Regulation

Guest post: What’s the fracking problem with the moratorium?

pnr 190820 Ros Wills

Cuadrilla’s Preston New Road site near Blackpool, 20 August 2019. Photo: Ros Wills

As the election draws to a close, campaigner Ada Zaffina sets out for the new government what she thinks is wrong with the moratorium on fracking.


Temporary pause

The moratorium on fracking, announced by the government on 2 November 2019, has been widely criticised as an “election stunt” to hold on to voters as public support has dropped to an all-time low.

The main criticism was around the fact that this moratorium was only a temporary pause and so would be easy to reverse when “compelling new evidence is provided”.

Published a few days later, the government’s response to a consultation on whether to introduce permitted development rights for shale gas exploratory drilling left the door open to fast-tracking shale gas. It said that although not being taken forward now, “there could be considerable merit in taking forward these proposals in the future” and that “the government remains committed to making planning decisions faster and fairer for all those affected by new shale developments.”

Limited scope

The temporary nature is not the only problem with this moratorium. It is also partial in scope, only covering some fracking operations. And there is confusion about which ones.

The moratorium announcement says that the government will take a presumption against issuing Hydraulic Fracturing Consents (HFC).

The requirement for an HFC, along with other controls on shale gas exploration, was introduced by the Infrastructure Act 2015.

An HFC is given by the secretary of state for business, energy and industrial strategy (BEIS). It is required for operations that meet the “associated hydraulic fracturing” definition in the Infrastructure Act: hydraulic fracturing that “involves, or is expected to involve, the injection of:

  1. more than 1,000 cubic metres of fluid at each stage, or expected stage, of the hydraulic fracturing, or
  2. more than 10,000 cubic metres of fluid in total.”

However, since a ministerial direction from BEIS to the Oil & Gas Authority (OGA) on 29 November 2017, all operations that also meet the definition of “relevant hydraulic fracturing” (introduced in 2016 regulations for protected areas) should be referred to the secretary of state for consent.

The difference between “relevant” and “associated” hydraulic fracturing is that the volume is, or is expected to be 1,000m3 at any stage vs each stage. This does make a very big difference.

So we interpreted this to mean that the moratorium applied only to operations that meet either the definition of “associated” or “relevant” hydraulic fracturing.

Written statement confusion

But this interpretation was contradicted by the parliamentary statement by the secretary of state, Andrea Leadsom, on 4 November 2019.

Here, she referred to HFCs but also said that “the OGA are therefore unlikely to approve future Hydraulic Fracture Plans unless new evidence is presented.”

Hydraulic Fracture Plans and Hydraulic Fracturing Consents are two different things.

A Hydraulic Fracture Plan (HFP) is required by the OGA. Its main purpose is to mitigate the risk of induced seismicity through a traffic light system contained within the HFP. The OGA guidance states that an HFP will always be required for hydraulic fracturing operations (any operation where injections are above fracture gradient).

But in evidence given to Housing, Communities and Local Government (HCLGC) in 2018, the OGA seems to contradict this by saying that they would not always require an HFP for operations that were below the Infrastructure Act volume thresholds.

So it is therefore unclear when exactly an HFP is required. But it is clearly required for a wider spectrum of fracking operations than either “associated” or “relevant” hydraulic fracturing.

Therefore, Mrs Leadsom’s statement suggests that the moratorium covers a wider spectrum of operations than “associated” or “relevant” hydraulic fracturing.

Since the reason for imposing the moratorium is because “it is not possible with current technology to accurately predict the probability of tremors associated with fracking” and since seismicity is regulated through an HFP, this conclusion seems correct.

PNR fracking was neither “associated” nor “relevant” hydraulic fracturing

Neither of the Preston New Road (PNR) fracking operations in 2018 (PNR1z) and 2019 (PNR2) met the definition of “associated” or “relevant” hydraulic fracturing.

The maximum volume in any stage in both cases was only 400m3+, while the total volumes were well below 10,000m3 (see the numbers highlighted in pale salmon below).

In both cases Cuadrilla sought Hydraulic Fracturing Consent from the secretary of state because the expected volumes were much higher than those achieved in the actual operations. It appears that, had Cuadrilla made more realistic expectations, they would not have had to obtain HFCs for either of the PNR wells.

However, even if the expected volumes matched the reduced volumes actually achieved, Cuadrilla would probably have had to submit and agree Hydraulic Fracture Plans with the OGA for both operations.

191212 HF volume

Comparison of all three high volume hydraulic fracturing operations carried out in England to date

Testing the moratorium

So these confusions and contradictions indicate that the fracking problem has not gone away at all.

The first test case for the moratorium (if it is not reversed before then) might be the Wressle, North Lincolnshire planning enquiry decision, where a Hydraulic Fracture Plan is required for the planned operations.

DrillOrDrop reported that the Environment Permit for the site made 27 references to hydraulic fracturing. But volumes are not expected to meet the “associated” or “relevant” definitions of hydraulic fracturing, and therefore won’t need a Hydraulic Fracturing Consent.

Other cases to watch are the Harthill site in South Yorkshire where Ineos is pursuing a shale gas development but the company has said the moratorium has no effect since the company is not fracking, and Woodsetts (also in South Yorkshire), where Ineos has just installed new protest injunction notices.

What about acid stimulation?

In any case, the moratorium definitely does not cover matrix acid stimulation – a form of fracking carried out through injections below fracture gradient (where the rock is dissolved by acid rather than fractured under hydraulic pressure).

Campaigners suspect this form of well stimulation might already be taking place at sites in Surrey and Sussex under the guise of acid wash, therefore escaping vital protections and regulations, including the traffic light system for induced seismicity.

