Last week many of us submitted comments to SLR Consulting on the Rhino Oil & Gas Applications for Exploration Rights in KZN and the Eastern Cape. Even if you missed the deadline, it is worth sending your thoughts to SLR. We have compiled a few of the submissions on the KZN application here, to assist others who face the same threats. Read also Jane Weston’s comments in Dear Mr Hemming.
Frack Free SA Comments on Exploration Applications for KZN 291ER
We do not understand why this application is persisting despite and/or in spite of the overwhelming negative response you have received to date during and after the “public participation” meetings. This application should have been withdrawn long ago. It is neither needed nor desirable and is definitely not in the public interest. A few people will make a lot of money and the local communities will be left to deal with the legacy with shattered lives and livelihoods.
We have a planet in crisis from greenhouse gas emissions and need to heed the global call for “business unusual” to ensure that the human race can survive the global warming that is underway. In South Africa, the water crisis is being exacerbated by Climate Change impacts. The activities ensuing from this application will continue to add to the impacts and drivers of Climate Change.
We will thus never support this application for exploration across KZN by Rhino Oil & Gas for so many good reasons as knowing that:
- Exploration leads to production and that to our knowledge not a single application for production that has been denied by PASA;
- The SLR report does not deal with the production aspect of the application which will follow exploration as surely as marriage follows the payment of lobola;
- The impacts of exploration and production will never be known as there has been no attempt to determine the baseline;
- It is unbelievable that seismic surveys have no impacts other than damage from vehicles and equipment or craters which will be filled;
- There has been no mention of the impact of drilling fluids or how they will be stored and treated for safe disposal during exploration drilling;
- PASA’s mandate “promotes exploration for onshore and offshore oil and gas resources and their optimal development on behalf of government” and nowhere in it is the requirement to protect people and the environment from the adverse impacts of exploration and/or mining;
- Mining has never improved the lives and livelihoods of local communities, but has rather left people worse off than they were before;
- The lessons from the Marikana Massacre have neither been learnt by government nor the mining industry;
- South Africa’s mining industry is not sustainable as envisaged in the principles of NEMA and our Constitution – there is not a single example where the impacts are being managed to prevent pollution, protect human health and benefit the local communities sustainably;
- Cheap gas is a misnomer – the costs are borne by society and the environment, not by those organisations involved in “moneytisation” of the “resource”;
- Rhino’s application is over a huge swathe of KZN, in sensitive areas where water is scarce/absent and children and old people already die from malnutrition;
- Rhino’s application should have been focused to the 10 areas where exploration will take place to ensure that the impacts in that area are predicted and addressed;
- Climate Change is being driven by emissions of gases and that extraction of underground gas will lead to large volumes of methane gas emissions to atmosphere during drilling, well casing and production, as well as during transport;
- South Africa has committed to reducing emissions of greenhouse gases and focusing on renewable sources of energy to avoid reaching the point of no return in terms of global warming;
- Fracking is banned in many developed and developing countries;
- Fracking is causing health impacts in all the areas where it has been used from emissions to the air and pollution of groundwater;
- Gas extraction uses huge amounts of water which will have to come from a supply that is already oversubscribed;
- Fracking generates “production” water, comprising toxic chemicals which has no way of being treated to avoid contamination;
- 6% of new wells in the USA fail in the first year and all fail with time causing pollution and affecting health of people, domestic animals and the environment
- Methane emissions from fracking have not been included in the database of emissions used to predict global warming increases in future which determine if we will be able to continue to live on our planet;
- Solar energy in South Africa is setting the standard for sustainability especially in terms of job creation and community development and this application represents damaging technology for dirty fuel sources which will keep us back;
- People living in the fracking belts of the USA and Australia have all repeated the refrain that they never knew how fracking would destroy their lives and livelihoods.
We will not support this application and call on the regulators to prevent exploration rights from being granted. This and similar projects must not be authorised in any shape or form.
Dr Dela Maiwald is particularly concerned about on Health issues:
1.The fear of the landowners re this project that you mention is not due to ignorance or misunderstanding of the processes involved as suggested. It is due to a real understanding of the threats posed to the environment health and water security of this proposed project to diligent research done. It is also due to the mistrust in governmental processes to evaluate this accurately and protect citizens constitutional rights of living in a healthy sustainable environment
2. PASA is absolving itself from the complaints procedure and redress as mentioned in the questions put to them from the community and replied by them. It also seems to not have initiated ANY communication with other governmental departments that should have a determining role to play as major stakeholders in the decisions to be made. Eg Dept agriculture, environmental affairs, health and water and sanitation. This lack of interdepartmental communication and advice will lead to the destruction of life security(water, food ,health) in the communities that are already burdoned with poverty and thus in no way able to cope with a worsening in these areas. Job creation for the rural citizens is unlikely as this process needs specialist labour NOT available in this country. It does not need unskilled labour.
