Yorkshire Water's "No Objection" requires reconsideration says DLC.

Drawing a Line in the Chalk (DLC) has raised a further concern regarding the proposed exploratory gas well at Land North of Butt Lane, Foxholes (NY/2025/0113/FUL).

Our concern relates specifically to Yorkshire Water's previous decision not to object to the proposal and whether that position remains defensible in light of new information concerning the geology and groundwater resources of the Yorkshire Wolds.

We are asking:

Can Yorkshire Water reasonably maintain its "no objection" position without demonstrating that the latest geological understanding of the Yorkshire Wolds has been properly considered?

We believe this question now requires a substantive answer.

1. BGS has confirmed that the geological understanding of the Wolds has materially changed

The British Geological Survey (BGS) has responded directly to questions raised concerning the recent Yorkshire Wolds geological remapping.

Its response confirms that:

"The remapping has allowed BGS to make considerable advances in the geological understanding of the area."

This is not merely an updated map.

BGS confirms that the work has identified geological complexities including:

• fault zones;

• karst features;

• different bedrock lithologies;

• superficial deposits; and

• geological structures capable of affecting groundwater pathways.

BGS specifically states:

"Each of these elements of the near surface geology can affect groundwater pathways."

This is highly relevant to a proposal involving drilling through the Principal Chalk Aquifer.

2. Yorkshire Water helped fund the new geological work – and already has access to it

The remapping was undertaken through a partnership involving BGS, the Environment Agency and Yorkshire Water. BGS confirms that the new geological information has been provided to both the Environment Agency and Yorkshire Water.

There is therefore a fundamental distinction between the information available to the applicant and the information available to the organisations responsible for protecting groundwater resources.

The new mapping has not yet been incorporated into the publicly available BGS geological dataset and is not expected to become part of that dataset until approximately 2029.

That does not mean the information is unavailable to Yorkshire Water. You already have it. This raises an obvious question:

Did Yorkshire Water consider the new geological understanding when deciding that it had no objection to the Foxholes proposal?

If it did, we ask Yorkshire Water to explain how?

If it did not, we ask why not?

3. BGS says better geological information supports better groundwater assessment

BGS has also stated:

"BGS would generally expect hydrogeological risk assessments to make use of the best available geological information."

And:

"Where geological remapping has materially improved understanding of the subsurface its use is likely to support a more robust assessment of potential groundwater impacts."

This is important. It is not about asking BGS to determine whether Egdon's Hydrogeological Risk Assessment is adequate. BGS has quite properly declined to do that. But it has provided a clear scientific principle:

Better geological understanding should support a more robust assessment of groundwater impacts.

That principle should surely be relevant to Yorkshire Water's own assessment of the proposal.

4. "We don't abstract nearby" is not an adequate answer to a groundwater-resource question

Yorkshire Water's previous consultation response stated that it had no objection and referred specifically to the fact that it does not abstract drinking water from locations close to Foxholes. DLC considers that this response is now insufficient.

The question is not simply:

"Is there a Yorkshire Water abstraction borehole next to the proposed wellsite?"

The question is:

"Could activities capable of affecting groundwater pathways or groundwater quality have implications for a strategically important groundwater resource?"

The distinction matters. The Yorkshire Wolds contain a Principal Chalk Aquifer.

BGS has now confirmed that faults, karst and other geological structures can influence groundwater pathways. The existence or location of a particular abstraction point cannot, by itself, demonstrate the absence of groundwater risk.

Groundwater does not respect administrative boundaries, planning application boundaries or the location of today's abstraction boreholes. Communities and populations downstream (over 900,000 people in the East Riding) are at significant risk and should be protected via the precautionary principle.

5. Yorkshire Water itself says groundwater is strategically important to its future

This concern is reinforced by Yorkshire Water's own recent public statements concerning its water resource strategy. Yorkshire Water states that between 2025 and 2030 it is delivering a major borehole programme across Yorkshire. Three new borehole projects are already in progress, and Yorkshire Water says these projects will provide an additional 21 million litres of water per day.

Most significantly, Yorkshire Water describes boreholes as:

"an integral part of our water resources management plan"

and as a key element of its long-term approach to ensuring sufficient water for its customers.

This raises another important question.

If groundwater is sufficiently important to Yorkshire Water's future water supply that it is investing in major new borehole infrastructure, why should protection of the wider groundwater resource at Foxholes be considered solely through the narrow lens of whether Yorkshire Water happens to abstract from a location close to the proposed wellsite today?

DLC believes that question deserves an answer.

6. The apparent contradiction

There is now a striking juxtaposition of statements from the organisations involved.

BGS says:

The new remapping represents a considerable advance in geological understanding.

BGS says:

Faults, karst and other geological features can affect groundwater pathways.

BGS says:

Best available geological information should be used in hydrogeological risk assessment.

Yorkshire Water says:

Groundwater and boreholes are an integral part of its long-term water-resource strategy.

Yet Yorkshire Water says:

It has no objection to the Foxholes proposal, in part because it does not currently abstract drinking water close to Foxholes.

DLC believes these positions require reconciliation.

7. We are therefore asking Yorkshire Water to reconsider

Drawing a Line in the Chalk respectfully asks Yorkshire Water to:

1. Review its previous "no objection" position in light of the new BGS geological information.

2. Confirm whether the new Yorkshire Wolds geological mapping was considered when Yorkshire Water reached its original position?

3. If it was considered, explain how the revised understanding of faults, karst, geological structures and groundwater pathways informed its assessment?

4. If it was not considered, explain why Yorkshire Water did not use information that it already possessed through its partnership with BGS?

5. Confirm whether the new geological information has been considered in Yorkshire Water's current assessment of groundwater resources and future groundwater abstraction within the Yorkshire Wolds?

6. Explain whether Yorkshire Water considers that the absence of a current abstraction point immediately adjacent to Foxholes is sufficient to rule out a material groundwater resource concern?

7. Confirm whether Yorkshire Water remains satisfied that the Hydrogeological Risk Assessment supporting the Foxholes proposal represents a sufficiently robust assessment in light of the improved geological understanding now available?

8. If Yorkshire Water's position has changed, or if further information is required, we ask that this be communicated formally to North Yorkshire Council and the Environment Agency.

8. This is about protecting the Chalk, not simply opposing a gas well

DLC's name is deliberate.

Drawing a Line in the Chalk exists because the Yorkshire Wolds Chalk is not simply rock beneath our feet. It hosts a major groundwater resource upon which communities, agriculture, businesses and the wider environment depend.

We do not believe that groundwater protection should be based on yesterday's geological understanding when materially improved information already exists.

Nor do we believe that the absence of a nearby abstraction borehole is, by itself, an adequate excuse for the absence of groundwater risk.

The precautionary principle exists precisely because some environmental risks cannot be reliably dismissed simply because they have not yet been demonstrated.

Our request

We therefore ask North Yorkshire Council and the Environment Agency to ensure that Yorkshire Water's current position is established and placed on the planning record.

And we ask Yorkshire Water to reconsider its "no objection" response in light of the evidence now available.

The question is not whether Yorkshire Water can prove that contamination will occur.

The question is whether it can demonstrate, on the basis of the best available geological understanding, that the proposal poses no unacceptable risk to the groundwater resource it has a responsibility to protect.

That is the standard the public should reasonably expect.

Yours faithfully

Angela Eddy (Chair) – Drawing a Line in the Chalk.