Given that, according to data from the British Geological Survey (BGS), Surrey is now one of the UK’s earthquake hot spots, this is a truly shocking state of affairs.

  • Ada Zaffina is a member of Brockham Oil Watch which campaigns against oil and gas development in Surrey. The group invited signatures to an open letter to the government to close this loophole and ban all forms of fracking. The letter is based on an in-depth legal briefing that goes into the above issues in more detail.

Links to sources for comparison chart of high volume hydraulic fracturing

Preese Hall, 2011

PNR1z, 2018

PNR2, 2019

52 replies »

  1. Is acid matrix stimulation a form of fracking? I suspect not, so a fracking moratorium will have no relevance to that activity.

    It would require an onshore well stimulation moratorium to address the concerns noted above.

    I note that California offshore fracking and acid matrix stimulation suspension was not related to seismic activity, which drives the present shale cracking moratorium.

    • And I see no compelling new evidence turning up in short order to overturn the moratorium on hphv shale fracking….Maybe some more testing is required out with the fylde.

      • NOW
        Thanks. I have already seen the brief, hence my comments above on some respect.

        Acid stimulation is not fracking, although it is noted as having similar risks, and I note the comments regarding regulatory issues.

        The moratorium is a fracking moratorium. If we need an acid stimulation moratorium that is a different matter, and not a missing in a shale HPHV fracking moratorium.

      • Definitions of fracking and acid stimulation by Schlumberger who have a fair amount of experience in these operations…..

        https://www.glossary.oilfield.slb.com/Terms/s/stimulation.aspx

        Stimulation: “A treatment performed to restore or enhance the productivity of a well. Stimulation treatments fall into two main groups, hydraulic fracturing treatments and matrix treatments. Fracturing treatments are performed above the fracture pressure of the reservoir formation and create a highly conductive flow path between the reservoir and the wellbore. Matrix treatments are performed below the reservoir fracture pressure and generally are designed to restore the natural permeability of the reservoir following damage to the near-wellbore area. Stimulation in shale gas reservoirs typically takes the form of hydraulic fracturing treatments.”

        Acid Stimulation: “The treatment of a reservoir formation with a stimulation fluid containing a reactive acid. In sandstone formations, the acid reacts with the soluble substances in the formation matrix to enlarge the pore spaces. In carbonate formations, the acid dissolves the entire formation matrix. In each case, the matrix acidizing treatment improves the formation permeability to enable enhanced production of reservoir fluids. Matrix acidizing operations are ideally performed at high rate, but at treatment pressures below the fracture pressure of the formation. This enables the acid to penetrate the formation and extend the depth of treatment while avoiding damage to the reservoir formation.”

        Acid Fracture Stimulation: “A well-stimulation operation in which acid, usually hydrochloric [HCl], is injected into a carbonate formation at a pressure above the formation-fracturing pressure. Flowing acid tends to etch the fracture faces in a nonuniform pattern, forming conductive channels that remain open without a propping agent after the fracture closes. The length of the etched fracture limits the effectiveness of an acid-fracture treatment. The fracture length depends on acid leakoff and acid spending. If acid fluid-loss characteristics are poor, excessive leakoff will terminate fracture extension. Similarly, if the acid spends too rapidly, the etched portion of the fracture will be too short. The major problem in fracture acidizing is the development of wormholes in the fracture face; these wormholes increase the reactive surface area and cause excessive leakoff and rapid spending of the acid. To some extent, this problem can be overcome by using inert fluid-loss additives to bridge wormholes or by using viscosified acids. Fracture acidizing is also called acid fracturing or acid-fracture treatment.”

  2. It would appear from the election results that all the areas currently being explored for hydrocarbons have returned Conservatives – with the exception of Formby which I believe is in Sefton which is Labour. As predicted, shale / oil / gas / fracking was irrelevant to this Election.

    Good to see Gina Dowding – Green – (3.7%) doing so well in the Fylde. Soon not to be our MEP post Brexit……

    Looking forward to an in depth analysis of the election results on DOD.

    • Paul

      We should start counting the days since HPHV fracking was suspended. Some expect it to reappear ( just an election con ), but I feel that a resumption is a way off …. Say 2 years plus for any shale frack, excluding any exploratory drilling or faux fracking.

      • Hewes62 – personally I don’t believe there will be any shale fracking in the Fylde again. But it is possible that INEOS may be able to demonstrate technically that a permit should be granted and one well will be fracked to see if they can successfully stimulate a shale well within the TLS which Cuadrilla failed to do. Different area / different geology / different owners etc. But that will require the moratorium to be lifted so we will have to see.

        • Paul Tresco

          Yes, I agree with you re fracking in the Fylde. I think we both posted something to that effect when the moratorium was announced.

  3. A timely report Ada Zaffina and Ruth Hayhurst. Food for thought at least.
    Now the elections are over, its back to business as usual. With a carefully written moratorium on fracking which may or may not be fit for purpose. And is not a ban.
    Liz Truss journey to USA earlier this year to investigate de-regulation including fossil fuels.
    A Brexit deal which will enable UK withdrawal from the EU ecology protection and human rights and working regulations.
    And a UK government and PM who are demonstrably funded by Russian interests, fossil fuel corporations and climate science denial organisations.
    And the earthquake swarm in Surrey. The timing of which, may or may not be the result of Acid Fracture Stimulation as mentioned in the report above. Or whatever other term the acid fracking process is regulated out by another name.

    Looks like we are in safe hands in such a critical crisis situation in the 6th Extinction event in the Earths history?

