Challenging the Gloucestershire Minerals Local Plan: A Work In Progress


This page has been set up as an open source document to analyse, deposit relevant research and to challenge the Emerging Gloucestershire Minerals Local Plan (2018-32). The plan, drawn up by county council planners at Shire Hall in Gloucester, is in draft form and the public is being consulted on it from September 29 to November 24 (before 5pm).

Click here for the main draft Minerals Local Plan document

Click here for the explanatory page and access to the supporting documents

UPDATE (NOV 2016): We have now produced a community guide to challenging the plan – read/ print/ download here (PDF)

The next stage is an Examination in Public, when an independent inspector holds a public inquiry and those who made submissions are invited to take part.

The final stage is that the Government rules whether the Minerals Local Plan for the county is “sound”. If it is ruled “unsound” this means county council planners will have to go back to the drawing board and the whole process gone through again. To be ruled unsound means Government deems it out of kilter with its own National Planning Policy Framework (NPPF).

The county minerals plan will be the primary policy which Gloucestershire County Council planning officers and councillors have to adhere to between 2018 and 2032 when considering any minerals applications – this includes quarrying, sand and gravel extraction, coal, any other kind of mining, plus oil and gas exploration and extraction, including fracking.

Surveys undertaken by teams spurred on by Frack Off Our Forest have shown that 85% of some communities – namely Parkend and Brierley – do not want to live in a future gasfield. But public opinion is not a planning consideration.

In its current draft form, the Gloucestershire Minerals Local Plan presents an open door to the oil and gas industry. It says any planning applications made concerning oil and gas exploration between 2018 and 2032, should be APPROVED (while coal-mining applications should be opposed).

We cannot blame or have a go at the county planners nor County Council Cabinet, the elite group of Conservative councillors which governs the council, the draft to go out for consultation, for presuming in favour of fracking (or steps towards fracking). They (as are other statutory authorities) are forced to follow the National Planning Policy Framework as well as legislation such as the Infrastructure Act 2015 as part of a “duty to co-operate”.

But what planners have not done is to take into account sufficiently is local conditions which should make oil / gas exploration especially dangerous to the stability of our Forest landscape as well as threaten our water supplies and ecosystem, never mind the threat to civil rights and climate change.

The draft policy on oil and gas, MW06, offers some vague conditions which would need to be satisfied before gas/oil plans are approved. The overarching policy statement on Page 25 of the draft MLP (Minerals Local Plan) is especially concerning:

Allow for the exploration and potential production of oil & gas including through unconventional techniques within licensed areas subject to impacts on the environment and local communities being minimised as a result of recognising and adapting to constraints and through the proportionate use of restrictions

Impacts “minimised” – how, when for instance it has been calculated that in order to recover just 15% of shale gas under Lancashire, 33,000 wells would need to be drilled on 5,500 pads – 1,000 each year. [according to Andy Aplin, Professor of Unconventional Petroleum at Durham University]?

It is difficult to raise the issue of future potential proliferation when each planning application has to be considered on its own merit alone. The fracking industry knows this and plays the system to its advantage – for instance, the first application will simply drill the hole and test rock cores, then future applications could be for drilling further down into shale, or then horizontally, and then fracking itself… and this even before the appraisal or gas development stage.

But the planners appear to have ignored the very pertinent local issues – those that place us, the forest, our water, our roads and our homes at risk – we and local experts have raised pertaining to the geology and hydrogeology/ hydrology (water system) of the Forest of Dean and Wye Valley. They have not considered, for instance, that under the central Statutory Forest, from Bream to Cinderford, is a great void created by extensive deep coal-mining, while the fringes of the area are like a honeycomb from both coal and iron-ore mining. Deep-mining ended in the 1960s because far more water had to be pumped out than coal taken out. Since the mines closed and the pumps ceased to operate, the great void has filled with water. This water which surges not only through natural faults, underground watercourses but through all the collapsed workings, according to Coleford-based mining surveyor Paul Morgan, runs under our feet at sufficient high pressure that would crumple submarines.

This is just one example of how the Gloucestershire Minerals Local Plan must be challenged.

What is also REALLY important is that a great many people challenge it in SEPARATE, INDIVIDUAL/ ORGANISATION submissions which could focus only on Policy MW06 (oil and gas) but also stone extraction proposals (many are also concerned at the proposed gargantuan quarry extensions which will make the main gateway to our forest from the western side – the main Chepstow-Coleford road, coming from St Briavels towards Clearwell – not the golden fields we see today across a limestone pavement but a gaping hole filled with heavy industry).

Of course not everyone will feel confident enough to spend hours writing their own submissions, and we invite anyone who is certain they are unable to do this, possibly not having time, to simply email the council at m& or posted to: – MLP Consultation 2016, Minerals & Waste Policy, Strategic Infrastructure, Gloucestershire County Council, Shire Hall, Westgate Street, Gloucester, GL1 2TG [you MUST include

  • Who is making the response (an individual’s name  / or on behalf of an organisation);
  • Where the respondent is from (postal address / e-mail contact); and
  • What part(s) of the consultation is of interest (the section, paragraph number, page, policy, site allocation etc..)

or register [CLICK HERE] in the consultation, to say “I support the Frack Off Our Forest submission” or “I add my weight to…” or something else in your own words!

BUT to respond in your own words with your own observations carries FAR MORE WEIGHT than any petition, chain letter or pro forma response, so we strongly encourage the thousands of people who care about the future of our Forest to find the time and do the work to make their own independent submissions.

We would also really like to see those responses and people share with us their observations, introduce potential challenges, contribute to research. We don’t have long though so get those sleeves rolled up now! You can either comment below this page or email us at (we will entirely respect any requests for anonymity).

Whether you put the time in to make your own worded response or are only able to back up the Frack Off Our Forest response, it’s VITAL that your voice is heard and it WON’T BE unless you either register to be part of the consultation or do so (including those details as above) via an email or letter.



Again, that deadline for everyone to get their responses to Shire Hall is NOVEMBER 24TH 2016 before 5pm. Can you help us get the word out, pass this on, and also if you have printing facilities, run off some copies of our guide to give to your friends, colleagues etc?