4. The perceived economic gains are poor if thought about carefully. All equipment needed will need to be imported and the market for gas usage in the country is non-existant. So it will not benefit citizens initially as the market and infrastructure needs to be developed for it to benefit ordinary citizens. The budget is so strained already that current service delivery is protested against daily somewhere in the country. So the initial exploration and production will be for export.. this profit is also under strain due to the very definitive move towards divestment in oil gas and coal in the international developed world countries and markets.
5. SA boasts excellent environmental legislation but typical of developing countries seems to want to ignore that legislation. This and the inability to enforce the legislation and regulation is also EXTREMELY concerning. SA may well have the resource available but does not have the climate to utilise this resource responsibly and appropriately yet.
6. If job creation and electricity security is at the heart of this governmental venture, this is not the path. Alternate sources that are more sustainable need to be investigated. It has been done successfully in the George airport that is run on solar energy.
I am 100% against this exploration attempt that will surely lead to production. Let us not deny that fact. Other countries have ample evidence of the negative effects that were not anticipated by their governments or scientists. We have the advantage of that knowledge and should heed the experiences carefully…we will surely experience the same and do not have better capacity to avoid the negative impacts…in fact we may have less capacity to cope with negative impact. Hoping that the government will have the interests of its citizens at heart and uphold the constitutional rights for each of us.
Francois du Toit believes the entire process is flawed:
I reiterate the concerns we voiced at the public meetings, and in general over the past few months. We do not condone the process, the application and reserve all rights in this regard. We find the application and it purport flawed and insufficiently considered in light of the real and documented risks, as indicated in your BID and internationally. We will never support this application for exploration across KZN by Rhino Oil & Gas for so many good reasons.
You and your client, Rhino Oil and Gas, have publicly acknowledged that:
- There are risks to the process of exploration and production, which may include seismic testing, fracking, and/or gas extraction.
- The risks are real and documented and in fact outlined in parts of your BID
- Rhino Oil and Gas is in the business of making money and is speculating on the value and whereabouts of potential gas plays in KZN
- Rhino seeks, for its own personal profit, to compromise the integrity of the environment and the rights of the landowners, and the health, social and economic detriment of the current land occupier.
WE DEMAND AN IMMEDIATE MORATORIUM ON ALL APPLICATIONS, A STRATEGIC ENVIRONMENTAL ASSESSMENT OF KZN AND THIS AREA IN PARTICULAR, A CESSATION OF ALL ACTIVITIES IN FURTHERANCE OF THIS APPLICIATION. You personally have indicated that your responsibility is to the process and the environment.
I BELIEVE THAT FAILURE TO STRONGLY RECOMMEND THE ABOVE, IN THE LIGHT OF THE MANY OBJECTIONS RECEIVED ON THIS AND THE OTHER GAS EXPLORATION APPLICATIONS YOU ACT FOR, IS A MATTER OF BAD FAITH BY YOURSELF AS AN ENVINROMENTAL PRACTIONER AND YOUR ORGANISATION AS A PROTECTOR OF THE RIGHTS OF SOUTH AFRICANS! YOU SHOULD BE CONDEMNING THE APPLICATION PROCESS INSTEAD OF BEING PART OF IT, FOR ALL THE REASONS OUTLINED ABOVE. Withdraw your services and absolve yourself from infringing on the very rights you are supposed to be.
We are not impressed with the integrity of this process, its applicants and its proponents.
Malvina van Bremem is rightly furious:
After wading through the lengthy Report and admitting to myself that legal speak is almost as much rubbish as the proposal Rhino Oil & Gas has put forward for permission to explore the KZN Midlands, herewith my 5c worth: In your statements that so many points are outside the initial Scoping report and cannot be dealt with in this report, I see a massive minefield awaiting all of us who object to RO &G’s application for permission to explore – it is disingenuous to say the least to make this statement, as most of our concerns could and will only be addressed once or after the invasive activities begin.This is unacceptable to us as we will be left “holding the baby” once RO&G have raped our beautiful countryside and then sold off any exploration or other rights to some other totally disinterested party.