    Meanwhile in Madrid. The COP25 negotiations have typically collapsed into another lack of any real action by the attendant countries representatives. Carbon Credit Fraud and Double Carbon Accounting seems to be more important that actually doing anything about the causes.

    At least the attending scientists are trying to get the truth out there. But are any governments actually listening?

    Climate change: the trouble with trees | The Economist

    Dr Peter Carter: summarising the lack of “climate emergency” at #COP25

    Dr. William Moomaw – Humanity’s Mortality Moment

    • David King

      As

      I do not believe there has been any acid fracking in the Weald by ukog or angus.

      The fear is that it may happen.I

      The reports which consider there may be a link between recent oil and gas activity and seismic activity do not link it to acid fracking ( as it has not happened being one reason ).

      [Autocorrection manually reversed at poster’s request]

      While noting the reservations people have about such non fracking acid activities, there seems to be a creep towards linking those seismic activities to imaginary fracking activity.

      • From Ada Zaffina’s Guest post above: What’s the fracking problem with the moratorium?

        ‘What about acid stimulation?
        In any case, the moratorium definitely does not cover matrix acid stimulation – a form of fracking carried out through injections below fracture gradient (where the rock is dissolved by acid rather than fractured under hydraulic pressure).

        Campaigners suspect this form of well stimulation might already be taking place at sites in Surrey and Sussex under the guise of acid wash, therefore escaping vital protections and regulations, including the traffic light system for induced seismicity.

        Given that, according to data from the British Geological Survey (BGS), Surrey is now one of the UK’s earthquake hot spots, this is a truly shocking state of affairs.’

        • David – of course the moratorium does not cover matrix acid stimulation – because it is a moratorium on “fracking”. As you correctly note in your post “carried out through injections below fracture gradient (where the rock is dissolved by acid rather than fractured under hydraulic pressure”. Fracking cannot be caried out below the fracture gradient by definition.

          It seems to be difficult for some antis to grasp the fact that “fracking” relates to stimulation processes undertaken at pressures ABOVE the fracture gradient.

          Why should there be a moratorium or ban on acid stimulations below the fracture gradient – or even above the fracture gradient? The issue that brought about the fracking moratorium is the induced seismicity exceeding the TLS boundaries.

          • Paul, you say: ‘It seems to be difficult for some antis to grasp the fact that “fracking” relates to stimulation processes undertaken at pressures ABOVE the fracture gradient.’

            What is an ‘anti’ Paul? Whatever that is. I am not.
            And how is it that ‘fracking’ is a stimulation process undertaken at pressures ABOVE the fracture gradient difficult to grasp in relation to ‘fracking’. Or a that a stimulation process undertaken at pressures BELOW the fracture gradient difficult to grasp in relation to ‘fracking’? And how is that different in its ability to cause earthquakes in either location equally difficult to grasp?

            Just asking.

            • The seismicity “earthquakes” is induced by opening fractures in the rock by exceeding the fracture gradient of that rock using hydraulic pressure. If you don’t exceed the fracture gradient (break the rock) there will not be any induced seismicity.

              Acid fracture stimulations are also unlikely to cause induced seismicity (at least none of the ones I managed did and they were very big). In these the carbonate is opened hydraulically and the acid etches out the fractures so that when the pressure is taken off the fractures don’t close up.

              Apologies for the “anti” tag but that is basically what this BB appears to be about. Most people on here are not interested in the processes but only interested in not having any oil and gas operations anywhere near there homes. They raise issues about processes which have no impacts and which have been undertaken for many years without problems. Fracturing shale is new to the UK, at least with high volume stimulations, and in the Fylde these operations have induced seismicity which has resulted in the TLS shutting them down.

              So why should there be a moratorium or ban on acid stimulations below the fracture gradient – or even above the fracture gradient? The issue that brought about the fracking moratorium is the induced seismicity exceeding the TLS boundaries.

              • Thankyou for replying Paul. I will read through that more when i get the chance.

                I dont believe i am ‘anti’ anything to any great degree. Apart from obvious ones. Only that there are wider implications to almost everything in these times. I am sure i would prefer to be ‘pro’ solutions, rather than ‘anti’ problems.

                Opposition taken to extremes tends to consolidate positions in a process called ‘polarisation’ and entrench sides even more. I think its better to work on a problem without entrenching one side or the other, or both. And to seek solutions that may well transform problems into solutions. However that might be achieved or defined.

                And we all have some very big problems to seek solutions to.
                One way or the other. It had better be fast.

        • David King
          Yes..Ada has it wrong in saying that acid stimulation is a form of fracking as it is not ( as the note explains after that statement).

          Hence a moratorium based on hphv shale fracking ( which is not a ban, as noted by the Scottish courts for the Scottish moratorium ) is not relevant to it.

          Perhaps the title of the long read should cover the issues around the moratorium, and add ‘and we would like a ban on all UK onshore unconventional oil and gas development’s’. Which is the gist of the BOW information paper on the issue.

    • I heard the end of something on Radio4 yesterday morning (Dieter Helm?) which pretty much said that Europe (including us) has failed to make an impression on carbon output due to the increasing reliance on China / India / Indonesia etc. to manufacture Europe’s consumables such as cement and steel and consumer goods. Any progress made in Europe by decarbonising electricity etc has been more than offset by importing manufactured goods and materials from overseas. It also said that Donald Trump’s policy of increasing manufacturing in the US and reducing imports through his trade tariffs, and switching from coal to shale gas, was having significantly more impact on global carbon reduction than anything Europe has done. So the message seems to be forget the IPCC, make stuff at home and cut imports….

