The permission allows for the drilling of a single vertical core well to gain scientific knowledge of what is below the surface – as has been agreed by many Councils many times in the past to support the coal industry in the region.
“Ineos Shale hopes that this case will set a precedent for timely decisions on future applications upon the facts. A fully-fledged shale industry can be a huge boost to the UK, providing jobs, investment and secure energy.”
David Kesteven, chair of Eckington Against Fracking
“I can’t tell you how saddened I am by today’s decision. I’d like to thank all the committee and everyone who comes to the public meetings and all the other anti-fracking groups for all their support. I’m sorry that we couldn’t stop them at this stage.
“But we will stop them. Fracking has no future and they will not drill at Marsh Lane.
Keep the faith. Keep strong. Keep together. Are we beaten? NO FRACKING WAY!!!!”
Lee Rowley MP for North East Derbyshire
The local Conservative MP, Lee Rowley, tweeted:
“Extremely disappointed that the Planning Inspector has allowed drilling to go ahead at Bramleymoor Lane. This decision is simply wrong. I know residents will be hugely disappointed and I share that disappointment; will review the detail properly & come back later today.”
Rebecca Long-Bailey, shadow energy secretary
“Today’s Planning inspectorate decision for exploratory fracking at Marsh Lane flies in the face of overwhelming national and local opposition to fracking. Many people remain unconvinced that the risks posed by fracking to our natural environment and the purity of our water can be addressed.
“There are also grave concerns that the aggressive championing of fracking at the same time as consistently undermining renewable energy projects shows that this Government is not serious about meeting our Paris Agreement commitments.
“Labour will ban fracking, instead committing to building our renewables sector and sourcing 60% of our energy from clean, green sources by 2030.”
Friends of the Earth
Richard Dyer, Friends of the Earth regional campaign organisers for the East Midlands said:
“This is a bitter disappointment for the local community who have worked so hard to fight this threat, and also Derbyshire County Council who opposed it, but at least local people have had a say.
“The Government’s current outrageous proposals to fast track future shale gas test drills through ‘permitted development’ rules will ride roughshod over local democracy and mean communities will be shut out of participating in decisions like this”
Woodsetts Against Fracking
The residents’ group, Woodsetts Against Fracking, which is campaigning against Ineos shale gas plans in Woodsetts, South Yorkshire, tweeted:
“Heartbreaking”
UK Onshore Oil and Gas
Charles McAllister, policy officer of the industry organisation UK Onshore Oil and Gas, tweeted: “Great news from NE Derbyshire where 96% of homes are connected to the gas grid. As only 49% of UK gas is produced domestically at present, this will be the first step to reversing a worrying trend of swelling natural gas imports”.
In a formal statement, UKOOG’s chief executive, Ken Cronin, said:
“We welcome the decision today by the Planning Inspector to grant Ineos planning permission for an exploration site at Bramleymoor Lane. This follows a successful appeal that saw thorough representation on both sides of the debate. Ultimately, the Inspector has concluded that she has given substantial weight to the potential to improve resources for energy supplies, something we strong agree is a nationally important priority.
“A planning appeal is part of the overall planning process in the UK and it is not unique to onshore oil and gas. UKOOG notes that according to DCLG databases since 2000 57% of refusals for onshore wind were appealed .”
Chris Peace, local Labour candidate
Chris Peace, Labour’s prospective parliamentary candidate for North East Derbyshire said:
“Appalling news that go ahead given for fracking exploratory drilling at Marsh Lane, NE Derbyshire. Our environment & communities playing second fiddle to big business profits & dirty energy sources.”
This post will be updated as reaction comes in
DrillOrDrop page on the Bramleymoor Lane inquiry
Link to Planning Inspectorate decision notice
Categories: Regulation
DRILL OR DROP? 
If all goes well Sir Jim Rat can increase production of unwanted plastic from his stinking Grangemouth facility.
Can anyone who doesn’t want marine life choking on plastic made from fracked gas please write to your supermarket today and demand they pledge to cut single use plastics or you will shop somewhere that will.
