Written evidence submitted by the Keep Kirdford and Wisborough Green, KKWG (RUT0126)
Submitter
KEY QUESTIONS raised by the Committee
Application for Exploratory Oil/Gas drilling within PEDL 234, West Sussex
“This study has identified the potential for a significant volume of oil-mature shale to be present at several horizons in the centre of the Jurassic, but shales further west and on the northern and southern flanks are not considered mature for oil generation (Figure 50)….
“This study concludes that there is no significant Jurassic shale gas potential in the Weald Basin. Even the deepest Lias shales are unlikely to have attached sufficient maturity to allow for significant gas generation.
“….Some of the most prospective plays are in environmentally sensitive areas, in National Parks, Areas of Outstanding National Beauty or under towns and villages (Figure 52). Shale oil exploration and potential development should progress cautiously to ensure the activity is safe and the environment is properly protected.”
The Jurassic Shales of the Weald Basin – Geology, Shale Oil and Shale Gas Estimation, British Geological Society, May 23, 2014 |
“There is no doubt that this is a very dirty, noisy industry” and “You should never frack near or close to a fault line!”[3]
http://www.medact.org/wp-content/uploads/2015/04/medact_fracking-report_WEB4.pdf
31 Tourism provides millions of permanent jobs for the rural economy (over 3.1 million in 2013, according to Visit Britain).
32. Fracking would only provide a small number of short-term jobs at each well-site.
34. Most jobs on fracking well-sites would go to specialists brought in on fixed contracts, not local people.
“Shale gas may transform a previously pristine and quiet natural region, bringing increased industrialisation. As a result, rural economy businesses that rely on clean air, land, water and/or a tranquil environment may suffer losses from this change, such as agriculture, tourism, organic farming, hunting, fishing and outdoor recre-ation.”
These are the major assets of rural communities.
CUMULATIVE IMPACTS
Conclusions
− It is clear from the current evidence concerning Climate Change and with the Paris Convention recently agreed (Dec, 2015) and now jointly signed by China and the USA (September 2nd, 2016) that the most difficult to get at fossil fuel resources should NOT be being exploited, rather they should stay in the ground.
− Britain’s fracking regulations may be inadequate to prevent environmentally dama-ging methane leaks from shale gas production, the Government’s official climate change advisers have warned.
− The Committee on Climate Change said that large-scale shale gas extraction in the UK would not be compatible with the UK’s targets to drastically reduce greenhouse gas emissions unless three key tests were met to minimise its impacts.
− The National Aeronautics and Space Administration's (NASA) top climate scientist announced that the Earth is warming at a pace not seen in at least the past 1,000 years, making it "very unlikely" that global temperatures will stay below the 1.5O C limit agreed to in the landmark climate treaty negotiated in Paris last December.
− Widespread fracking should not be undertaken – the UK is too small, has densely populated cities, has many different landscapes much valued by tourism, an inade-quate infrastructure such as facilities for dealing with wastewater and the underlying geology is riddled with faults which cannot mix with such drilling.
− Not only would such an industry have a very damaging effect on tourism in rural areas, we believe that the shale gas industry threatens the UK.
− We feel that Defra has a duty to oppose such developments within government, and should instead be working with the Local Government Association to promote sustainable, low-impact tourism in order to preserve the English countryside.
− The current access points to the South Downs National Park are overwhelmingly reliant on the car which contributes to climate change and public transport issues need addressing as is happening in the New Forest, Derbyshire Dales and Lake District.
Recommendations:
− We recommend that the EFRA Select Committee should commission a new independent report concerning the impacts of the shale gas industry on the rural economy, including rural tourism.
− Until such a report is produced, the EFRA Select Committee (in line with the recommendation of the Environment Audit Committee) should demand an immediate moratorium on fracking and other forms of unconventional gas production.
− A great many recommendations for research were made at the recent US-UK workshop held to consider hydraulic fracturing in Arlington, November 2015. These should be considered in the context of whether or not they would result in adverse impacts on the rural economy.
Joint US-UK workshop on Improving Understanding of Potential Environmental Impacts Associated with Unconventional Hydrocarbons, 5-6 November 2015, Arlington, Washington DC, USA
NERC and the United States National Science Foundation (NSF), along with the Environment Sustainability & Energy Division of the Royal Society of Chemistry (ESED), are inviting applications from UK scientists to attend a jointly organised workshop on Improving Understanding of Potential Environmental Impacts Associated with Unconventional Hydrocarbons in Washington DC on 5-6 November 2015.
The deployment of hydraulic fracturing technology to exploit shale oil and gas reservoirs in the USA and now potentially in the UK has raised a number of environmental concerns. This workshop brings together researchers in the USA and the UK to learn from each other to identify the areas of major environmental uncertainty, the focused scientific research questions that need to be addressed, and the opportunities for innovation and translation of existing research within this area. It identifies over 140 topics requiring research.