      We will shortly be in a position to do this post Brexit. Europe also seems to be getting this message based on recent announcements.

      • hewes62, if you read our paper and the foreword, you will see that what we’re arguing is that all well stimulation treatments of unconventional (i.e. low permeability) rocks are ‘fracking’ and all should be regulated in the same way. The term ‘fracking’ is not well defined, and it has changed meaning as technology progressed. Especially when you refer to the public’s understanding, it is entirely correct to refer to matrix acidisation as ‘fracking’ as an all-encompassing term for unconventional extraction. Matrix acid stimulation enlarges existing and creates new fractures in a rock, so even if done below hydraulic pressure, it still causes fracturing to release hydrocarbons from the rock. We are arguing that the definition of fracking in UK should follow California legislation (SB4) and regulations on fracking, which explicitly include both: hydraulic fracturing and acid stimulation (INCLUDING matrix acidisation). So we are not wrong in this analysis and there is at least one precedent in law.
        Another point to make is that currently there is very little regulation for acid injections, and there is a risk of acid stimulation going on under the guise of acid wash. There is NO reporting requirement for this, which means that acid stimulation can be taking place but we, or even the regulators, are not told any details – no volumes, injection pressures, not even dates, nothing. This means that nobody can analyse any potential links between those injections and the Surrey earthquakes. There is simply no information available to analyse.
        You will also see from the table above that the injections that caused PNR1 and PNR2 micro seismic events were relatively small volume, they are well below what the expectation is for high volume fracking.

          • BOW

            Do regulations for all Matrix Acidisations below fracture pressureneed to be brought to the same level as the standard for high volume hydraulic fracturing?

            What would be your take on the proposed acidisation of the Wressle Well say?

        • BOW
          I disagree with your stance that all well stimulations in low permeability rock should be classed as fracking.

          I will provide a broader reasoning later … Busy weekend.

          • Sure, hewes62. A conversation about this issue is exactly what is required to raise public awareness. What are your credentials by the way? Happy to be criticised, but it would only be fair to know who it’s coming from.

            • BOW

              Yes, one expect some agreement and or disagreement and a conversation if one posts on here or produce information supporting a view one has.

              Plus, public awareness and understanding of subjects is important. Something I am always aware of when attending presentations (INEOS in the main ), or other events, such as the Wressle planning review.

              My credentials. Mining Engineer with experience in UK coal mining and then Offshore / onshore oil and gas UK and globally. Chartered Engineer and Ex FIMME ( I say ex as I no longer pay the dues to retain the title, and one should not take credit for the titles unless coughing up the cash ). MIOSH

              I have been interested in the issues around shale gas, and as an extension, other onshore oil and gas extraction recently, ever since I ran across an anti fracking stall in Retford ( and you will not be surprised to know that I disagreed with some of the claims being made but not all)

              And your credentials?

              • We note that you remain anonymous. We are a group of local people who care. One identified above with credentials of a nerdy campaigner drawing on BOW’s collective experience in engineering, environmental regulations, environmental impact assessment, sustainable development, as well as expert legal advice from Harrison Grant solicitors and scientific advice from David K. Smythe – Emeritus Professor of Geophysics at the University of Glasgow.

                • So no upstream oil and gas experience in BOW, at least not in stimulation, drilling, petroleum engineering, petrophysics, production, process, wellsite supervision or operations mangagement in your local group? No experience in planning, engineering and executing the stimulations you are opposed to? No experience using acid in oil and gas wells? No hydraulic fracture stimulation experience? No onshore UK drilling and production experience?

                  It would appear that BOW are missing key technical experience in the organisation.

                • BOW

                  Part 4 of the considered reply

                  e) Another point to make is that currently there is very little regulation for acid injections, and there is a risk of acid stimulation going on under the guise of acid wash. There is NO reporting requirement for this, which means that acid stimulation can be taking place but we, or even the regulators, are not told any details – no volumes, injection pressures, not even dates, nothing.

                  An interesting point…..

                  There is indeed less public reporting of such activities in the past and recently, as (as noted in the legal brief) it was considered to be a normal and infrequent activity and not recorded.

                  The parliamentary reply referred to in the legal brief does give an insight into the environmental regulation of the activity. I include the full reply below, the legal brief only quotes the first paragraph.

                  Question

                  In a written parliamentary question earlier this year, Dr David Drew MP asked the Secretary of State for BEIS whether the consent process for acidising is the same as for fracking.In response, Claire Perry MP stated “Acidisation refers to a number of techniques used to clean wells to improve productivity”.

                  Reply below.

                  Acidisation refers to a number of techniques used to clean wells to improve productivity. Activities at oil and gas sites (including acidisation) are controlled under the Environmental Permitting (England and Wales) Regulations 2016 and regulated by the Environment Agency.
                  When assessing an environmental permit application the Environment Agency considers the proposed activity, the chemicals and products used in the process, waste management and the environmental setting. The permit ensures that there are appropriate mitigation measures in place to protect people and the environment. If the proposed activity poses an unacceptable risk to the environment it will not be permitted.
                  There are currently 78 onshore oil and gas sites permitted by the Environment Agency, some of these sites will be allowed to use the acidisation technique as part of their processes.

                  The legal brief says…

                  This inaccurate statement highlights the concerns of Brockham Oil Watch and others, who fear acid stimulation and its environmental consequences are not sufficiently understood by politicians and, as a consequence, are not subject to appropriate regulation.

                  In my opinion, the gov statement rightly describes the present state of regulation for those activities although the civil service (who provide the answer for the minister to approve and give) could have done better by saying.