We feel very strongly that your so-called ‘Public Participation Process’ is just whitewashing and a cover-up for the highly suspect RO &G applications. In fact the entire scoping report is a whitewash for a load of hogwash.
The public have participated and throughout have told RO &G and yourselves to frack off in no uncertain terms. Nobody wants exploration to take place and above all else nobody wants any invasive process to take place, no matter WHAT the process is – we do NOT believe that PASA, SLR, RO &G and DMR have our interests at heart and therefore mistrust deeply any processes and/or applications which may lead in the direction of this occurring.
And quoting Gaetane Le Grange in the Comments section ‘The pre-cautionary principle states that, if one does not understand the impacts fully, they should not go ahead with the project. The ‘polluter pays’ principle states that, the one who causes pollution is responsible to mitigating it. Both these principles apply in this process and we do not for one second believe that either RO &G, PASA, SLR, DMR or anyone else however remotely involved in mining or future extraction processes will adhere to these tenets.
Your document states:
- ‘The aim will be to identify key features of the groundwater resource and to define which regions may be incompatible with the proposed exploration activities related to the groundwater resources. Pxii’
“Water required for the operation of the drilling rig as well as potable water would be obtained from an available source and in compliance with legislation’
With the entire country gripped in the worst drought in decades, does this not seem like an irresponsible attitude? Even if the drought breaks in the near future, South Africa remains a water-scarce country. Then there remains the possibility of contamination of already scarce water resources. We deem that the possibilities of water and other contamination simply outweigh any benefit to the entire country as a whole.
There is simply NOTHING ‘green’ or eco-friendly in the proposed processes of either exploration or future extraction, thereby leaving no doubt that any and all processes involved will be highly detrimental to health, welfare, income, quality of life and anything of benefit to society within South Africa.
As to the veracity of the following, we have our gravest doubts:
- Rhino was granted the opportunity to apply for the proposed Exploration Right based on experience. In terms of the MPRDA, an exploration right can only be granted if, inter alia, the applicant has access to financial resources and has the technical ability to conduct the proposed exploration operation optimally in accordance with the exploration work programme.
At the Howick West follow-up meeting, one Travis Smithard was trotted out as the “expert geologist” – he is no more than 26 or 27 years old and has not even finished his degree/postgraduate studies – are these the so-called type of “experts” who will be involved in the future? When far more senior and informed experts within South Africa are already espousing the risks and dangers associated with both exploration of this type and ultimately extraction?
Your document also leaves us in no doubt as to how clueless you really are:
- SLR will assess the impacts of the proposed early-phase exploration work programme. It is not possible to provide an informed assessment of potential future impacts where the proponent has no idea of the project plan, the methodology or the locality. The scope of the current EIA is therefore linked and limited to the early-phase exploration work programme.
The true ramifications of the dangers of both exploration and extraction processes are far, far too great to allow any of these processes to occur. We therefore submit in the strongest terms possible that we do not condone or approve of any application going forward, be it exploration or extraction of any sort. Leave it where it is and rather invest everything in renewable energy, instead of threatening our health, environment and livelihoods and just plain wasting our time!
Please note that I reserve my right to give additional commentary on this matter until the prescribed time frame is exhausted and that the above is by no means a comprehensive commentary on your document. Yours in complete mistrust.
Bronwyn Howard is particularly concerned about infrastructure development:
Something that must be mentioned – is the infrastructure issue. If viable resources are found, significant infrastructural developments such as pipelines will be needed to move the gas from the production site to where it is being used – or the port where it will be transported from. South Africa has very few of these sorts of pipelines currently and such infrastructure development will have a tremendous footprint with potential for further habitat destruction, communities being moved, leaks of methane, etc, so this really needs to be addressed somewhere at some stage.
WWF-SA (Sue Viljoen and Tjasa Bole-Rentel) compiled this comprehensive response:
Thank you for the opportunity to comment on the Scoping Report prepared by SLR Consulting on behalf of Rhino Oil and Gas Exploration South Africa in support of its application for an “Exploration Right for Petroleum on various Farms in the Magisterial District of Pietermaritzburg, KwaZulu-Natal‟ (12/3/291 ER).
Due to time constraints, we were only able to review in detail the document‟s Executive Summary and only scan the main body of the report, and our comments and questions should therefore be interpreted with the prior acknowledgment that the details laid out in the body of the report have not been read in full. We apologise for any comments/questions presented here that may be addressed in the main body of the report and are thus superfluous.
