Template submission on proposed changes to FODC LDP [Local Development Plan]

Comment on proposed changes to Local Development Plan 2030

Email  to FODC at: developmentplan@fermanaghomagh.com

Subject:  proposed changes to the Fermanagh & Omagh District Council [FODC] Local Development Plan [LDP] 2030 Draft plan [published in October 2018]. The proposed changes to the LDP were published in July 2020.

Specifically I object to the proposed change to the Mineral section [MIN 04]

Currently in the 2018 LDP draft it states on page 127 ‘The local council will not permit unconventional hydrocarbon extraction until it is proved that there would be no adverse effects on the environment or public health’. The proposed change is to alter the above sentence to ‘The local council will not permit unconventional hydrocarbon extraction until there is robust evidence on all associated impacts on the environment and human health’.

Unconventional hydrocarbon extraction [UHE] goes under many names including fracking.

I object to any changes of MIN 04 [2018] for the following reasons.

1. The term ‘robust evidence on all associated impacts’ leaves open the possibility that despite the evidence of negative impacts on human health and the environment the FODC may still decide to allow UHE. This is possible as the change in wording allows the fracking industry and/or FODC to argue that regulation ‘of the associated impacts’ is possible. Very strong evidence from the USA has shown time and again that regulation of fracking does not work and people’s health deteriorates. I insist the original sentence remains unaltered. Public Health is central to any long term plan for our communities and must be explicitly included in the LDP with regards to UHE.

2. In the ‘Summary of Issue/ Justification’ box for the above proposed change to the FODC LDP wording it states ‘to reflect SPPS’. The SPPS [Strategic Planning Policy Statement for Northern Ireland published in 2015] is an important document and states that the SPPS should ‘be taken into account’ when local plans are drawn up. This does not mean that the FODC are not allowed to choose its own slightly different wording where appropriate. Indeed in the introduction to the SPPS document the Minister stated the vision of the SPPS was simple; to improve well-being for the people, no compromising on environmental standards and creating places where communities can flourish now and into the future. If Public Health is not explicitly written into the FODC LDP then the SPPS will not fulfil the goals as set out above by the Minister.

3. There is a huge increase in high quality peer reviewed evidence, year on year, of the definitive harm to Public health and the environment that unconventional hydrocarbon extraction causes. Thus statements of even two years ago let alone five years ago have been superseded by the evidence. See www.concernedhealthny.org/compendium compiled by USA physicians relating to the extensive harm to both Public Health and the environment due to UHE. A court ruling in the UK last year [the Dove Judgement www.frackfreeunited.co.uk/fracking-unlawful] states that National and Local Government departments can and must adapt their plans to take account of current evidence of Public health harm and/ or climate damage even if their new adaptations appear to contradict existing planning policies. To put it simply: if the evidence changes and becomes more definitive then plans [including the FODC LDP] should reflect these changes, irrespective of what older, out-of-date Government documents say.

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