Then start reducing plastic in your home, Friends of the Earth have great advice. Refillable detergent bottles, going back to soap bars and using shampoo bars all help to turn the tide on plastic.
So Sir Jim throws the plastic in the ocean does he? Is it not a case of supply and demand. Get rid of the demand and the supply goes with it. Getting rid of plastic is a must however it isn’t going to happen overnight. And FOE can say what they want in the UK and make zero difference on a global scale. Another great example of Enemies of Industry…. Nearly all the ocean plastic comes down a few rivers in Asia and the Indian Sub Continent. But you already knew that, it just doesn’t fit with your anti fracking in the UK agenda.
Is it always the fault of some foreigner Paul?
“Nearly all the ocean plastic comes down a few rivers in Asia and the Indian Sub Continent.”
Prove that, then make your arguement as to how Ineos, who’s stated aim of using domestic fracked gas to increase it’s production of plastic pellets at Grangmouth, will help the global problem of plastic waste in the sea.
I hear Sir Jim lobbied hard to keep plastic bags free at the check-outs. Sustained public pressure eventually forced change, you and Sir Jim are on the wrong side of history again.
https://www.weforum.org/agenda/2018/06/90-of-plastic-polluting-our-oceans-comes-from-just-10-rivers/
“By analyzing the waste found in the rivers and surrounding landscape, researchers were able to estimate that just 10 river systems carry 90% of the plastic that ends up in the ocean.
Eight of them are in Asia: the Yangtze; Indus; Yellow; Hai He; Ganges; Pearl; Amur; Mekong; and two in Africa – the Nile and the Niger.”
Perhaps the World Economic Forum are making this up Dorkinian? I apologise for missing out Africa….
“INEOS is a significant consumer of ethane, propane, butane, naphtha and condensates. The integrated trading business enables not only provision of these feedstocks where they are needed but also financial risk management in a constantly changing market.”
No mention of methane as a feedstock:
http://essentialchemicalindustry.org/chemicals/ethene.html
https://www.chemicals-technology.com/projects/ineos-grangemouth-petrochemical-complex/
https://www.ineos.com/sites/grangemouth/about/
The amount of ethane in UK shale gas is not known until the wells are tested. However it is not likely to be as high as the MarcellusShale Wet Gas which is 75% methane, 16% ethane, 5% propane and 1% for butane, pentane, hexane and other gases.
INEOS does not throw the plastic away – consumers do. Cut the demand and the supply goes away.
No Paul, Ineos don’t throw it away they sell it, cheaply, world wide, where the pellets are made into different products some of which end up in the sea.
We also export our own plastic waste abroad and care little about what is done with it.
All of which is presumably fine by you Paul, as long Sir Jim doesn’t personally throw it in the sea?
So you stick with blaming foreigners if you choose to, I will continue supporting study and action on reducing the linear systems that turn hydrocarbons into products that are used once and then become harmful waste, often replacing perfectly adequate alternatives which could be reused or would brack down harmlessly.
Thanks for the link though, I will take a look when I’m back from my hols.
https://www.weforum.org/agenda/2018/06/90-of-plastic-polluting-our-oceans-comes-from-just-10-rivers/
“By analyzing the waste found in the rivers and surrounding landscape, researchers were able to estimate that just 10 river systems carry 90% of the plastic that ends up in the ocean.
Eight of them are in Asia: the Yangtze; Indus; Yellow; Hai He; Ganges; Pearl; Amur; Mekong; and two in Africa – the Nile and the Niger.”
Perhaps the World Economic Forum are making this up Dorkinian? I apologise for missing out Africa….
NEW PLASTIC TAX likely to be applied to businesses that produce the stuff.
DORKINIAN
Looks like the government is listening to the public on single use plastic after 162,000 responses .
Tax on ‘bad plastic’ expected to be signed off by Government to boost recycling
https://www.telegraph.co.uk/news/2018/08/17/tax-bad-plastic-expected-signed-government-boost-recycling/
Public ‘back’ taxes to tackle single-use plastic waste
https://www.bbc.co.uk/news/uk-45232167
This is good – lets hope they go through with it. But doesn’t solve the global problem and what goes into the oceans.
