Grounds for Objection – Environment and Ecology

The High Court ruled in March 2019 that paragraph 209a of the National Planning Policy Framework (NPPF) which gave strong support to onshore hydrocarbon was illegal. Its subsequent removal from the NPPF means that the planning policy system is no longer as heavily weighted in favour of the grant of planning permission for onshore hydrocarbon operations as it was before the court decision and some balance has been reintroduced.  As a result Surrey County Council must take more account of the adverse impacts the grant of this application would have on the local environment.

Hydrology – to follow

Stress on water supply
This is already a water stressed area and large numbers of new houses being built in the immediate area is going to add to that. The Applicant has not made it clear how much water its operations are going to require or where that is going to come from and whether it will be mains water or brought in by tankers.

Noise – to follow

Impact on Ancient Woodland
In The Woodland Trust’s “Planners Manual for Ancient Woodland and Veteran Trees, (the accepted guidance for buffer zones), the Trust recommends a minimum buffer of 50 metres.
As a precautionary principle, a minimum 50 metre buffer should be maintained between a development and the ancient woodland, including through the construction phase, unless the applicant can demonstrate very clearly how a smaller buffer would suffice.  A larger buffer may be required for particularly significant engineering operations, or for after-uses that generate significant disturbance.
The Applicant is only providing a buffer of 20 metres between the site and the boundary of the Ancient Woodland and it has so far failed to offer any explanation as to “how a smaller buffer would suffice”.

Light pollution – artificial lights and gas flaring
The countryside around Dunsfold is currently remarkable for the lack of light pollution blighting it.  If planning permission is granted that will change completely as during the [testing] phase the Applicant proposes 24 hour working with artificial lighting and some flaring of gas (obviously, should this become a permanent production site this impact/disruption will also become permanent). This will have a serious and detrimental impact on local residents and local wildlife (see also the section below on Bats).

Bats  
The applicant’s own Bat Survey records at 11 species of bat roosting and foraging in and around the application site including some of the UK’s rarest bats.
The Applicant states there are going to be 24 hour operations which will require artificial lighting during the hours of darkness.  There will also be some flaring of gas.  The Bat Conservation Trust says that artificial lighting is particularly detrimental to bats.
The Applicant’s Bat expert has merely recorded the presence of the various bats but otherwise completely ignored the potential impact of any of the Applicant’s activities on the local bat colonies, some of which are very sensitive to artificial lighting.