Major plans for oil and gas production in East Yorkshire are “fundamentally flawed and should be refused”, experts said today.
Rathlin Energy is seeking permission to more than triple the size of its West Newton-A site north of Hull, drill a further six wells and produce hydrocarbons for up to 20 years.
But a 78-page report published today has concluded that the company’s planning application had “significant inadequacies”, including missing documents, flawed assessments and insufficient information.
The scheme would also be “wholly contrary” to the government’s aim to reduce greenhouse gas emissions to net zero by 2050, the document concluded.
The report, by KVA Planning Consultancy, was commissioned by the local campaign group, Fossil Free East Yorkshire.
The document said the application failed to comply with national or local planning policies and more information was needed to address key concerns:
- Unsafe or unsuitable traffic routes to the site
- Detrimental impact on landscape from the proposal and other sites nearby
- Detrimental impact of noise on nearby homes
- Climate change impact
Fossil Free East Yorkshire said today:
“It is quite clear from the frightening increase in news reports detailing the climate catastrophe that we need to stop burning fossil fuels for our very survival – and stop drilling for more.
“The head of the UN says so, the International Energy Agency says so, and UK government policy says so. And yet here is a Planning Application for major new oil drilling right here in East Yorkshire.
“Now this report, by independent planning consultants, exposes just how flawed and incomplete this Planning Application is, especially when it comes to the huge increase in traffic, and spells out exactly how and why it should be refused.
“We hope East Riding Planning Committee will pay due attention and refuse the Planning Application.”
Major onshore oil and gas proposal
Rathlin’s application is the largest individual proposal for onshore oil and gas to go through the planning system for at least eight years.
The site would be enlarged from the existing area of 0.84ha to approximately 3.46ha.
The scheme plans multiple phases of work over 25 years, from testing the site’s existing two wells to the extension work, drilling, treating and testing new wells, followed by oil and gas production, decommissioning and restoration.
The expected equipment needed on the site would include a 55m drilling rig, 35m workover rig and, or, 25m coiled tubing unit, 60m crane, 12.5m gas flare, 15m generators, 10m storage tanks, 15m conductor rig, welfare and office buildings and 9m lighting columns.
The enlarged wellsite would be surrounded by 3m earth mounds planted with native woodland. A 2.4m security fence would be around the perimeter. There would also be a new entrance off Fosham Road, 160m east of the existing entrance on Pipers Lane.
DrillOrDrop reported on the planning application in July 2021 (click for link)
Traffic routes “neither safe nor suitable”
Fossil Free East Yorkshire (FFEY) estimated that constructing and servicing the West Newton-A site would lead to 17,000 journeys by heavy goods vehicles (HGVs).
Once production began, oil would be transported by road tanker to a refinery, probably in North Lincolnshire. The initial application estimated this would result in 25 trips a day, seven days a week. But Rathlin later said it would reduce daily tanker visits in response to local concerns.
The FFEY report said the proposals did not provide “safe and suitable access to the site” and so failed to comply with local planning policy and the tests set out in the National Planning Policy Framework (NPPF).
There was no thorough transport assessment, no traffic management plan and a failure to consider vulnerable road users, the report said.
“There is a significant lack of information in the applicant’s TA [transport assessment] to rule out a potential conflict between vehicular movements associated with the site and other road users and as such the proposal should be refused in line with paragraph 111 of the Framework (NPPF).”
The application proposed two routes (blue and orange), taking lorries through the villages of Sproatley and Bilton and past Burton Constable Hall, an Elizabethan country house open to the public.
But the report said some stretches of the route were less than 3m wide, when at least 6.8m was needed for large articulated lorries to pass safely.
The report also highlighted poor visibility on bends, likely presence of vulnerable road users, unsuitability of the routes for convoys, conflicts with Burton Constable traffic, a lack of a holding area for large vehicles and no proposed control over vehicle movements at dusk.
The report criticised the failure of the application’s transport assessment to consider properly the impact of lorries on pedestrians, cyclists and horse riders, including users of nearby public rights of way and the Trans Pennine and Hornsea Rail Trails.
It also criticised the lack of swept path analysis to show the likelihood of conflict between vehicles on the route.
“Significant harm to landscape”
Rathlin Energy’s application said it had “not identified any notable landscape or visual effects that would justify a refusal in planning permission”. It said the proposal complied with a local policy that promoted “high-quality landscape”.
The company also said other energy infrastructure, such as Withernwick Wind Farm mand Tansterne biomass plant, justified the West Newton-A application.