Jack TL
Good oh, about time too.
The tax needs to be on the user, of course, otherwise we will just import it I guess, if the tax is only on the producer in the UK.
I would hope this tax was for the right reasons, but sadly it isn’t; just another inroad to prop up the depleting coffers due to this governance’s mismanagement of our state assets, borrowing on our pension funds, selling our land, energy sources and water to offshore companies.
They’ll tax the cup first, then the coffee (now everyone is addicted) just a replacement for tobacco tax. Watch this space
One good old earthquake when Cuadrilla have another attempt at fracking Preston New Road in Lancashire then watch the whole filthy industry and their corrupt backers disappear in a cloud of radioactive dust!
Wonder what your pro-fracking posters will be saying then?
Agreed. This is pretty much all that the anti’s can hope for at this point. That even 5% of what they’ve been claiming comes true. If it turns out that the industry operates without the issues they’ve claimed then they’re going to look pretty stupid.
Peter Roberts
If the seismicity cannot be managed, then fracking will likely not be viable in the Fylde.
This has been said before here on DoD
Likewise if there is insufficient gas to make it economic ( for whatever reason ) then it is not likely to go ahead.
On the other side of the Pennines, similar challenges exist, but as the development is behind Cuadrilla, then it may be just Cuadrilla that disappear, but the companies who work for them ( drillers, mud loggers, geologists, environmentalists, waste contractors, civil engineers etc etc ) will continue to exist.
As Ineos want shale gas to make plastic at their Grangemouth petro-chemical plant and to power this,all this rubbish about gas shortages etc,show that Mrs Hill seems very lacking in the real reasons for this industry. She is very lacking in understanding all aspects of the fracking industry.Does she care?
Sue, Mrs Hill is a Planning Inspector – the clue is in the word “planning”? She dermines Appeals based on Planning Law. She doesn’t care what the gas is used for.
INEOS can also do whatever it wants with the gas. If they’re using it for plastics then that frees some for use in power generation, i.e. the two consumers won’t need to compete, i.e. a reduced pressure on upward prices. So all good.
Garry – I expect any INEOS produced gas in England will go into the grid at the nearest entry point and subject to calorific value. I thought the Grangemouth feedstock was ethane? Perhaps INEOS will find a reservoir of pure ethane in Derbyshire – but I very much doubt it.
https://www.ineos.com/news/ineos-group/ineos-signs-agreement-with-exxonmobil-chemical-limited-and-shell-chemicals-europe-bv/
Do any of you read your post before posting it. as if you did you would realise how stupid it was… eg Ineos needs shale gas to make plastic at grangemouth. Exactly How do you propose they get it there then ?
Gasman, Where do think they get it from now?
It’s all on their website.
They have to ship it across the Atlantic, which means they currently run Grangemouth plastic production at around 30% capacity, from memory.
Hope that makes more sense to you now.
“INEOS is a significant consumer of ethane, propane, butane, naphtha and condensates. The integrated trading business enables not only provision of these feedstocks where they are needed but also financial risk management in a constantly changing market.”
No mention of methane as a feedstock:
http://essentialchemicalindustry.org/chemicals/ethene.html
https://www.ineos.com/sites/grangemouth/about/
The amount of ethane in UK shale gas is not known until the wells are tested. However it is not likely to be as high as the MarcellusShale Wet Gas which is 75% methane, 16% ethane, 5% propane and 1% for butane, pentane, hexane and other gases.
INEOS does not throw the plastic away – consumers do. Cut the demand and the supply goes away.
‘Cut the demand and the supply goes away’ – hear hear
Work it people, take responsibility….
Sue Cuthert
FOE have a decent document discussing why INEOS would want frack gas, and the INEOS website likewise.
In both cases it is cheap gas ( and a secure supply ) which is the prize, with any additional feedstock a bonus.
If the gas is not cheap ( or not cheaper than the alternative ) then it will not work. Supplies of Ethane are assured from the US, but gas for power is UK produced or imported.
Rather than it being ‘ all about the plastic’, it is more likely, ‘all about the price’.
Well Dorkinian you would have had a real problem when sewage was floating in the sea on a more regular basis! A giant cork for the decades it took to stop it being put in the sea? Then, there would be an outcry concerning the decimation of the cork oaks!
Perhaps rather than squealing about plastic then the solution should be to stop it being dumped in the sea? It generates pretty good electricity if collected and utilised appropriately.
You sound just like those moaning about the removal of public toilets. One day someone will realise coffee is a diuretic and insist that prior to agreeing to more and more coffee shops in a town they make the same coffee shops pay for the “convenience” of the public? (No solution just having toilets in the coffee shops-the “impact” is not instant!)
So easy to become an anti, even when the statistics from the recent survey indicate many do without much knowledge. Bit more difficult to find solutions, but much more rewarding.
Plastic just isn’t comparable to sewage Martin. The fact that it isn’t biodegradable means it will inevitably end up in places it shouldn’t be.
I’m sorry these issuses are so hard for you to follow, everyone else who wasn’t already aware seemed to catch on when this was highlighted by David Attenborough’s Blue Planet 2.
Perhaps watching that would be a good start to help catch up with the rest of us? Otherwise you will continue to sound like Rip Van Winkle,
Twelve million tons (and rising) of plastic waste ends up in the sea every year with devastating effects on marine life. We need less single use plastic, not new sources of the raw materials for it.
I won’t apologise for caring about marine species in decline and facing extinction, if that sounds like squealing and moaning to you Martin, you should perhaps stick to The Daily Mail or similar where you may find more like minded individuals.
[Typo edited at poster’s request]
……………CLIMATE CHANGE…………..
TAKE A LOOK at what they’ve found in the MELTED SWISS ALPS .
Second World War plane found after 72 years as heatwave melts Swiss snow
https://www.telegraph.co.uk/news/2018/08/14/second-world-war-plane-found-72-years-heatwave-melts-swiss-snow/amp/
Yes, Jack, and the locals in Siberia make lots of money when the mammoth tusks are discovered as the ice melts.
BUT-how come they were there before the ice???? Hmmm-this climate change seems to have been coming and going for some little time, without any impact from humans. Equally, as the ice melts in Greenland and plant seeds are found under the ice, how come they were there?
No links-just information. You can do your own research. Not quite as selective, but knowledge shouldn’t be.
MARTIN
Now we all know that the process of Fracking uses a LOT of ENERGY .
You could say it takes a lot of energy to extract a little … Thus adding MORE greenhouse gases in to the atmosphere .
Taking note of the above ……..do you have any ideas as to what we should be telling the people of Devon and Cornwall, as they may be the first to be hardest hit in the UK by Climate Change ????
UK tsunami WARNING: Devon and Cornwall hit with alert – ‘worst-case prediction NOT ENOUGH
https://www.express.co.uk/news/uk/1004102/Uk-tsunami-warning-devon-cornwall-shock-alert-weather-latest
“Jackie, Devon – ×
Probably more likely to be killed by a lightening strike rather than a tsunami in Devon. More pointless scare stories.”
Comment below your linked article Jack. Sums it up….
Not a lot of fossil fuel climate change in 1014…. And the Daily Express. Tut tut.
Ahh Martin, you’ve come out have you? I’d long suspected you were a climate change denier.
So you believe that all the most qualified climate change scientists, the very best in their fields, didn’t think to allow for natural trends when they concluded that modern climate change is man made?
Whereas you, pluckily using nothing but your own common sense have it solved iwithout needing all those years of peer reviewed research! 🤣🤣🤣
Seriously though, on shore unconventional extraction only really begins to make sense to nutty CC deniers (and/ or greedy opportunists / sociopaths.
Anyone else that understands what is happening is aghast that we can sign an agreement effectively agreeing to leave 80% of existing hydrocarbon discoveries in the ground whilst also accelerating unconventional exploration.
Excellent news! A decsion definitely in the national interest. Also, interesting that this BBC Radio 4 programme broadcasted today covered some of the issues around controversial planning decisions. I thought it a well balanced account. It even covers opposition to a renewable energy infrastructure planning proposal. https://www.bbc.co.uk/programmes/b0bf7n9s
but not fracking?