While it is understood that the scoping report only deals with early exploration activities over the first 3 years of the exploration programme, which do not include extraction of hydrocarbons or significant amounts of water (on a regional level), no stimulation of wells or hydraulic fracturing (fracking), we wish to re-iterate the strong opposition to activities that would result from a successful completion of this early exploration phase, thus questioning the rational for even early exploration.
It is greatly appreciated that SLR dutifully reported the wide public opposition to both Rhino‟s short-term exploration activities, as well as long-term hydrocarbon extraction ambitions. We find the major themes of the public opposition to be appropriately summarised and welcome SLR‟s word of caution for its client (Rhino) urging it to give due consideration to the concerns underlying public opposition to oil and gas development in KZN and the practical implications for its exploration programme in the application area.
While the list of specialist studies proposed seems acceptable, what is lacking is a summary of the known or possible impacts for each method of exploration. i.e. what impacts could one expect from the drill tests versus the seismic surveys? If all the potential impacts with all the steps involved in exploration are conflated into one section such as surface water, it is hard to ascertain exactly what risks are relevant to which type of exploration. This separate of methods and associated impacts could be useful for landowners, as some might have core borehole drilling on their property and others might have the seismic 2D survey cross their property.
We recommend that the WRC project recently completed and led by Dr Surina Esterhuyse is consulted (namely “Development of an Interactive Vulnerability Map and Monitoring Framework to Assess the Potential Environmental Impact of Unconventional Oil and Gas Extraction by Means of Hydraulic Fracturing”) when considering potential locations for both exploration and possible later extraction, as this work provides a useful framework for assessing environment impacts of unconventional hydrocarbon extraction, and it also covers CBM methods. The full technical WRC report of Dr. Esterhuyse’s UFS team can be downloaded from researchgate here: https://www.researchgate.net/publication/280920027_Development_of_an_Interactive_Vulnerability_Map_and_Monitoring_Framework_to_Assess_the_Potential_Environmental_Impact_of_Unconventional_Oil_and_Gas_Extraction_by_Means_of_Hydraulic_Fracturing
SPECIFIC COMMENTS to the Scoping Report:
Executive Summary (pg ii) “These comments will be used to update the Scoping Report which will then be submitted to PASA for acceptance”
- This statement could mislead some of the public to assume their comments would simply be integrated into the Scoping report if useful for its improvement and not recorded and reported to PASA in their entirety, thus discouraging some stakeholders from providing feedback.
Executive Summary (pg iv) “Approvals are also likely to be required in terms of other legislation”
- It would be useful if the Scoping report clarified what legislation and under what conditions are further approvals going to be necessary and when not?
Executive Summary (pg iv) “…if the later exploration led to the discovery of a commercial resource suitable for development then Rhino Oil and Gas would need to secure a production right from PASA.”
- This sentence touches upon the crux of the procedural problematic. Under current legislation if exploration is successful, then the Minister “will” grant a production right to the applicant (subject to a number of financial and technical conditions, but not environmental or social ones), so it is crucial for I&AP to know if the exploration right Rhino is currently applying for is granted, is there going to be another – a separate – exploration right application for further exploration activities, subject to the same process where I&AP will again have the opportunity for meaningful engagement?
- This uncertainty is further exacerbated by PASA‟s response to Issue 2 in Section A on pg viii, which says “If the applicant wanted to pursue any activities beyond the scope of the proposed work programme then environmental authorisation for such activities would have to be obtained. This process provides for further engagement with I&APs and in-depth assessment of the associated issues.” It mentions the need for an additional environmental authorisation, but not a new exploration right application.
- Figure 1.1 on pg 1-4 also seems to suggest that additional environmental authorisation does not require another exploration right application. All this suggests that if Rhino‟s hydrocarbon production activities are not stopped now, there might not be another opportunity for the public to do so in the process leading up to a production right.
Executive Summary (pg v) and Section 4 “Need and desirability”
- The US experience with unconventional hydrocarbons, especially shale gas holds limited relevance for South Africa, as production of unconventional hydrocarbons would take place in a completely different socio-economic, institutional, infrastructure and historical context, which will severely diminish the benefits of developing a domestic “unconventionals” sector and may indeed prove less rational than importing conventional gas.