                  It depends on the specific acidizing process taking place.. And then to add the existing reply, replacing the word ‘to’ in the first line to ‘and’. Hence, reading as follows …

                  Acidisation refers to a number of techniques used to clean wells and improve productivity.

                  However, the minister would be replying to the initial ( inaccurate ) question, which the legal brief considers was asked by a politician who does not sufficiently understand acid stimulation and its environmental consequences, I am not surprised that he got a generic reply.

                  A such, I believe that more comprehensive regulation could be enacted to cover well stimulation, especially any that would require the back to back drilling of wells and multiple stimulation stages in order to make extraction commercial. And that the EA and the planning process has an overview of any such developing process (which would come from drilling multiple wells in tight formations that can be acidized and including various requirements for acid use, storage and expected waste disposal amounts etc etc).

                  The regulators, should be developing suitable regulation should that activity be seen on the horizon (and not just some hopeful thinking in a share prospectus ), and in the meantime keeping a suitable eye on any small scale planned activities via the existing permitting regime.

                  I take the point that, as reporting requirements are not as comprehensive as those required by the Californian regulation, and will address that issue in the reply covering seismic activity.

        • BOW

          First part of the more considered reply

          hewes62, if you read our paper and the foreword, you will see that what we’re arguing is that all well stimulation treatments of unconventional (i.e. low permeability) rocks are ‘fracking’ and all should be regulated in the same way.

          Yes, I note that but disagree with that as shown below

          a) The term ‘fracking’ is not well defined, and it has changed meaning as technology progressed.

          I disagree

          The term ‘fracking’ is well defined. As Paul Tresco Notes, it requires the rock to be fractured.
          Petrowiki notes that ‘Hydraulic fracturing is the process of pumping fluid into a wellbore at an injection rate that is too high for the formation to accept without breaking’.
          That it is not defined in law is a different matter. The law relating to fracking will no doubt change as technology progresses, but the physical meaning of fracking is quite clear.

          b) Especially when you refer to the public’s understanding, it is entirely correct to refer to matrix acidisation as ‘fracking’ as an all-encompassing term for unconventional extraction.

          I disagree

          The key linked study, in the legal briefing, for the American publics understanding is below

          https://deepblue.lib.umich.edu/handle/2027.42/138020

          The study notes, inter alia that

          ‘Such oil and gas development at a large scale has come to be known as “fracking” in the public’s mind, regardless of a particular well’s depth, orientation or fluid volume used’.

          This finding is interesting, but that is no reason why matrix acidisation, at a pressure below that to fracture the rock should be called fracking, when it is not, and the research does not reach a conclusion that what is not fracking should be considered as such.

          As the research notes …

          …..’These different meanings of “fracking” can be problematic, especially when communicating about potential risks. Many of the concerns the public raises about HVHF are, by industry standards, risks associated with other oil and gas processes—and not actual fracking84′

          The key issue is that the different meanings of ‘fracking’ can be problematic, it does not recommend applying an extra layer of confusion to the issue by adding processes that are not fracking to the term. Although, looking at some of the input to DoD, some people are already confusing matrix acidizing with HPHV Shale fracking.

          The reference, no 84 can be found in the link below you need to click on the title. It is an interesting read in its own right.

          Title …. Primer on hydraulic fracturing concerning initiatives on energy sustainability

          https://scholar.google.com/citations?user=nm_UCfAAAAAJ&hl=en#d=gs_md_cita-d&u=%2Fcitations%3Fview_op%3Dview_citation%26hl%3Den%26user%3Dnm_UCfAAAAAJ%26citation_for_view%3Dnm_ %3AYsMSGLbcyi4C%26tzom%3D0

          Hence, on these two issues, fracking is well defined (but more on appropriate legislation later ) and public perception is not a reason to alter a Scientific term, although more later on the term ‘unconventional’ which while a relative construct, has clearer definition than some years ago (what was unconventional in 1990 is not unconventional now in respect of mobile phones, so maybe the term ‘tight’ is better ).

        • BOW

          Part 2 of the considered reply

          This follows on from Part 1 which has disappeared into DoD purdah I suspect.

          I also disagree with the use of the term fracking as ‘an all-encompassing word for unconventional extraction (to include matrix acidisation ) , out with issue of public perception.

          As the legal briefing notes ….

          ‘The Government estimates that some 200 wells in the UK have been hydraulically fractured5 . However, it is critical to understand that these operations, sometimes referred to as ‘conventional fracking’, were carried out on vertical wells in conventional (high permeability) formations. The first hydraulic fracturing of unconventional (low permeability) shale rock in the UK was carried out in 2011 at Preese Hall’….

          From this, it seems clear to me that using fracking as an all encompassing term for unconventional extraction is not appropriate. To use it as such could (or does ) lead people to assume that any frack, be it in any reservoir and for any purpose has the same impacts as you would expect from HPHV shale fracking and / or lower pressure / lower volume, multiple wells matrix acidisation.

          Just as using the term matrix acidisation, without understanding the context of the application, could lead to similar concerns.

          c) Matrix acid stimulation enlarges existing and creates new fractures in a rock, so even if done below hydraulic pressure, it still causes fracturing to release hydrocarbons from the rock.

          I disagree that matrix acid stimulation causes new fractures in the rock, when carried out below the pressure required to fracture the rock.

          As Rigzone notes

          ‘A matrix acid job is performed when acid is pumped into the well and into the pores of the reservoir rocks. In this form of acidization, the acids dissolve the sediments and mud solids that are inhibiting the permeability of the rock, enlarging the natural pores of the reservoir and stimulating flow of hydrocarbons.