Report: Joint US-UK Workshop on Improving the Understanding of the Potential Environmental Impacts Associated with Unconventional Hydrocarbons
Danny Reible1 and Richard Davies2 1 Texas Tech University, Department of Chemical Engineering; Department of Civil, Environmental, and Construction Engineering; Box 41023, Lubbock, TX, USA 79409−1023 2 Newcastle University, School of Civil Engineering and Geosciences, Newcastle upon Tyne, Tyne and Wear, NE1 7RU, UK
Aldgate J.L. et al (Feb, 2014), Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas Development, Environ. Sci. Technol., American Chemical Society, 14 pages.
dx.doi.org/10.1021/es404621d1Environ.Sci.Technol.
Angling Trust, the National Trust, RSPB, the Salmon&Trout Association, the Wildlife Trusts and the Wildfowl&Wetlands Trust (WWT) (March, 2014)
Are we fit to frack: Policy recommendations for a robust regulatory framework for the shale gas industry in the UK; This report is underpinned by a separate document, Hydraulic fracturing for shale gas in the UK: Examining the evidence for potential environmental impacts
AEA Report on the Identification of potential risks for the environment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe Report for European Commission DG Environment, Aug 10th, 2012
BBC News January 27, 2014 – item about flowback waste water disposal into the canal from the Preese Hall well.
British Geological Society (BGS)/DECC (May 23, 2014), The Jurassic shales of the Weald Basin: geology and shale and shale gas resource estimation, a Report
British Medical Journal (BMJ) (April 26, 2014), Editorial
Carson, P (Dec 2013), Presentation at Rogate Parish Hall Information Session, Independent Oil/Gas industry representative
Celtique Energie (2013/2014) – range of publications submitted in association with the application; consultancy reports; website; letters sent to part of the local community
Eg Addendum of Non Technical Summary (NTS); Environmental Statement – all parts and particularly Environment; Ecology; Transport; and diagrams
Chartered Institution of Water and Environmental Management (CIWEM) (2014) Policy Position Statement Hydraulic Fracturing (Fracking) of Shale in the UK
CDC (2014), Local Development Framework Key Policies – Pre-submission Local Plan
Davies R.J. et al (2014), Oil and gas wells and their integrity: Implications for shale and unconventional resource exploitation, Marine and Petroleum Geology. http://dx.doi.org/10.1016/j.marpetgeto.2014.03.001 p14
DCLG (2011) Localism Bill A plain English Guide to the Localism Bill https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/5959/1896534.pdf
DCLG (2012) National Policy Planning Framework (NPPF) https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf
DCLG (July 2013),
DCLG (March 2014) Planning Practice Guidance for Onshore Oil and Gas
Dept for Business, Innovation and Skills (2010) Guidelines on scientific analysis in policy making
Dhot, N (2013) Water requirements for fracking, Head of Corporate Affairs UKhttp://www.greenpeace.org.uk/newsdesk/energy/news/shale-and-water-water-requirements-could-pose-challenges-fracking
EU 2000, The Precautionary Principle, Article 191 of the Treaty on the Functioning of the European Union. Available from: http://europa.eu/legislation_summaries/consumers/consumer_safety/132042_en.htm
Frack Free Balcombe Residents Association, FFBRA, April 2014, Evidence to WSCC Planning Committee meeting, held Horsham
Frackfreetameside (March 2014), Evidence to the DECC consultation
Government Office for Science (2011), Code of practice for scientific advisory committees
Hill, M (2014), Evidence to Royal Society report on regulatory framework
Still confused about Fracking?, Expert Engineer to speak in Bushmills, what does Gas and Oil Exploration mean for the North coast, Presentation in Ireland (May, 2014); The Lancet, June 20th, 2014
House of Commons Hansard (2010) Ministerial Statement, Dec 20th, 2010; Paul Flynn MP and Kate Green MP (2014)
Kirdford Parish Council (2014) Neighbourhood Plan
Law, A et al (17 April, 2014), Public Health England’s draft report on shale gas extraction, Mistaking best practices for actual practices, BMJ Editorial
Mahler, H (1981), Health 2000: the meaning of Health for All by the year 2000, World Health Forum Vol 2, No 1, pp 5-22
MEDACT (2014) Climate Science for Health Professionals, MEDACT 2014; MEDACT (2016)
National Planning Statement for Energy Env-1
New Scientist (May 23, 2014) News item by C Barras about the publication of the BGS report
Office of the Deputy Prime Minister (ODPM) circular (2005) Circular 06/05: Biodiversity and Geological Conservation - Statutory Obligations and Their Impact Within The Planning System Ref: ISBN 9780117539518PDF, 751KB, 88 pages
Oil and Gas UK (2012), OPO69 – Well Integrity Guidelines, Issue 1
Pater, CJ and S. Baisch (November 2011), Report on Geomechanical Study of Bowland Shale Seismicity
Pickles, E (2013) Statement on Local Planning and Onshore Industry circulated by Rt Hon Dan Rogerson MP, October 1st 2013