Executive Summary (pg v) “Where physical exploration/field activity is proposed the primary mitigation would be the appropriate siting at a locality of low sensitivity”
- The locality of physical exploration/field activity is a function of both likelihood of hydrocarbon presence and environmental sensitivities. In practice, how are the two reconciled if they are in opposition (i.e. the locality that shows highest likelihood of hydrocarbon presence is also one of high environmental sensitivity)?
Executive Summary (pg vii) “The overriding finding of the public participation has been that the great majority of IAP’s are strongly particular.”
- There is a typo at the end of this very important sentence – please rectify what should be where the word “particular” is?
Executive Summary (pg vii) Section 8, “Results of Public consultation”
- Second to last bullet in this section “SA does not understand shale gas risks….”.
- Concerns around future water resource impacts (if extraction follows) were repeatedly raised at a number of public meetings, especially considering the current drought and water restrictions being faced by many IAP‟s in KZN. However this point was not mentioned in the bulleted list/summary of major themes of the public opposition in this section. Please amend.
- This should rather read “SA does not yet fully understand unconventional hydrocarbon extraction risks” considering this application covers a number of minerals.
Executive Summary (pg viii) Issue 4: “The time available in the current EIA schedule is insufficient to allow for the required public consultation for such a large application area and contentious project. “The Agency can consider requests received in writing from the EAP or applicant to extend the timeframe provided that the requests comply with the provisions of the EIA Regulations.”
- Has SLR or Rhino followed-up on this opportunity and requested more time for public consultation as demanded by the I&AP?
Executive Summary (pg xiv) “The proposed exploration activities could result in the loss of or damage to heritage resources (including archaeological, palaeontology and cultural heritage sites
- Shouldn’t such sites (and a suitable buffer zone around them) be a-priori excluded from exploration activities, just as protected areas?
Executive Summary (pg xv) “Exploration activities could increase noise levels, which may disturb or be a nuisance to landowners or adjacent residents.”
- We question the use of conditionality in this statement as exploration activities; especially seismic surveying and core drilling will increase noise levels.
Executive Summary (pg xv) Paragraph on “Effect on local economy due to job creation and direct revenues”
- We find that this paragraph in the Executive Summary does not adequately summarise the finding of Section 5.4.19 (Contribution to the local economy) which correctly concludes that the contribution to the local economy in terms of direct job creation for local job seekers would be negligible.
- In addition the possible negative impacts on the environment, particularly water resources (and the well-known and reported general lack of legislative oversight or compliance to environmental and related legislation, such as the National Water Act), which would accrue over time as exploration and possible extraction activities continue and its ecological footprint increases, these activities could ultimately result in job losses as existing rural livelihoods such as agriculture, farming, livestock production, ecotourism, community arts & crafts projects, etc are curtailed due to the environmental impact. Job losses will have a knock-on effect ultimately on the economies of towns, which usually support the rural communities and farmers surrounding them, as well as their economic activities.
Executive Summary (pg xv & xvi) and Page 6 – 308 in Scoping Report “If exploration detracts from or compromises the main attractions of the region then it could result in a reduction in external inputs to the local economy.”
- It is recommended that the impact on tourism in the Natal Midlands is included in the list of “Socio-economic” aspects to be assessed with specialist studies in the EIA. Tourism is only briefly mentioned in the section under local economy, but warrants its own dedicated section, considering one of the main attractions of the midlands is its scenic landscapes, unspoilt natural beauty and sporting events such the Midmar Mile and Dusi Canoe Marathon. Even exploration in a popular tourism destination is likely to raise negative expectations and ill-feeling amongst tourism establishments, and should extraction proceed, is highly likely to detrimentally impact on the midlands tourism industry and sense of place in the midlands.
Section 18.104.22.168: Contamination of groundwater resources “Contamination of groundwater could occur as a result of the use of drilling fluids during core hole drilling, and accidental spillages and leaks”
- It is proposed that as an additional mitigation measure once the desktop stage of exploration is complete and the locations of the 10 core boreholes have been selected, that these locations are made public, and that baseline monitoring of surface and groundwater resources around these 10 sites is then immediately commenced.
Section 22.214.171.124: Contamination of groundwater resources “The drilling additives used are largely not hazardous and/or are bio-degradable”
- A complete list of drilling additives likely to be used is requested and flagging of the ones that are not “not-hazardous”.
Section 126.96.36.199: Water consumption “In some catchments in the region the water resource is fully allocated and there is no surface or groundwater available for new users, unless such water is reallocated from an existing user. Exploration will therefore compete with farmers and other users.”