          While matrix acidizing is done at a low enough pressure to keep from fracturing the reservoir rock, fracture acidizing involves pumping highly pressurized acid into the well, physically fracturing the reservoir rock and dissolving the permeability inhibitive sediments. This type of acid job forms channels through which the hydrocarbons can flow’.

          …I would note that the legal brief does say that matrix acidisation below fracture pressure creates fractures so I am not sure if that is an accepted BOW group belief (or if I am wrong, if anyone knows otherwise ).

          • Hewes – adding to your note above – matrix acidiscation of sandstones does not create fractures but improves existing permeability. Clearly not “fracking”. Probably the most common stimulation of none shale rocks after mud acid washes

            • Paul Tresco

              Thanks. Its all quite interesting. a new issue for everyone to get their teeth into while the moratorium rolls on.

          • The California law regulates all well stimulation treatments in the same way because they all pose similar risks to the environment and public health. This is the underlying argument for our brief. If you see that the law is not consistent on this, can you point out exactly where.

            On your 2nd point, whether fractures are created by hydraulic pressure (physically fracturing the rock) or by dissolving the rock is in our view irrelevant. Regardless of whether it is a mechanical process or a chemical process, it creates the same risks, and there’s a robust argument that the chemical process is actually more damaging than the mechanical one because it means more chemical pollution pumped underground and coming back up to the surface for disposal.

            • BOW – fractures created by hydraulic pressure are exactly that – fractures. Fractures are not created by acid alone – this is not possible. As soon as acid is spent the only contact is spent acid on the rock and no further reaction. So very limited and certainly not fractures. For an acid fracture treatment you need the hydraulic pressure to make the fractures as in a conventional hydraulic fracture treatment. A none acid hydraulic fracture needs sand to keep the fracture open when the pressure is removed. An acid fracture uses hydraulic pressure to open a fracture and the acid etches the fracture surface so that it remains open when the pressure is removed without the need for a sand proppant. This is why acid fracks are generally in carbonates because HCl is good at dissolving carbonates. As for creating “the same risk” that comes down to each individual operation and risk management of that operation. But in my opinion having worked extensively in this part of the industry, acid fracture stimulations have significantly lower risk to the environment. Spent acid is exactly that – spent acid. There are many other applications for acid in other industries which result in similar spent acid which is disposed of regularly without fuss. There is no “robust argument” that I have seen that persuades me that using acid is more damaging than high volume hydraulic fracturing of shales. There is a small risk which is easily managed to personnel on the rig site with acid mixing and pumping but that is all.

              The sub surface risk is more to do with the type of rock and size and number of treatments and is only related to the hydraulic part of the operation. Hence shale gas / oil fracture stimulations will be higher risk due to the possibility of induced sesismicity as shown by Cuadrilla in the Fylde.

              As for California….it is a very odd State and who knows why they came up with this regulation.

            • BOW

              You say

              We are arguing that the definition of fracking in UK should follow California legislation (SB4) and regulations on fracking, which explicitly include both hydraulic fracturing and acid stimulation (INCLUDING matrix acidisation). So we are not wrong in this analysis and there is at least one precedent in law…

              My point is that Californian law has regulation on well stimulation that include fracking (not regulations on fracking that include both hydraulic fracturing and acid stimulation). I would not disagree that this is a suitable approach to the situation. But it would point against the claim that acid stimulation is fracking by stealth, rather that well stimulation is a broad subject, which includes fracking.

              You then say

              The California law regulates all well stimulation treatments in the same way because they all pose similar risks to the environment and public health. This is the underlying argument for our brief. If you see that the law is not consistent on this, can you point out exactly where…

              Yes, that is the premise of the California law to regulate oil and gas well stimulation all well stimulation activities (other than those excluded ) in the same way. The Californian law is consistent in its approach to the regulation of such activities. Hence my link to the legislation ( no need to root about in the legal brief).

              They, however, do seem to be a bit brief on the seismic risks from HPHV fracking (I have not found their traffic light system, to be used in all cases of well stimulation). So it would be good if you could point me to that particular missing (this may well be because they are more worried about injection wells than the actual fracking per se )

              Regarding the underlying argument of the briefing, in the conclusions it argues that the law should…..

              ‘To urgently tackle climate change and given the climate change impacts of the extraction and use of oil and gas trapped in unconventional formations’:

              1. Ban all well stimulation, including water-based hydraulic fracturing and acid stimulation, for oil and gas exploration and production (in such formations I assume, and I also assume this is for onshore oil and gas production?)

              That is not in line with Californian legislation, although it is in line with the wishes of CAF

              Then, in the interim (or while leading up to the ban on anything but conventional extraction )

              3. Require all regulators of the shale oil and gas exploration and production industry to apply this amended Petroleum Act 1998 definition consistently across the entire regulatory regime to ensure that all prohibitions and restrictions and monitoring and reporting requirements currently applicable to high-volume hydraulic fracturing apply to all well stimulation treatments, including:
              a. The requirement to draw up a “well-stimulation plan” (currently a hydraulic fracture plan); and
              b. The requirement for a traffic light monitoring system to monitor and manage induced seismicity……….

              That requirement clears up the volume issues around shale fracturing (and no doubt open for discussion ), but it excludes non shale stimulation, whereas the Californian regulations do not differentiate between any geology (be it shale / tight / conventional ) or have i got that wrong?

