- Government pushing new licensing round
- Give away of 60% of UK to fracking companies
- Justified by strategic environmental assessment
- Report written by fracking consultants, AMEC
- Public consultation on report ends 28th March
- New fracking give away could begin soon after
- Report ignores massive scale and intensity
- Focuses just on shale gas, ignores CBM threat
- Completely ignores a large number of impacts
- Assumes someone else will deal with issues
- Ignores evidence from US, Canada & Australia
- Assumes things will somehow be different here
- Overlooks the radically new nature of fracking
The 14th onshore licencing round is looming ever closer as the Department of Energy and Climate Change (DECC) tries to give away up to 60 percent of the UK to fracking companies. The government has to perform a strategic environmental assessment (SEA) before it can go ahead with the licensing round which requires a report to be written, followed by a public consultation on its contents. DECC has paid AMEC, an engineering consultancy with ambitions in the shale gas industry, to write the report titled Strategic Environmental Assessment for Further Onshore Oil and Gas Licensing (PDF). The consultation on the report’s contents comes to an end on Friday (28th March) and depending on how long they want to leave to give the appearance of having considered the responses from the public, the actual process of handing out new licences to fracking companies could begin soon afterwards.
Below we analyse some of the most glaring shortcomings of this report which is supposed to “identify and quantify the potentially significant environmental effects” of the licensing round. This is particularly useful in understanding the PR strategy which the industry/government is using to try to gain public acquiescence to fracking, but could also be used to inform consultation responses if you are so inclined. It should be noted that in addition to the more fundamental issues addressed below the AMEC report is also highly inconsistent and shows a very poor understanding of the nature of fracking. Just one example is the assumption of a 5km minimum distance between well pads used in the report. This is completely impossible and for shale gas (with 8 wells per square mile) would imply around 70 wells per pad whereas in other part of the report 6-24 wells per pad is assumed. In another misunderstanding of how fracking works it is assumed that for both conventional and unconventional production all the wells would be drilled in the first 12 years. The reality of fracking is that production from individual wells declines precipitously (usually around 70 percent in the first year alone) and so new wells need to be drilled constant to throughout the production phase.
Unconventional gas and oil wells produce much smaller amounts of hydrocarbons than conventional wells and so much larger numbers of wells are need to produce even moderate amounts. Unlike conventional resources which are concentrated in relatively small geological traps, shale and coal formations are distributed over wide areas and extraction requires coating larger areas with wells, at up to 8 wells per square mile or more. In the US more than 100,000 unconventional wells have been drilled in the last few years, over 20,000 in Canada and over 5,000 in Australia. Based on the amounts of gas and oil companies are bragging they can get out of their existing UK licenses it is estimated that over 70,000 wells would be needed. The much larger areas which will be up for grabs in the 14th onshore round could allow much larger numbers of wells to be drilled. The High Activity Scenario in the AMEC report envisages only 1440-2880 wells being drilled, a number which would only be capable of producing a few months worth of UK gas consumption. No real justification is made for using this number.
For purely historical reasons the impacts of shale gas in the US received some public exposure before the equally severe impacts of coal bed methane (CBM) and shale/tight oil gained any attention. Since then the industry/government spin machine has been working overtime to try to limit the scope of public discourse to just shale gas (and if they can just one stage in the extraction process – hydraulic fracturing). The AMEC report barely mentions CBM or shale oil and then only to dismiss it as irrelevant. Around 30 CBM exploration wells drilled and another 80 planning permissions granted in recent years, compared to around 8 shale exploration wells drilled and a handful of additional planning permissions. Dart Energy is presently fighting a planning inquiry in Scotland against 27 local communities, to try to kick start CBM production with an initial 22 wells, 20 km of pipeline and an outfall to dump the produced water into the Firth of Forth. In the longer term, the gas Dart is bragging about in this one licence block would require a least a 1,000 wells to extract.
Given all this, CBM rather than shale gas seems likely to be the fracking technology which will try to get rolling first in the UK (as it has done in most places around the world) and completely ignoring it demonstrates just how much the AMEC report misses the point. Similarly, tight (shale) oil exploration has already been kicked off in the UK by Cuadrilla Resources in Balcombe, Sussex, with several other companies showing interest, but the report does not specifically address it. While the extraction process is very similar to shale gas and has most of its impacts, shale oil does have a number unique impacts as we saw with the Lac-Mégantic disaster last year and the numerous other shale oil train crashes which followed it. Finally, it should be noted that while the DECC licensing rounds only cover shale and CBM, the fact that these are being subject to a strategic environmental assessment while the piecemeal sale of Underground Coal Gasification (UCG) licences by DECC (24 licences issued in the last few years, with 5 more application pending) are not, is another example of the industry/government trying to sneak whatever it can through under the radar. The impact of this UCG licensing would likely be as catastrophic, if not more so, than the DECC PEDL licensing round.
The massive and invasive nature of fracking, with vast numbers of wells, pipelines, compressor stations and associated infrastructure coating the landscape over huge areas leads to a whole host of impacts, some of the most long term of which probably have not even been identified yet. The impacts documented in the US, Canada and Australia include Water Contamination, Air Pollution, Radioactive Contamination, Human Health, Agriculture & Animal Health, Wildlife, Methane Migration, Climate Change, Fracking Waste,Water Usage, Earthquakes, Transport, Pipelines, Blowouts, Spills & Explosions, Frack Sand, Leaking Wells, Orphaned Wells, Industrialisation, Secrecy, Oppression, Corruption, and Bubble Economics. Almost none of these are mentioned at all in the AMEC report and the few that are mentioned, are promptly dismissed with little or no justification.
The standard response to any impacts which the report cannot avoid mentioning is that some other agency or stage in the process (planning, environmental permitting etc.) will ensure that they are addressed. Of course all the other agencies involved (county council’s, Health and Safety Executive, Environment Agency etc.) take a similar approach, assuming that someone else will deal with the fundamental issues and limiting themselves to most narrowest scope of their remit. Indeed, even if there was an agency that was willing and able to address these overarching issues DECC certainly would not be it. This exposes the joke behind this whole SEA process. Since DECC’s stated policy is to “seek full economic recovery of UK hydrocarbon resources—both conventional and unconventional”, a policy which is a complete odds with any sort of concern for the environment, putting it in charge of making a strategic assessment of the environmental impacts of fracking is like putting the fox in charge of the hen house. This is hammered home by the fact that they promptly out sourced that job to a private company whose interest is in the expansion of fracking in the UK. Of course due to the disperse nature of fracking with thousands of small sites spread over wide areas the industry is pretty much unregulatable and even if it was, many of the impacts are intrinsic to the process and cannot be regulated away (see below).
The overall premise of the AMEC report is that fracking is conventional oil and gas with a bit of hydraulic fracturing, and that therefore the tiny onshore oil and gas industry which exists in the UK at present should be the starting point from which to estimate future impacts. This view point is extremely convenient since it allows what has happened in the US, Canada and Australia to be largely ignored. Add in a few appeals to jingoism in the form of assertions that our superior regulatory framework will protect us, when in fact the opposite is true because there has been almost no onshore oil and gas extraction in the UK to date, there is almost no regulation to limit it. More fundamentally most of the impacts above cannot be regulated out of existence, they are part and parcel of the process, and so no amount of regulation could eliminate them. The reality is that the laws of physics, available technology and our economic systems are all identical to those in the US, Canada and Australia. Therefore there is no reason to expect that outcome of fracking to be any different from those countries. The only major difference is that our much higher population density will mean that a much greater number of people will be affected.
Frack Free Tameside also have an extensive critique of the consultation on there website.