- To the best of our knowledge, water that is licensed for a certain use cannot be re-directed to other uses without approval from DWS? Or is there a minimum amount that can? In addition, the mitigation actions proposed to avoid water competition fall short of recommending abandoning a drill site if sufficient water cannot be sourced economically without compromising the rights of existing water users in the area.
“The (EIA) assessment would be based on the known details of the work as proposed by the applicant. It is also expected that if/when this phase commences that the Karoo SEA for Shale Gas will be complete and will provide a sound basis on which to undertake an assessment of future exploration work.”
- The scope of the Karoo SEA is limited to shale gas only, and therefore will not describe the expected impacts of other forms of unconventional gas extraction methods.
Section 5.5.8: Biodiversity (pgs. 5-266/267) Sites of Conservation Significance: Protected Areas
- Not all of the most recently proclaimed protected areas which will be excluded from exploration activities are listed (e.g. uMngeni Plateau Nature Reserve). Refer to WWF’s note on our submission dated 12 Nov 2015 about the 14 other privately owned reserves that were proclaimed on 9 Oct 2015 (as per Gov Gazette No. 1522, Vol 9).
Appendix 5.3 “Stakeholder Database”
- It is suggested that for future reports the following is considered: Please list names alphabetically, as it is difficult to search for a particular name when not arranged in this way. Please list the regulating authorities as the first section (as their comments carry the most weight).
- We were dismayed to see that only 1 official from KZN Department of Water & Sanitation was listed (namely Ms B Msane). For an application of this scale with large potential future impacts on water, we strongly recommend more senior officials are contacted (e.g. Angela Masefield, Jay Reddy, Alistair Starkey) as well as water quality officials from all the regions that cover the exploration area. Furthermore, Namisha Muthraparsad should be consulted from National DWS in Pretoria (email@example.com), as it is her directorate that is responsible for authorising activities linked to hydraulic fracturing.
- No name was listed next to Dept of Mineral Resources.
- We suggest TAU (Transvaal Agricultural Union) is also included in the list of Agricultural Associations. The contact person is Herman de Wet (who also represents Agri-SA), email: firstname.lastname@example.org. They do have members within Natal.
In conclusion, WWF-SA would like to note that it concurs with the points provided by Frackfree SA, Maloti Drakensberg Transfrontier Park and NatureStamp in the comments these organisations submitted on the Scoping Report.
Nikki Brighton is most concerned about earthworms and micro-organisms:
The Scoping Report has done nothing to alleviate the fears I have about the extraction of Unconventional Gas, or the exploration process. It is very clear that should anything be found, extraction rights will follow. Across the globe we have examples of the horrors that Unconventional Gas extraction brings to communities in terms of health and social issues, destruction of the eco-systems which support our lives and livelihoods, and that the economic benefits accrue to very few. This short term greed by a minority, overriding the rights of communities and, in all likelihood, leaving them with the mess to deal with afterwards (plenty of evidence of this in other extractive industries in South Africa) is completely unacceptable. Business as usual is no way to deal with the challenges our planet (and humanity) is facing.
During the exploration process, my major concerns are with the seismic studies/vibrosis. There appear to be no baseline studies about what below ground eco-systems (including micro-organisms) would be affected. It is clear that seismic disturbances in the ocean are extremely detrimental to marine eco-system functionality and references to the possibility of this are made in the BID. We know that everything is linked and that by destroying or damaging soil life, above ground organisms would be affected, which will impact on river health as well. Until, very clear data is provided on exactly what the impact of ‘low frequency, long wavelength acoustic waves’ might be, and a full study on the soil organisms which may be affected in the entire area of the application is complete, I strongly oppose this application.
No matter where Rhino Oil & Gas intends drilling core-wells (in the very unlikely instance that this right to explore be granted), please be assured that there will be opposition and it is very unlikely that they will be able to go ahead. Investment in renewable energy and resilient communities must surely be a more sensible option.
Dargle Conservancy sums things up:
The Dargle Conservancy wishes to express its strong dissent to the above application. The basis of our rejection is the inevitable mining, including hydraulic mining (fracking) to which we object in the strongest terms. We are concerned about the potential devastating destruction that such exploration (and mining) is likely to have on our environment, biodiversity and water resources. We are also concerned about the consequential detrimental effect this will have on the health of our communities and the pollution of our precious water resources.
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