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NSIP Consultation Guidelines

This information will help you respond to the government consultation on whether to include shale gas production projects in the Nationally Significant Infrastructure Project (NSIP) regime under the Planning Act 2008. If designated as NSIP, fracking proposals would go through a national planning process that would reduce local jurisdiction, and the final decision would be taken by the Secretary of State and the Planning Inspectorate, not locally elected councils. Click this link to download your copy. (The full text is published below)

DOWNLOAD OUR NSIP CONSULTATION GUIDELINES HERE
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Full text here.

 

NSIP CONSULTATION GUIDELINES

This information will help you respond to the government consultation on whether to include shale gas production projects in the Nationally Significant Infrastructure Project (NSIP) regime under the Planning Act 2008. If designated as NSIP, fracking proposals would go through a national planning process that would reduce local jurisdiction, and the final decision would be taken by the Secretary of State and the Planning Inspectorate, not locally elected councils.  

Here is the home page for this consultation. We also recommend that before beginning your response, you take a few minutes to read the government guidelines to this consultation, which provides background on the proposal (from the government's point of view).

HOW TO SUBMIT YOUR RESPONSE TO THE CONSULTATION  

The government is keen for everyone to respond to the consultation online, which you can do by clicking here or by cutting and pasting this link into your browser: https://beisgovuk.citizenspace.com/energy-development/nsip-shale-gas/consultation/intro/

Alternatively, you can send your response to the following email address. There isn't a downloadable form this time, so you can write your own response, as long as you answer the questions in the online form. The government advice here is that "Your response will be most useful if it is framed in direct response to the questions posed, though further comments and evidence are also welcome."

You can email your response as an attachment to this address: shalegas.NSIP@beis.gov.uk

Or post it to the following address:

Oil and Gas Exploration and Production Team

Department for Business, Energy & Industrial Strategy

Orchard 2, 3rd floor

1 Victoria Street

London

SW1H 0ET

The deadline for this consultation is 11.45 pm on Thursday 25th October 2018.

CONSULTATION RESPONSE GUIDELINES

Firstly, don't forget to complete your answers on the online form.

QUESTION 1

The first question is: Do you agree with the proposal to include major shale gas production projects in the Nationally Significant Infrastructure Project regime?  

We recommend that you answer No.

QUESTION 2

The next question asks: "Please provide any relevant evidence to support your response to Question 1." This is followed by a box where you can write your answers, and you can also upload supporting documents in .doc, .docx, .odt, .odm or .pdf formats.

So, this is your opportunity to argue against the proposal of fracking production to become an Nationally Significant Infrastructure Project. Here are some points you can make, and of course please feel free to add your own.

  • The proposal that fracking production should become part of the NSIP regime would take decisions out of the hands of communities and bypass local authorities, and place these decisions in the hands of the Secretary of State and the government appointed Planning Expectorate. This would result in centralisation of the decision-making process at the expense of local democracy, and would be completely contrary to the government's commitment to support local decisionmaking.
  • The Guidelines for this consultation say: "Local communities must be fully involved in planning decisions and any shale planning application – whether decided by councils or government." (Page 6). This is in direct contradiction to the aim of the consultation itself, which would leave local communities on the sidelines when major fracking decisions are taken by central government.
  • Declaring shale gas production projects to be NSIPs would deprive local authorities of any direct decision-making role in relation to such projects. This would be an affront to local democracy that would result in the industrialisation of the countryside against the wishes of communities, councils and the country as a whole.
  • I am in full agreement with The Housing, Communities and Local Government Select Committee report "Planning Guidance on Fracking", published on 5th, July, which says that: "Fracking planning applications should not be brought under the NSIP regime. While we note that the NSIP regime does provide opportunities for consultation with Mineral Planning Authorities and local communities, such a move could be perceived as a significant loss to local decision-making. Mineral Planning Authorities are best placed to understand their local area and consider how fracking can best take place in their local communities. (Paragraph 83)
  • Research by Professor Calvin Jones at the Cardiff Business School (see here) concluded that, in the most likely scenario, we would need to drill one new well every day for 15 years just to replace half of UK gas imports for 20121-2035 with fracked shale gas. This would mean 6,100 wells stretching across the English countryside, requiring at least 3,500 hectares of land. If productivity is at the lower range of possibility, that figure rises to 9,600 hectares - which would mean more than 13,000 football pitches of our countryside handed over to the fracking industry. This would result in nothing less than the industrialisation of our countryside, to which I am strongly opposed.
  • Bringing fracking into the NSIP regime would undermine the UK's domestic and international climate change commitments by encouraging wide scale extraction of oil and gas, at a time when we need to be moving rapidly towards clean renewable energy.

