12th April 2014
The Frack Free Balcombe Residents’ Association (FFBRA) has called for a block on all future onshore oil and gas licences in the UK. It also says Environmental Impact Assessments should be carried out on all existing licences.
The organisation was responding to the government’s consultation on the next round of oil and gas licencing, which is likely to cover about 60% of the country.
In a 10-page document, FFBRA identifies what it regards as failings in the Strategic Environmental Assessment (SEA), commissioned by the Department for Energy and Climate Change and produced by the consultancy, AMEC.
FFBRA says expansion of the industry should be halted until there are techniques that can properly assess its impacts. The risks of contamination of air and water make the industry “to dangerous to proceed with”, FFBRA says.
Criticism of the Strategic Environmental Assessment
FFBRA says the SEA should not conclude that there is “a cumulative minor negative effect” from air emissions or that “effects can be mitigated through planning and regulatory controls”. The organisation argues:
- There are no long-term studies on the health effects of chronic exposure of human populations to the emissions from shale gas/oil extraction so the long term risk is not known
- Emissions may critically affect people with an existing condition, such as respiratory or cardiovascular disease.
- Risks to residents living within 400 metres of a well pad may be very significant due to exposure to products of flaring and radon, compressors and pipe networks
FFBRA says claims that the regulatory regime can mitigate the recognised health effects from shale emissions are unfounded and the trend towards self-monitoring by operators is not stringent enough to prevent serious illness
- The Environment Agency imposed no emissions limits from flaring on Cuadrilla for flow testing the well at Balcombe
- Cuadrilla will self-monitor with one monthly spot test
- Cuadrilla is not required to monitor atmospheric polycyclic aromatic hydrocarbons (PAHs), particulate matter or radon emissions
- Emission limits do not take account of a mixture of endocrine-disrupting chemicals, which FFBRA says, can be particularly harmful prenatally or in children.
- Regulation cannot mitigate or regulate emissions through geological faults
FFBRA says the SEA does not consider a range of issues on air emissions, including:
- Endocrine disruption through chronic exposure to airborne emissions
- Risk of persistent organic chemicals entering the food chain
- Depressive illnesses for those living in oil/gas fields
- Low-level chronic exposure to many chemicals simultaneously
- Radon, which FFBRA says cannot easily be separated by shale gas, could be released into indoor areas when shale gas is piped into homes
FFBRA calls for:
- Clarification that extended exposure to emissions typically associated with shale gas/oil operations pose a serious mortality and morbidity risk
- Publication of statistics on expected mortality and morbidity
- Investigations into the interaction of components in air emissions and low-level chronic exposure to many chemicals simultaneously
- Cumulative risks to be estimated using a verifiable method
- Continuous monitoring of all toxic emissions from flares at nearest properties
- Continuous monitoring of radon within shale gas and publication of total radioactive count
- Capping and reuse of all fugitive methane emissions, rather than venting or flaring
- Monitoring by continuous methods which record spikes in levels and fluctuations in concentrations
- Strategy to remedy immediately occasions when emissions levels breach safe limits
The SEA recommends that lorries serving shale oil and gas sites should avoid residential areas but does not say what should happen if this is not possible. FFBRA says the SEA does not describe what the lorries will be like (30,000 ltr tankers, FFBRA says). Nor does it propose measures to repair roads damaged by vehicles, the cost of which in some US states is $billions.
Landscape and visual impacts
FFBRA says the SEA’s suggestion that a site could return to what it was before is “fantastical and ill-informed”. The organisation says the SEA does not define landscape, is unclear about the methodology for measuring impact and oversimplified in its conclusions.
FFBRA is particularly critical of the suggestion that a complete loss of habitat is regarded as a “minor adverse effect” with only local impact. FFBRA also describes as “comical” the suggestion that a 26m drilling rig could be minimised through appropriate setting, screening and managing the extent of overlook.
FFBRA criticises the SEA for not assessing the costs to communities. It estimates property values in Balcombe will drop by £125m. “There is no community benefit”, it says. “There is a huge potential loss to individuals”. It also predicts a significant loss of jobs in rural areas because of the effects of drilling on tourism, farming and recreational activities.
The organisation calls for a bond to cover uninsurable damage to homes, health and activities. It says there should be a realistic assessment of the costs to local communities. And it recommends that the industry should pay for its own policing, in the same way that football clubs pay for policing at football matches.