Environment Agency Relevant Comment Areas.

These comments are limited to Environmental or Technical Issues or omitted information from the Application about the Site Only.
We consider the Access Road from the Main A3045 to be part of the site

If you use these suggestions and links as a guide to write your concerns PLEASE write in Your Own Words - DON’T cut and paste.

PLEASE NOTE..  YOU WILL ONLY BE ABLE TO ATTACH ONE EVIDENCE FILE TO EACH COMMENT SO CHOOSE IT WISELY!

YOU CAN SUBMIT MULTIPLE COMMENTS CONCERNING DIFFERENT ISSUES IF YOU WISH TO ATTACH FURTHER EVIDENCE FILES.


Technical Issues of the Site, Location & Techniques
· New site surveys should be undertaken prior to any development  for Bats, Dormice, Badgers as these were out of date by 2020.

 

Newchurch Moors Nature Reserve has been recognised as a Site of National Importance for scarce dragonflies by the British Dragonfly Society and rely on good quality water supplies, vegetation and flowing rivers. Air polution and contaminated dust puts this species at risk.

· Mature hedgerows/flora & soils/habitat will be removed for 2 hectare site and access, these cannot be replaced after 3 years to restore site to original condition with extra ecological value as claimed.

· New  2D or 3D seismic surveys not undertaken by UKOG despite these being a condition by the OGA of the purchase of the PEDL Licence. 
(Link)

· Before any permit is granted, UKOG must provide up-to-date detailed contour maps and cross sections of the areas it proposes to drill through, including the paths of the exploration well and sidetrack well. New seismic analysis should be undertaken to validate these,  since current plans for Arreton are proven  be outdated and inaccurate.(Link)

· Outdated Geological survey data used in application & is incomplete and proven inaccurate (Link)

· Horizontal drilling of appraisal under homes and businesses direction is not accurate or clarified and there is missing strata fault data  ( Link )

· Studies by structural geologists and the history of erosion and small seismic shifts on the Island have shown that our local faults are critically stressed, and tiny changes in pressure are likely to cause earthquakes.  Because this could pollute groundwater the EA should regulate this issue. (Link)

· Concerns over the adequacy of the inclined curving access track and swept path analysis undertaken (Link). 


· Access track has no impermeable membrane, only compacted aggregate – flooding from main site/spills will pollute land/water  with any discharged fluids from tanker leakage , HGV/accident  will enter strata above our major aquifer. 


· Possible  damage to impermeable liner on well pad as not covered by concrete – only crushed rock which could perforate  the liner  through compression by multiple HGV and other large vehicle manoeuvres allowing migration route for contaminated fluids to leak into the substrata from the well pad.


· Ecological - damage/ water pollution from HGV carrying hazardous chemicals or contaminated waste fluids from the well bore accidents/miscalculated entry/egress on track


• There are no water monitoring boreholes around the site to create a baseline prior to drilling and to help track any possible accidental pollution of groundwater sources.


• UKOG considers that it does not require a groundwater permit.  It admits it will use hydrochloric acid at 15% concentration for wellbore operations. There is a loophole in our regulatory system which fails to distinguish between acid wash (a weak 5% acid solution that cleans the well bore at low pressure) and stimulation (hydrochloric acid at higher pressure and often at higher concentration).  A groundwater permit should be required at Arreton as a precautionary measure.
 


Air Pollution and Emissions and Health
· Additional Greenhouse Gas increase from the site activity is estimated  be over 24 thousand tons CO2 equivalent in the 86 week period – The average household annual emissions are between 15 and 20 tons CO2 equivalent . This is only an estimation!  (Links)

Can this be trusted since the Applicant’s Community Brochure quoted it would be between 10,000 and 15,000 tons CO2 equivalent (Link)


· The CCC has recommended action to achieve net zero emissions by 2030. The Environment Agency should require a full reassessment of the likely additional greenhouse gas emissions from all aspects of operations for this application -  not only at the site, but also the emissions across the Island from over 6000 additional HGVs  over the 86 week period,   travelling to and  from the site.   Which other independent  authority will undertake to do this to evaluate the impacts of this activity if not the EA? (Link)


· The International Energy Agency has published a report in which it clearly states “There is no need for investment in new fossil fuel supply in our net zero pathway. Beyond projects already committed as of 2021, there are no new oil and gas fields approved for development in our pathway, and no new coal mines or mine extensions are required.” (link)

 · Site will increase local air pollution added to current traffic flow idling due to delays, traffic queues – access and egress of over 6000 HGV and site vehicles. (Links)


· School and homes are in proximity and direct wind direction path of admitted site air pollutants which are a greater health risk to infants ( Links)


· Shrouded flares in proximity (300+ metres)to the Biogas plant which stores gas and also vents excess gas. Impacts of a major explosive or fire accident at the site and its possible impact on the Biodigestor which  has not been registered with the Health and Safety Executive as a hazardous site.  

Risks and Financial Remuneration
• There should be air quality monitors  around the site and in the locality downwind to Arreton to record  rates of increase of air pollution to confirm those estimated by UKOG over the 86 week period. Who will pay? It should be the Applicant.


• There should be financial bonds in place to ensure that costs of decommissioning of the site will be fully covered by the Applicant.


• There should be a financial risk analysis of the costs of  accidental pollution of the aquifer and surface water resources to be paid by the Applicant as  remuneration for the lifetime supply of water to the Island by Southern Water.