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Shale environmental assessment high on uncertainty and assumptions

The report commissioned by the Government to assess the impact of onshore shale oil and gas development admits to multiple uncertainties and makes assumptions that opponents regularly challenge.

Uncertainties

The report (released 17/12/13) is part of the preparation for the government’s sale of onshore oil and gas licences next year. It uses the words “uncertain” or “uncertainty” a total of 97 times in 130 pages. It also uses “insufficient evidence” nine times, “unclear” six times and “unknown” 10 times.

In alphabetical order, the following are just some of the issues that the authors, Amec, say are uncertain:

  • Balance between conventional, LNG and unconventional gas production and consumption in future
  • Characteristics of fracking sites that will be developed
  • Cumulative effects of future operations carried out in close proximity in adjacent areas
  • Current market conditions and economic forecasts for shale gas exploration
  • Effect of shale gas production and gas storage on UK greenhouse gas emissions
  • Effects of shale gas production associated with flood risk and coastal change
  • Flowback volumes (waste material after drilling)
  • Fossil fuel prices
  • Impact of operations that take place in close succession on adjacent sites or licence areas
  • Impact of Virgin Coal Bed Methane on the environment generally
  • Impact of water use for hydraulic fracturing on water resource availability, aquatic habitats and ecosystems and water quality
  • Impacts of shale oil and gas on biodiversity and cultural heritage
  • Impacts on the historic environment, landscape and townscape quality and visual amenity
  • Location of likely well pad sites and transport corridors and their proximity to of local populations
  • Location of where activities under 14th round may take place
  • Location, distribution and phasing of sites and associated infrastructure
  • Long-term effects of the presence of hydraulic fracturing fluid underground
  • Nature, quality and proximity of “sensitive receptors” (report-speak for communities, habitats and landscapes)
  • Negative impact of gas storage on cultural heritage features because dependent on local biodiversity and cultural heritage characteristics
  • Number of shale gas wells that will be drilled under the 13th round
  • Potential for landscape enhancement during site restoration and reclamation
  • Potential negative effects on cultural heritage features and landscape of sub-surface and buried archaeology
  • Recoverable oil or gas in licence areas
  • Scale and location of future activities
  • Scale of activity under the 14th licence round
  • Sensitivity of the environment around well pad sites
  • Timing of when activities under 14th round will proceed
  • Visual intrusion of fracking sites
  • Volume of waste arisings
  • Volume of water required for hydraulic fracturing

Despite this, the report, commissioned by the Department for Energy and Climate Change, claims there could be beneficial impacts to the economy, jobs and communities. It suggests employment in the oil and gas industry could rise by 7 per cent, creating 16,000-32,000 full-time jobs. Local economies could benefit by almost £1 billion.

The report acknowledges shale oil and gas production has potential negative impacts on greenhouse gas emissions, waste, public health, land use, geology, water, air, resources and landscape.

Assumption: “regulations will mitigate negative effects”

But the authors appear to put great faith in the planning and regulatory process for dealing with any problems. There are more than 40 references to how the planning system would mitigate negative impacts, such as:

  • Adverse effects on landscape and townscape quality
  • Cumulative adverse effects on health
  • Disturbance to local communities
  • Effect of heavy goods vehicle movements
  • Impact of discharges, emissions and noise on communities
  • Visual impact of construction activities and associated machinery

The report says, for example, that regulatory controls would ensure that “elevated levels of stress and disturbance from noise nuisance, vehicle movements and particulates” were not unacceptable.

Assumption: regulations will make the effects of pollution “not unacceptable”

On the release of pollutants, the report says: “it can be anticipated that regulatory controls through the Town and Country planning system and subsequent environmental permitting will ensure that these effects are not unacceptable”. National planning policies would, it says, seek to “avoid development in areas that are sensitive, including those of high agricultural land quality”. And “any discharge of produced water and or accidental spillage of flowback water and pollutants with adverse impacts on aquatic environment would be managed through planning requirements, regulatory controls and implementation of good practice.”

Opponents of shale gas development challenge the ability of regulators to ensure that operators comply with planning conditions and permit consents. In a letter to the Prime Minister this week, Charles Metcalfe of Frack-free Balcombe Residents Association, said “To have effective regulation, the rules must be policed by the regulators. The HSE, DECC, the EA and County Councils do not have enough staff, with enough experience of the industry, to have any presence at drill-pads.”

Assumption: operators will monitor the effects of shale development

The report also proposes a number of measures to monitor the effects of shale oil and gas development on the environment. All but one require information from the operator. Opponents of fracking are critical of this type of monitoring. Tina Rothery, of Residents’ Action on Fylde Fracking told the House of Lords Economic Affairs Committee (10/12/13) “It is essentially asking the industry to mark its own homework, so we are not happy with that at all.”

Assumption: small impact on greenhouse gas emissions

The authors assume that shale gas development will have a small effect on UK greenhouse gas emissions because it would displace imported LNG (liquified natural gas). The report acknowledges that if this displaced gas were used elsewhere in the world it could increase global greenhouse gas emissions. But the report says this is dependent on global energy policy and market demand, which is, of course, uncertain.

  • The government is now consulting on the assessment and the licencing plans. The consultation closes on March 28 2014.

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