You can also add any comments explaining why you are opposed to fracking in general - for example, its impact on health, water, climate change and the amount of traffic, noise and air pollution is creates - and upload any documents you think will support your arguments.

QUESTION 3

This question asks: "If you consider that major shale gas production projects should be brought into the Nationally Significant Infrastructure Project regime, which criteria should be used to indicate a nationally significant project with regards to shale gas production?"

You are then asked: "Please select one or more from the options below, or provide other criteria if applicable." ... with a range of options listed below on the form.

As you can see, this question is only directed at those who agree with the government's proposals, which is also true of the rest of the consultation. But don't go away - this is still an opportunity to add your comments and make your opinions heard.

We suggest here that you don't tick any of the options listed - as by doing so you will be supporting the idea that fracking production should in some way become an NSIP - but instead add one or more of the following comments (or your own version) in the 'Other: Please specify' box.

  • As I am strongly opposed to the principle that major shale gas production projects should be brought into the Nationally Significant Infrastructure Project regime, there are no criteria that would make this acceptable. However, the suggested criteria in this consultation clearly indicate how disruptive shale gas production would be to local communities, and how inappropriate it would be to make this an NSIP.
  • If I ticked any of the boxes in question 3, it could be interpreted as support of the principle that fracking production should become part of the NSIP regime - a principle to which I am firmly opposed.
  • There are no criteria that would make the proposal that fracking production should become part of the NSIP regime acceptable, and I reiterate my opposition to this proposal in principle.
  • Commercial fracking would require thousands of wells on hundreds of well sites, as well as associated infrastructure such as water and gas pipelines, compressor stations, lorry parks, storage facilities, gas processing plants, communications infrastructure, new roads and a huge increase in HGV traffic. This would result in the irreversible industrialisation of the countryside, and be imposed on unwilling rural communities by government-appointed planning inspectors with local people cut out of the decision-making process.
  • I also agree with Paragraph 82 of the report by The Housing, Communities and Local Government Select Committee, which states that: "There is little to be gained from bringing fracking planning applications at any stage under the NSIP regime; there is limited evidence that it would expedite the application process and such a move is likely to exacerbate existing mistrust between local communities and the fracking industry.."

QUESTION 4

Question 4 states: "Please provide any relevant evidence to support your response(s) to Question 3."

If you would like to add any comments or documents to support your answers to question 3, then this is the place to add them. Again, this is an opportunity to include any concerns you have about fracking in general if you haven't done so already.

QUESTION 5

This question asks: "At what stage should this change be introduced? For example, as soon as possible, ahead of the first anticipated production site, or when a critical mass of shale gas exploration and appraisal sites has been reached."

  • Again this assumes that you are in favour of fracking production becoming an NSIP, and is simply asking when you would like it introduced. It's a bit like asking when you would like your countryside destroyed - as soon as possible, next year, or a few years down the line. We suggest you answer this question with one of the following paragraphs (or your own version):
  • I do not think this change should ever be introduced, as I am strongly opposed to including shale gas production projects in the NSIP regime.
  • Fracking applications should be handled by regional planning authorities, who are best placed to understand the local situation and the wishes of the local communities, not imposed on them by central government decree.
  • I agree with The Housing, Communities and Local Government Select Committee, which states in its report Planning Guidance on Fracking that: "We are particularly concerned that if the NSIP regime were adopted, there would be no relationship between fracking applications and Local Plans in communities. Furthermore, we note that the Government has not provided any justification or evidence for why fracking has been singled out to be included in a national planning regime in contrast to general mineral applications."
  • There is no evidence to show why shale gas should be singled out as a candidate for fast-tracking by becoming part of the NSIP regime, as only a single well in the UK has been subjected to high pressure hydraulic fracturing (Preese Hall in 2011) – and that resulted in the industry being shut down due to safety fears. 
  • Given the widespread and growing opposition to fracking in the UK, and the impact that commercial fracking would have on the English countryside, the climate and local communities, there is no conceivable point in the future at which fracking should be included in the NSIP regime.
  • The answer to this question is 'never'.

QUESTION 6

This question asks: "Please provide any relevant evidence to support your response to Question 5."

Again, if you have any other documents to add here, then please do so.

And that's it! Don't forget to send in your responses, either online or by email/post, and please spread the word about this issue with neighbours, friends, family and colleagues. 

Also please make sure you contact your MP and local councillors to ask them to oppose this proposal.

And if you haven't done it already, please respond to the parallel consultation on whether non-hydraulic exploratory drilling for shale gas should be considered as Permitted Development (PD). To find out more about this, and for easy-to-use guidelines on how to respond to the consultation, click here.

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