UKOOG is the representative body for the UK onshore oil and gas industry, including exploration and production.
We support the process of local plan making and want to ensure that any proposed plan with respect to onshore oil and gas is sound and meets with the criteria and policies outlined by Government in the NPPF, Planning Practice Guidance and related Written Ministerial Statements. In our view, minerals plans should establish clear criteria-based policies against which proposals can be transparently assessed on a case by case basis.
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. Our view is that minerals plans should include a review of each regulatory function and identify those areas which fall outside of the planning process. PPG 012 and PPG 112 make clear that planning authorities are not responsible for matters covered by other regulatory regimes. 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 including; Frack Free Balcombe Residents Association v West Sussex CC 2014.

Our comments on draft plan are as follows:
Vision and Strategic Objectives
UKOOG supports the vision of the minerals and waste plan. We agree with the need to minimise the impacts of onshore oil and gas developments, while ensuring no unacceptable adverse impacts on the amenity of local communities. The plan area is not covered under the latest Petroleum Exploration and Development License (PEDL) round as it was not identified as a region of interest for onshore oil and gas operators.
By developing onshore oil and gas - the UK can reduce the carbon footprint of the fuel consumed by homes and businesses and improve the UK's energy security by strengthening supply resilience in the advent of disturbance to supply.
Policy MW4: Climate Change Policy and adaption
UKOOG supports MW4 and its recognition that the mitigation measures required would apply to onshore oil and gas sites. However, the plan does not take into account the fact that onshore oil and gas sites are temporary uses of land, with drilling, workover or stimulation activities representing a small period over the life of the site. Therefore, the generation or sourcing of energy may not be practical in such circumstances (criterion c).
MP 12: Energy Minerals
MP 12:28: It is important that the Minerals Planning Authority refer to national guidance, planning policy guidance and relevant written ministerial statements as well as the development plan when considering applications.
MP12.30 states that 'all applications for oil and gas developments will be considered against the Environmental Impact Assessment Regulations 2017'. This statement requires clarification because not all onshore oil and gas sites will fall under the scope of requiring an EIA.
MP 12 also states that applications should:
e. 'includes a full appraisal programme for the oil and/or gas resource, completed to the satisfaction of the Mineral Planning Authority; and
f. includes a development framework for the site, incorporating or supplemented by justification for the number and extent of the proposed production facilities and an assessment of the proposal's economic impacts.
Both of these points fall within the remit of the Oil and Gas authority (field development plans) and are therefore not material to a local planning committee.
Policy MP 12: Conventional and unconventional oil and gas development
There should not be a differentiation between unconventional and conventional oil and gas development. From a surface perspective, and therefore from a planning perspective - the difference is unnoticeable.
Similarly, the integrity of the underlying geological structure is a matter for the OGA and the EA - it should not be included as a planning criterion.
Please do not hesitate to get in contact if any of the above requires clarification