              4. For the purposes of environmental permitting and monitoring:

              a. introduce a volume-based definition of matrix acidising as an acid stimulation that penetrates 1 meter or more away from the wellbore (to distinguish from acid wash treatments); and
              b. require the submission of detailed injection charts to the EA for all injected fluids, including volumes of fluid pumped, injection depth, pressures, and timings.
              c. require the disclosure of information, including to the public, about all chemicals and the amounts used in each acid stimulation treatment,
              including chemicals subject to the ‘de minimis’exclusion.

              I just presume that all this applies to unconventional developments, could you clarify if that is the case? My assumption is based on the caveat at the introduction to the recommendations.

              5. Amend the Minerals NPPG:
              a. To replace “hydraulic fracturing” with “well stimulation”, including at para.129 and amend the definition at parat.129 in line with the
              proposed Petroleum 1998 Act definition;
              b. To clarify that para.130 is only one form of well stimulation technique; and
              c. To include at para.119 a presumption in favour of an EIA in all cases involving well stimulation.

              My only thoughts are, does this mean that in the minerals NPPG would exempt non unconventional well stimulation (the ‘traditional fracking mentioned in the introduction to the conclusions ) or is this a cover all for all stimulation activities, and not dependant on reservoir characteristics?

              Hence, although the conclusions do lean towards a California type approach there seems to be some differences in application, lack of clarity in application and an overall wish to ban all unconventional reservoir well stimulation activities (which is the same as banning all unconventional oil and gas developments in the UK I expect ).

              As the legal briefing notes

              ‘The Government estimates that some 200 wells in the UK have been hydraulically fractured5 . However, it is critical to understand that these operations, sometimes referred to as ‘conventional fracking’, were carried out on vertical wells in conventional (high permeability) formations’.

              Hence my assumption that the requirements similar to the Californian regulations would not apply to such ‘conventional fracking’ or (following the gist of the brief) that an exemption would be applied to such activities as described although this is not laid our clearly in the recommendations.

              .

              • Hewes – another point relating to the above: 200 wells in the UK have been hydraulically fractured……

                Not sure why fracking in vertical wells is okay and fracking in deviated / horizontal wells is not? Technically why are the risks different? To anyone other than commercial risks to the well operator. Also if the wells had high permeability why would a company hydraulically fracture them? Makes no sense. They may have been conventional SST / LST reservoirs which were very tight and would not flow economic rates, even zero, and were fracked to improve productivity to a commercial level. Or they were perhaps fracked for gravel packing purposes. And I don’t believe they were all vertical wells. We (Amoco) had highly deviated wells in Hampshire; BP had highly deviated wells at Wytch Farm in Dorset. Several of these were stimulated although I don’t recall if they were fracked / acidised or combination of both.

                BOW – 2/10 for homework…..

                • Paul Tresco

                  Thanks

                  Maybe BOW will clarify the exact scope of the reports recommendations.

                  Just need finish off the next reply …. Seismic activity in the weald and why the proposed regulations would help ( or not if based on Californian law ).

                  Maybe the Californian seismic traffic light system will be found. Or maybe California have gone down the well stimulation route as the have relatively little fracking?

                • Dear BOW

                  Thanks. No rush for a reply.

                  BTW….not sure which one of us you need to know more about, but if myself could you clarify what additional information you require to ‘know who I am’ ( and as a quid pro quo, who posts under the pseudonym BOW?).

                • Not sure why using your own name is considered anonymous Hewes62? (“whoever you are, would you like to identify yourself?”). Perhaps BOW wants you to make a name up? Happy festive season and thanks for all the research and work you put into your well thought out responses on DOD. Of course your extensive industry experience is a big help.

                • Paul Tresco

                  Thanks. It has been an interesting year and I expect 2020 to be as interesting.

                  Meanwhile I will think up a suitable pseudonym, may be Brian Oliver Wright will do.

                  Or perhaps it is a coded greeting used in BOW meetings?

        • BOW

          Section 3 of the considered reply

          d) We are arguing that the definition of fracking in UK should follow California legislation (SB4) and regulations on fracking, which explicitly include both: hydraulic fracturing and acid stimulation (INCLUDING matrix acidisation). So we are not wrong in this analysis and there is at least one precedent in law.

          https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201320140SB4

          I disagree.

          The California regulations (link above) regulate well stimulation treatment, and include fracking in that definition (with some exclusions), not vica versa.

          That is an important distinction as to say otherwise may lead the ‘confused public’ to believe that the legislation covers all aspects of fracking (from drilling the well through to popping the gas into a pipeline ), but it does not, with any legal limit on seismic activity being a big miss for that law which covers HPHV shale fracking, should California wish to do that big time ( as far as I can see that is ).

          Specifically

          In that legislation, fracking is defined as …..

          3152.
          “Hydraulic fracturing” means a well stimulation treatment that, in whole or in part, includes the pressurized injection of hydraulic fracturing fluid or fluids into an underground geologic formation in order to fracture or with the intent to fracture the formation, thereby causing or enhancing, for the purposes of this division, the production of oil or gas from a well……

          Well Stimulation is defined as

          3158.
          “Acid well stimulation treatment” means a well stimulation treatment that uses, in whole or in part, the application of one or more acids to the well or underground geologic formation. The acid well stimulation treatment may be at any applied pressure and may be used in combination with hydraulic fracturing treatments or other well stimulation treatments. Acid well stimulation treatments include acid matrix stimulation treatments and acid fracturing treatments. Acid matrix stimulation treatments are acid treatments conducted at pressures lower than the applied pressure necessary to fracture the underground geologic formation……

          It is important to note that they have included acid fracking in the definition of ‘acid well stimulation treatment’ but have not included all fracking under that term.

          It is worth noting that in the definitions, there is further clarification as to the meaning of ‘well stimulation treatment’ in ‘this article’, which includes hydraulic fracking and acid well stimulation treatments. Plus there are some exclusions, which would mean that the law does not apply equally to all,as follow

          3157.
          (a) For purposes of this article, “well stimulation treatment” means any treatment of a well designed to enhance oil and gas production or recovery by increasing the permeability of the formation. Well stimulation treatments include, but are not limited to, hydraulic fracturing treatments and acid well stimulation treatments.

          (b) Well stimulation treatments do not include steam flooding, water flooding, or cyclic steaming and do not include routine well cleanout work, routine well maintenance, routine removal of formation damage due to drilling, bottom hole pressure surveys, or routine activities that do not affect the integrity of the well or the formation……

          It is the above section that brings fracking (in any form related to oil and gas development) into the well stimulation regulations.

          The California Law has developed in some respect due to the particular circumstances of the local reservoirs it seems, as well as near shore offshore, offshore oil and gas platforms dumping expended stimulation fluid into the ocean ( an avenue of discussion should anyone want to stimulate a well nearshore in the UK I guess ).

          The report ‘An Independent Scienti¬c Assessment of Well Stimulation in California’ has some interesting facts on fracking and matricxacidisation ( start at page 69 ). The report is dated 2015, so things may have changed a bit.

          Click to access 160708-sb4-vol-I.pdf

          CAF (California against Fracking) also has views on the issue, and while a shorter read than the link above, has some interesting background information to digest, although they pine after a moratorium on fracking it seems listing areas where it is banned ( but not any areas where well stimulation is banned)

          Click to access fracking-and-drilling-in-california.pdf

          That there is such a law is interesting however, should the UK consider extending the existing regulations to cover acidisation in a more comprehensive way, I am sure that they will take that law into consideration and vica versa.
          A full comparison of Californian legal requirements vs UK requirements would be a good start to see here the gaps are in both cases.
          However, it seems that in California, their legislation was very lax compared to UK oil and gas regulation and they are playing catch up. Good that they have done this and in one respect have covered well stimulation in a more comprehensive way than the UK, which does not have such a history of intensive development, lax regulation and ( it seems ) less water.
          In terms of seismic activity, they seem more concerned with wastewater injection than fracking per se, which may be why fracking has been subsumed into the well stimulation regulations.

      • Paul Tresto. You are right that we have been importing consumables from China and India for some time now. That is one way the government has attempted to boast that they have lowered our carbon emissions when In fact they have just exported the problem elsewhere. I doubt we will be “making stuff at home to cut imports” as you say, however, on any large scale anyway. Workers in China and India receive far lower pay than workers in this country could survive on, given our cost of living. Are you advocating UK pay levels should drop to that level. If not the price of goods will rise dramatically.

        • Pauline – Stop free trade, impose tariffs and cut carbon emissions aka the US. Make stuff in Europe. Even better stop buying useless consumer goods. Stop buying new clothes every 5 minutes. Keep your TV for more than 5 years. Buy second hand cars. Get rid of domestic cats…

  4. hewes62-I suspect your time line is around correct, and I believe it will be related to a drive towards hydrogen production to power green buses, trains, vans and then cars.

    Lot easier to justify fracking leading towards Net Zero.

    • Martin

      Yes. I am not sure that battery storage will cut it, although mining machinery manufacturers are drooling at the thought of all the mining required to fill the need ( and to dispose of them after ).

      There is a bit of fuss in the financial press about Orkney hydrogen ( spare wind…tidal to hydrogen ), so where there is a will there is a way no doubt, and they advise investing in the companies involved to !and a killing ( as you would expect ).

      Meanwhile Locals invested in Sirius hope that the much awaited Brexit event might allow the gov to give the company a bung to keep going.

  5. Precisely so. Here in Pendle, the Conservative MP at the Hustings made the false claim that Fracking has been banned. We corrected him and showed the same evidence as your article does that it was only a moratorium. He then said he was personally against Fracking after supporting it all all the way in Pendle and East Lancashire, where Osprey have active Licences, up to the General Election. What hyprocrisy! Dave Penney Keep East Lancashire Frack Free

  6. Further to my previous comment re Conservative Pendle MP, the threat of fracking is now greater in East Lancashire as both Burnley and Hyndburn have replaced Labour with Conservative MPs

    • Well, David, it either means the more of the good people of Lancashire are idiots-or, it means they have different views to yourself.

      I suspect it is that they are not as motivated against fracking as some would like to insist.

      • Martin. I think you know quite well that this election has been dominated by Brexit and fracking has been very low on most people’s agenda. Particularly since the Tories took the precaution of conveniently announcing the moratorium to coincide with the election. The majority of voters are not so knowledgable about the finer points of what qualifies as fracking or even what constitutes a moratorium compared with a ban. Many I’ve spoken to here in the Fylde are under the impression fracking is now over. In their minds, the Tory announcement of a moratorium meant the threat of fracking was no more.

  7. BOW

    You asked for my credentials, which I have supplied. I thought it only fair to ask the same question of whoever is penning the comments for BOW.

    I am slightly disappointed in the comment about my being anonymous. What does that have to do with theories raised in the long read?

    However, as you ask, My name is Hewes ( and there are 3 photographs on DoD in which I appear). Given the intellectual horsepower at your disposal ( and the information provided by me ) you have a head start of you need to know more.

    I respect your present position of remaining anonymous behind the group title, and have no desire to know who you are and so forth as that is not relevant to my comments on the long read and subsequent comments on here.

    Meanwhile I am enjoying the various linked articles on all the links provided through the various reports and will.comment in more detail soon.I

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