Government is consulting on the creation of a fund to ensure that local communities where shale gas is being extracted (“fracking”) benefit from that activity. The Society has responded to the consultation as follows:
These are the comments of the South Downs Society, the national park society for the South Downs National Park.
The Society has nearly 2,000 members and its focus is campaigning for the conservation and enhancement of the special qualities of the national park and their quiet enjoyment. Our comments will reflect this focus.
We note an emphasis in the consultation on the role of shale gas in regional development and the wish (para 1.19) to “rebalance growth across the regions”. The need for such a rebalancing is clearly less in evidence in the south east, unless it is intended to suggest that this region be accordingly afforded lower priority in pressures for exploitation.
We query what is intended by the expression (para 3.3) “shale sites themselves are small, with a lesser visual impact than many other forms of development.” It is our understanding that the visual impact – as well as aural, disturbance, aerial and subterranean impacts – will be considerable, and significantly greater than for conventional fossil fuel exploitation, owing in part to an increased number and frequency of wellheads.
We address below the consultation questions on which we wish to express a view.
Consultation Question 1: Do you think that providing opportunities for both local and regional investments are the right priorities for the Shale Wealth Fund?
Yes. While residents and others may be affected locally by visual and other impacts and traffic, there may be regional impacts such as effects on aquifers (notwithstanding government assurances) and the tourist economy.
Consultation Question 2: Do you agree that a more local level should receive revenues before a more regional level (establishing the ‘trickle up’ principle)?
No. This may provide an undesirable incentive to some local communities to seek to outweigh any genuine planning and environmental concerns with money or investment. Planning decisions should not be made on those lines. This seems less likely to happen at regional level.
Consultation Question 4: Should the government retain flexibility regarding the proportion of funding between delivering benefits at local and regional levels, to enable learning from the industry pilot schemes and once the magnitude of shale revenues becomes clearer?
Consultation Question 5: Do you have views on how the “local community” to a shale site should be defined for the purposes of the Shale Wealth Fund?
The community should be defined to include those likely to be affected by activities associated with extraction, such as lorry movements, as well as those directly affected by a drilling site by living close by.
Consultation Question 6: Do you agree that the “local community” should be defined on a case-by case basis?
Consultation Question 7: Do you think a set of principles should be developed to ensure consistency of approach for different shale developments?
Consultation Question 9: Do you agree that at a local level, it should be for local people to determine how the Shale Wealth Fund is spent?
While local people should be involved in the decision making, there should be objectives or criteria set for the funding to ensure it is used to compensate for the full range of impacts from fracking, including allocating to projects which improve the natural environment under threat.
Consultation Question 11: At the local level, should expenditure from the Shale Wealth Fund be subject to any ring-fences for a specific purpose? If so, should these be locally or centrally determined, and do you have views on what they should be?
A significant part of any extraction could take place beneath the South Downs National Park despite robust arguments having been made against that. If so, given the national park statutory purposes of conservation, understanding and enjoyment, it would be appropriate not only to compensate local communities but also recreational users of those parts of the park affected by fracking related activities, either beneath, within or close to the park. This would indicate a need for part of the fund within a national park to be ring-fenced to provide environmental enhancements and improved access, preferably to be allocated by the national park authority.
Consultation Question 12: At the local level, would an appropriate use of the Shale Wealth Fund be to make direct payments to households?
No. Other than, say, compensation for subsidence, other physical damage or blight – which should presumably be handled separately – it would be inappropriate for individual householders to be incentivised to overcome any legitimate concerns they may have about the proposed activity in order to unbalance the consideration of proper planning issues.
Consultation Question 14: How can the government ensure that decisions are as directly influenced by local residents as possible?
By affording more scope for local planning authorities (the traditional and democratically accountable mechanism) to consider the full range of potential effects of any proposal including aerial and subterranean impacts; and by discouraging ministers and planning inspectors from overruling the planning decisions made.
Consultation Question 16: What kind of investments do you think should be made from a regional level of the Shale Wealth Fund?
It would be appropriate to include investment in the natural environment and reductions in carbon emissions to compensate for the negative impacts of fracking including climate change.
Consultation Question 17: Do you think a regional level of the Shale Wealth Fund should be administered by direct grants to specific organisations, or through an open bidding process? How can the views of residents across the regions be best taken into account?
We would support an open bidding process, enabling environmental organisations like ourselves, as well as community groups, to apply for funding. If it were decided to allocate funds direct to specific organisations, that should include the national park authorities where they have planning responsibilities for any areas affected by fracking and associated activity.
Consultation Question 18: Do you have views on how a regional level of the Shale Wealth Fund should be governed? Are there existing regional organisations, or local or national governance structures that would be particularly suited to oversight of such a fund?
National park authorities should be responsible for, or at least involved in, the governance of any fund disbursed in a national park.
Click on this link for the consultation paper and full list of questions: