IGas Energy PLC (IGas) welcomes the opportunity to respond to the consultation on the Norfolk County Council Minerals and Waste Local Plan Preferred Options (the Plan). IGas has extensive interests in hydrocarbon production and exploration within the UK.
Summary
* IGas supports the vision and objectives of the Plan for future development and is of the view that onshore oil and gas could make a significant contribution towards achieving sustainable development by the efficient use of natural mineral resources and which would contribute to the economy.
* It is questionable whether there is a need for the Chapter and MP12 Energy Minerals and Policy MP12 given the geology of the county. However, I Gas understands why they have been included and supports the principles of such.
* IGas recommends the role of the Oil and Gas Authority is included alongside those of the Environment Agency and the Health and Safety Executive.
* IGas recommends the soles of other regulators be relied upon in accordance with national policy and guidance and criterion (c) be deleted from Policy MP12.
* IGas supports those views expressed by UKOOG in response to this consultation.

Introduction
IGas is a British company listed on the Alternative Investment Market of the London Stock Exchange. It is a leading UK onshore oil and gas exploration and production business, holding a portfolio of production and exploration assets primarily focused on three regions: the North West, East Midlands and the Weald Basin in Southern England.
The business has more than thirty years' experience of successfully and safely extracting and producing hydrocarbons onshore in the UK working closely with local communities, regulators and mineral planning authorities (MPAs). The UK is recognised globally as a leading example for oil and gas industry regulation.
IGas is committed to the protection of the environment and providing safe and healthy working conditions for its employees and contractors. It is also committed to maintaining close and responsive relationships with the communities in which it operates and has a long track record of engaging with local residents.
IGas has been operating its own Community Fund since 2008 which has, over the last decade, distributed almost £1 million to local projects that are charitable, educational or benevolent in purpose.
IGas holds a number of onshore UK licence interests in the three regions many of which it both owns and operates:
* North West: EXL273 and PEDLs 056, 145, 147, 184, 188, 189, 190,193, 293 and 295.
* East Midlands: AL009, EXL288, ML, 3,4,6 and 7, PEDLs 006, 012, 139, 140, 146,169, 200, 210, 273, 278, 305, 316, 317 and 337 and PLs162, 178,179,199 and 220.
* Weald Basin: DL002 and 004, ML 18 and 21, PEDLs 021, 070, 233, 235, 257 and 326 and PLs 182, 205, 211, 233, 240 and 249.
The East Midlands area is comprised of two primary production centres:
* Welton and Gainsborough. The Welton area is made up of six fields and a gathering centre where the produced oil, gas and water are separated. The produced oil is transported to Conoco lmmingham via road tanker; gas is used for power generation and exported to the National Grid; produced water is pumped for reinjection.
* The Gainsborough area is made up of 10 fields and a processing facility. Oil is transported to Phillips 66 via road taker, gas is piped to Gainsborough 1 for power generation and produced water is pumped for reinjection.
More recently IGas obtained planning permission in east Nottinghamshire (Misson) to develop a hydrocarbon wellsite and drill up to two exploratory boreholes with shale gas being targeted. Construction of the well pad and the drilling of a vertical well has been completed. The results of the drilling are subject to ongoing analysis but the indications are that hydraulic fracturing of the rock should be effective subject to further planning permission.
Our response to the Plan, focusses on the Vision and Strategic Objectives; Policy MP12 Conventional and unconventional oil and gas development and the supporting text; and the general development management policies.
Local Planning Policy
IGas supports the process of local plan considerations and wishes to ensure that any proposed plan with respect to onshore hydrocarbons is sound and meets with the criteria and policies outlined by Government in the NPPF (as amended), Planning Practice Guidance and related WMSs.
In particular, any policy framework which serves to significantly impede or prevent such development in areas where minerals are found and have been licensed by the Government for hydrocarbon development, will be contrary to national policy unless there is strong evidential justification.
The planning process for onshore oil and gas is one of five regulatory processes that are required under the current policy framework set by government. Planning Policy Guidance 012 and 112 make clear that mineral planning authorities are not responsible for matters covered by other regulatory regimes. It states, MPAs "should assume that these regimes will operate effectively. Whilst these issues may be put before mineral planning authorities, they should not need to carry out their own assessment as they can rely on the assessment of other regulatory bodies." This planning policy principle has been re-confirmed in a number of legal cases (see Frack Free Balcombe Residents Association v West Sussex CC 2014)1. The Plan should make the role of the regulatory bodies clear.
Comments on the Plan
IGas supports the views of UKOOG, the representative body for the UK onshore oil and gas industry, including exploration and production. IGas notes the geology of the Plan area and the fact that it is unlikely to support the presence of hydrocarbons. IGas also notes that whilst historically wells for hydrocarbons have been drilled and more recently seismic surveys carried out, there are no current PEDLs covering the Plan area and therefore no hydrocarbon development proposals could be brought forward at this moment in time. Whilst there may be a further round of onshore licences, which could include Norfolk, there is no timetable for such. It is therefore questionable whether it is necessary for a policy and supporting text for hydrocarbons to be included in the Plan. However, notwithstanding this, in the event the policy is to be retained, IGas would make the following comments in respect of the plan and those polices considered relevant to the hydrocarbon industry.
Vision and Strategic Objectives
IGas supports the Vision of the Plan. IGas supports the requirement for mineral developments to minimise their impacts on climate change and without unacceptable adverse impacts on the amenity of local communities etc. However, the vision should recognise the diversity of mineral operations and the fact that minerals can only be worked where they occur. IGas is of the view that onshore oil and gas development is compatible with this vision, specifically through the development of an adequate supply of domestic minerals under a regulatory environment superior to that of countries from which the UK imports its minerals. A domestic oil and gas supply offers significant carbon savings over fuels, which otherwise would be imported from overseas, possibly without regulatory regimes as strong as those in the UK, generating much needed local jobs in fields such as engineering and contributing to the transition towards a low carbon economy.
Presumption in favour of sustainable development
IGas supports the Council's approach to the presumption in favour of sustainable development.
Policy MW2: Development Management Criteria
The intentions of this policy are acknowledged. However, it is considered some of the information required are matters for other regulatory bodies and which is recognised in the supporting text. Consequently it is considered that matters relating to such as air quality, water resources and impacts on ground water are matters that should not be listed in the policy.
Policy MW3: Transport
The policy does not recognise or include the use of pipelines as an alternative to HGV transport. Pipelines can be used in the minerals industry, particularly the oil and gas industry, and can contribute to a reduction I the need for HGV movements. Reference to such should be included in the policy.
Policy MW4: Climate change mitigation and adaption
IGas supports the policy and the recognition that the mitigation measures required would apply to the construction and operation of sites. However, the policy does not appear to recognise that some mineral operations may be temporary, such as the exploration of hydrocarbons which could be carried out very a short period of time and therefor the generation or sourcing of energy may not be practical in such circumstance (criterion c). Whilst the intentions of the criterion are supported, provision for temporary operations should be made.
MP12: Energy minerals
IGas supports the intentions of the Chapter. However there are various points that IGas would wish to draw attention to. The 'Background' section of the chapter refers to other regulatory bodies (MP12.9 and 12.10). Whilst the Oil and Gas Authority (OGA) is referred to earlier in the Background as responsible for releasing petroleum exploration licences, it is and independent regulatory body also responsible for a variety of matters relating to the regulation of operators and operations on a site as well. It is therefore suggested the responsibilities of the OGA be included here as well as the Environment Agency (EA) and Health and Safety Executive (HSE).
MP12.28; it is important that the Mineral Planning Authority refer to national guidance, planning policy guidance and relevant Written Ministerial Statements as well as the Development Plan as a whole when considering planning applications.
MP12.30 states that 'a// applications for oil and gas developments will be considered against the Environmental Impact Assessment Regulations 2017 (EIA)'. However, it is not clear what this means. It is acknowledged that applications may be screened against the Regulations to establish the need or otherwise for EIA; if this is what the 12.30 intends then it should be made clear. Not all oil and gas development proposals will meet the criteria to be screened for EIA. Greater clarity should be provided as to what this statement means.
MP12.31 states that 'appropriate planning obligations and conditions will be sought to ensure the proposal adheres to the Development Plan'. It is important to be clear that planning permission should be granted if acceptable or can be made acceptable by the imposition of planning conditions. Planning obligations may be sought to control development out with the planning application boundary or within the highway. It is also possible that other agreements may be sought under different legislation, such as works within the highway. It is suggested MP12.31 be reviewed to make its intentions clear.
MP12.32; I Gas agrees that community engagement and close liaison with authorities is important for oil and gas developments. IGas actively engages with the community in accordance with the industry Community Charter and in accordance with mineral planning authority statements of community consultation. It is noted that the County Council adopted a Statement of Community Involvement in December 2018; it is suggested that this is referred to in MP12.32.
Policy MP12: Conventional and unconventional oil and gas development
IGas considers there to be very little difference in the exploration and appraisal stages and the production stages of conventional and unconventional oil and gas developments. It is therefore considered unnecessary to refer to 'conventional and unconventional oil and gas development' in the title of the policy. Given the wording and criterion set out in the policy, it is considered the title could simply refer to 'oil and gas development'.
(c) The integrity of the underlying geological structure is a matter for the OGA and the EA and should not be included as a planning criterion.
(f) 'completed to the satisfaction of the Mineral Planning Authority' should be deleted.
Conclusion
In conclusion, it is questionable in the circumstances whether there is a need for the Chapter and MP12 Energy Minerals and Policy MP12. However, I Gas understands why they have been included and supports the principles of such. If they are to be retained, IGas requests the above comments are taken into account as part of the next stage of the review of the Plan.
We look forward to the next stage of the process and would be pleased to discuss any of the matters raised to ensure the plan is sound or can be made sound.