Jack, nice to see you are concerned about the good people of Cornwall!
Shame you have only just adopted that concern. It wasn’t too evident when the Swansea Lagoon was being discussed and it was convenient to ignore the good people of Cornwall who were expected to see a big chunk of the Lizard blown up to produce the blocks for construction. Then “local democracy” was not so important and the locals objections could be ignored, and my favorite ice-cream sacrificed. Hmmm.
Ahh Dorkinian, that’s the problem only posting during the holidays-you miss everything else in between. But good you concentrate upon your education.
You might have observed several posts of mine agreeing that climate change is occurring, but reminding the easily excited that it has been occurring for as long as this planet has existed and that context needs to be considered, not ignored or rejected.
Equally, that replacing imported fossil fuel with UK fossil fuel does absolutely nothing to increase emissions, but actually reduces them. It also offers GREATER opportunity via taxation income to develop alternative energy sources (see the Norwegian experience.)
Additionally, that plastic can be kept out of the sea, like sewage, removing the problem from the sea and dealing with it on land-which is technically pretty easy. (Plastic can produce electricity quite effectively. Mine does.) The curry houses were not taxed or closed to deal with sewage in the marine environment. That would have been populist nonsense without answering the question, but it seems that is what is “liked” in the Internet age-instant “solutions” plus an Emoji which are instant but not solutions.
Hi Martin,
My point is that the historical context has been carefully considered and the clear academic consensus is that present climate change is man made and avoidable.
If you deny this and say modern climate change is a natural occurrence, as you seem too, you will be labelled a climate change denier.
On your other point you may be surprised to hear that domestic fracked gas will have a higher carbon footprint than imported conventional gas, due to the intensive energy that is always needed to extract hydrocarbons from unconventional rock, plus the energy required to move and dispose of the produced water which must be evaporated and the various pollutants, including NORMs, removed and disposed of safely.
As if this wasn’t bad enough, it gets worse when we take into account the warming effect of fugitive emissions of methane- the American EA (the EPA) calculate these are 240 times higher in a US fracked well than in a conventional gas well (and the US shale boom corresponds with a spike in the temperature change graph thought to be caused by the powerful warming effects of these methane emissions). We can expect this rate to be worse still in the UK due to the extensive faulting here.
In summary that argument doesn’t add up, please stop using it.
Dorkian
Howarth and Ingraffea calculated 40-60% more fugitive emissions from fracked wells, so an increase in their figure by 300-500% looks interesting, given that their assumptions have been contested. Have you a link for the 240% figure?
The bulk of the increase they link to methane venting during frack flowback ( into pits in some cases in the US ).
Re the need to evaporate frack water, I see no plans to do this in the UK via open pits ( more likely to fill with water? ) and while we await news on how the Preston Road frack fluid will be treated, it seems that evaporation by boiling off the water, is not planned.
Hawes62
This from a document prepared for the purposes of Congressional oversight;
“According to EPA analysis, natural gas well completions involving hydraulic fracturing vent approximately 230 times more natural gas and volatile organic compounds than natural gas well completions that do not involve hydraulic fracturing” Source Oil and gas: Information on Shale Resources, Development, and Environmental and Public Health Risks, U.S. Government Accountability Office, September 2012 p.35 [see:]
https://www.gao.gov/assets/650/647791.pdf#page36
Also search for “fugitive emissions” within the following pdf for what effect these emissions have on climate change (only 6 references come up, at least a couple are very relevant and worth checking- I’m on 4g here in Galicia and onto the Talisker now so won’t cut and paste them);
Click to access Fracking_Science_Compendium_5FINAL.pdf
This from a wastewater treatment specialist
http://www.after-oil.co.uk/fracking_wastewater.htm
Thanks for asking Hawes, hope you find them interesting. On the emissions, it’s clearly very hard to estimate this hence the discrepancies, but an additional issue in the UK with our extensive faulting, but thats another link. 🙂
[typo corrected at poster’s request]