Diagram of simple schematic of shale gas production

Habitat Regulations Assessment 14th Onshore and Gas Licensing Round Consultation Question 2

Q. Do you have any comments on the assessments carried out for individual licence Blocks? (You may wish to comment on more than one Block.) Please provide the reference for the Block you are commenting on (e.g. SD26a ).

Thank you for the opportunity to comment on the Habitat Regulations Assessment carried out for the 14th onshore oil and gas licensing round, with specific reference to fracking. Wiltshire Wildlife Trust have specific comments to make with respect to the following individual licence blocks; ST84, ST85, ST94 and ST95. We welcome and agree with the assessment in all cases that Stage B, C and D activities will be prohibited at or near the surface within the boundaries of all European sites in these licence blocks. With reference to each block we have the additional comments.

ST84. We do not agree that it can be concluded that Stage A, B, C and D activities undertaken at depth are not considered likely to result in adverse effect on integrity (AEOI), with respect to the River Avon SAC. Any sub-surface activity which threatens the integrity of the underground aquifer which provides fresh water to the chalk streams of the River Avon SAC must be considered to be a threat to the favourable condition of the site. It has been shown directly in recent years that the chalk streams are vulnerable to climate change impacts, with low flows and in stream temperature increases recorded as having an impact on wildlife. This vulnerable ecosystem cannot tolerate the additional water resource requirement to service fracking activity. We are also concerned about the potential impacts of pollution, both to the river and the aquifer through drilling activity, and also through surface water run-off localised to drilling sites.

ST85. For the same reasons we do not agree that it can be concluded that Stage A, B, C and D activities undertaken at depth are not considered likely to result in no adverse effect on integrity (AEOI), with respect to the River Avon SAC within this licence block.

In addition it cannot necessarily be concluded that Stage A, B, C and D activities have no AEOI on the Bath and Bradford-on-Avon Bats SAC. It has been proven in recent years that the population of the European protected species Bechstein’s bat (Myotis bechsteini) linked to the Bath and Bradford-on-Avon Bats SAC is active, resident and breeding within ancient woodlands within this licence block. In particular at Green Lane and Biss Woods Nature Reserves owned by the Trust.

ST94. We have the same views for ST94 as indicated above for ST84. It appears from the map Figure 1 ST94, that approximately 75% of this licence block comprises Salisbury Plain SPA and SAC and the River Avon SAC. Once again to be contemplating drilling activities in this block would appear to directly impact on the integrity of the fresh water resource held within the chalk aquifer. We raise concerns here about the impact on the wildlife of the designated River Avon SAC, alongside the potential contamination of the water supply used for human consumption.

ST95. Once again we do not agree that it can be concluded that Stage A, B, C and D activities undertaken at depth are not considered likely to result in no adverse impact on integrity (AEOI), with respect to the River Avon SAC.

The United Kingdom holds 85% of the world’s chalk stream habitat, which translates to 161 chalk rivers found across England. The River Avon is the richest most biodiverse of these rivers in the United Kingdom, and clearly by virtue of the global scarcity of such habitats must be considered be too precious to put at risk from the activities associated with fracking.

In addition to the above the Trust takes the view that investment in renewable energy sources is a far more appropriate mechanism for meeting our long term energy needs. The Trust supports moves towards reducing the demand on fossil fuels for meeting our energy needs due to the established detrimental climate change impacts of continuing to burn fossil fuels.

For more information see:

www.wildlifetrusts.org/Fracking

www.gov.uk/government/consultations/habitats-regulations-assessments-of-14th-onshore-oil-and-gas-licensing-round