The FFEY report said:
“Simply because other infrastructure and developments exist, is not reason to approve further schemes in the area, especially should the landscape be at risk of overindustrialisation.”
It rejected the company’s conclusion on landscape impact:
“Fossil Free East Yorkshire ultimately consider that the proposals will cause significant harm to the landscape in this part of East Riding, especially in combination with other major developed sites, and this is not in conformity with national or local planning policies and should be refused.”
The report said the company’s landscape and visual assessment had “some significant omissions”, there was “simply insufficient information and assessment” and the conclusion was “fundamentally flawed”.
The assessment of tall infrastructure considered only the 55m drilling rig, when all tall structures should be considered, the report said.
It was untrue, the report said, for Rathlin Energy to conclude that smaller size equipment required during production would be less intrusive than during drilling. Regular well maintenance, repair and checks on eight boreholes would mean tall equipment was likely to be on site frequently, the report said.
The report also argued that it was factually incorrect of the company to argue that the “degree of change [from the drilling rig] would be lessened” by the Withernwick Wind Farm turbines and the Tanstern biomass plant.
“There is no evidence this has been assessed to reach this conclusion”, the report said.
Other criticisms of the landscape assessment included
- Subjective and qualitative assessments
- Missing methodology
- Photo montages not showing worst case scenarios of multiple high infrastructure on site at the same time
- 3km study area for the assessment – with no explanation – so that it excluded the Tanstern biomass plant
- No assessment of the site in combination with Withernwick Windfarm 1.9km away
- No cumulative assessment of West Newton-A, the windfarm and biomass plant
- An implication that the site would be restored after two years
- No consideration to proposed development at West Newton-B
- No assessment of impact on pedestrians, dog walkers, cyclists and horse riders
- No best and most versatile land assessment, as requested by East Riding of Yorkshire Council
- Insufficient mitigation of landscape effects, including “visually recessive colour” for structures and equipment and proposals to minimise lighting glare
“Noise disturbance could be significant”
Planning law requires noise from a site to be reduced “to a minimum” to avoid “significant adverse impacts on health and quality of life”.
Fossil Free Yorkshire said:
“the potential detrimental harm to the nearest receptors, by way of noise disturbance to their health and quality of life, could be significant and the proposal should subsequently be refused as contrary to both national and local planning policy.”
Rathlin Energy has proposed a bund or hoarding around the nearest home to the site to reduce noise. But the Fossil Free East Yorkshire report said this could result in a feeling of “forced enclosure”. Other homes should be considered for further mitigation, the report said.
It added that the company should prove it had reduced noise to a minimum and give evidence of any burden to further reduction.
Fossil fuel extraction “wholly inappropriate”
Fossil Free East Yorkshire said:
“the development of a new fossil fuel extraction site is wholly inappropriate and [we] cannot comprehend how the proposed development of this oil production site would fit with statutory commitments to decarbonise the economy.
The report said the mineral planning authority at East Riding of Yorkshire Council should consider the global and local impact of a new fossil fuel extraction site.
It said this was particularly important because the site was relatively close to the Humber where carbon emissions were reported to be the highest per resident across the country, at 13.9 tonnes, more than twice the national average.
Fracking: The application for West Newton-A does not include high volume hydraulic fracturing (HVHF). Fossil Free East Yorkshire said the oil at the site could be accessed by an acid wash, matrix acidisation and low volume hydraulic fracturing. HVHF is often undertaken at greater depth but the environmental impact can be similar to low volume fracking, the organisation said.
Other regulators: “the mineral planning authority should absolutely be satisfied that these regimes will work effectively and not simply assume that they will. … it is incumbent on the MPA to adequately assess the proposals to ensure their satisfaction prior to determination.” Rathlin Energy has not applied for an environmental permit application for the West Newton-A proposals.
Biodiversity: no metric in the application to measure whether there would be a net gain for biodiversity, as required by national planning policy. Returning the site to arable would not provide a measurable net gain, the report said.
Missing documents: The report said the application did not include a construction environmental management plan, biodiversity assessment or biodiversity enhancement and management plan, despite a request from the council.
Heritage impact: The company’s heritage impact assessment has not recognised the impact of increased vehicle movements in front of Burton Constable Hall.
- The KVA Planning Consultancy has previously assessed applications for oil and gas proposals at Kirby Misperton (North Yorkshire), Grange Road (Lancashire), Preston New Road and Roseacre (Lancashire), Wressle 1A Well (Northern Lincolnshire), Marsh Lane (Derbyshire), Woodsetts (Rotherham), Biscathorpe (Lincolnshire) and Great Altcar (Lancashire).