Plain English Guide to the Localism Bill, www.communities.gov.uk
Royal Society/Royal Academy of Engineers (2012) Shale gas extraction in the UK: a review of hydraulic fracturing June 2012
Smythe D (2013) Evidence given to the House of Lords Inquiry into Shale Gas, Nov 11, 2013; Objection (2014) submitted in response to this application and its additional information
Spice, A (2014), Pers comm, email June 4th, 2014
Tyldesley D and Assocs (1999) Fife Landscape Assessment, SNH
UKOOG (2013), UK Onshore Shale Gas Well guidelines: Exploration and Appraisal Phase
WSCC (2013) FAQs factsheet on Oil/Gas developments November
WSCC (2004), West Sussex Structure Plan 2001-2016
WSCC (2014) Exchange of emails with Democratic Services
Wisborough Green Parish (2013) Council Minutes November 19th, 2013; WG Parish Neighbourhood Plan, July 2016
CLIMATE CHANGE
Committee on Climate Change, (Jan 2014) Scrutiny of IPCC report “Climate Change 2013: The Physical Science Basis
Intergovernmental Panel on Climate Change (IPCC) 2013-14, Climate Change 2014: Mitigation of Climate Change, is the third of three Working Group reports, which, along with a Synthesis Report due to be published in October 2014, constitute the IPCC’s Fifth Assessment Report on climate change
Stern, N, Lord (2006) Stern Review on the Economics of Climate Change is a 700-page report released for the British government on 30 October 2006 by economist Nicholas Stern, chair of the Grantham Research Institute on Climate Change and the Environment at the London School of Economics and also chair of the Centre for Climate Change Economics and Policy (CCCEP) at Leeds University and LSE
UK Government Climate Change Act (2008). The Act provides the UK with a legal framework, including a long-term target for emissions in 2050
UNFCCC’s Kyoto Protocol puts binding obligations on industrialised countries to reduce emissions of greenhouse gases
United Nations Framework Convention on Climate Change (UNFCCC) which sets out the framework for multilateral cooperation to tackle climate change.
ENVIRONMENT
AEA (2013), Support to the identification of potential risks for the environment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe
AEA + EA Monitoring and control of fugitive methane from unconventional gas operations http://www.environment-agency.gov.uk/business/topics/134511.aspx
Ashley, L (2014) Commentary included in KKWG newsletter by former Oil worker
Broderick, J, Anderson, K, Wood, R, Gilbert, P, Sharmina M, Footitt, A, Glynn, S and Nicholls, F (2011), Shale Gas: an updated assessment of environmental and climate change impacts.
Chichester District Council (2011), Local Biodiversity Action Plan
Convention on Biological Diversity (1992)
CPRE (2006) Tranquillity report and maps
DECC and AMEC (2013), Strategic Environmental Assessment for Further Onshore Oil and Gas Licensing – Environmental Report.
DECC (Dec 2013), Onshore oil and gas exploration in the UK; regulation and best practice
DECC (2014), environmental legislation applicable to the onshore hydrocarbon industry (England, Scotland and Wales), available as ‘onshore_leg_1.doc’ from www.gov.uk
DECC (April 2014), Guidance on the preparation of an environmental risk assessment of shale gas operations in Great Britain involving the use of hydraulic fracking.
DEFRA, Natural Environment White Paper NEWP (2011) The Natural Choice: securing the value of nature; DEFRA (2011) Biodiversity 2020: A strategy for England’s wildlife and ecosystem services; DEFRA (2010) Conservation of Habitats and Species Regulations
DNV (2013), Risk Management of Shale Gas Developments and Operations
EA (2009) Arun and Western Streams Flood risk report
Environment Agency (EA), (2012), Position Statement: regulating the recovery of drilling muds, MWRP PS 037, version 1
EA (2013), An Environmental Risk Assessment for shale gas exploratory operations in England.
EA (Aug 2013), Onshore oil and gas exploratory operations: technical guidance, Consultation Draft
European Council EIA Directive 85/337/EEC Environmental Impact Assessment The EIA Directive (85/337/EEC) has been in force since 1985 and applies to a wide range of defined public and private projects, which are defined in Annexes I and II: and 15/05/2014: The revision of Environmental Impact Assessment (EIA) Directive enters into force. Guidance on Integrating Climate Change and Biodiversity into Environmental Impact Assessment (2013).
European Landscape Convention, Council of Europe (2000; URL: http://conventions.coe.int/Treaty/en/Treaties/Html/176.htm)
Francis, Clinton D, Catherine P. Ortega, Alexander Cruz (2009) Noise Pollution Changes Avian Communities and Species Interactions, Current Biology, Volume 19, Issue 16, p1415–1419, 25 August 2009 DOI: http://dx.doi.org/10.1016/j.cub.2009.06.052
Kleist, N.J., R.P. Guralnick & C.D. Francis (in press) Noise pollution masks intruder song and weakens territorial response. Ecosphere
Francis, C.D. (2015) Vocal traits and diet explain avian sensitivities to anthropogenic noise. Global Change Biology 21, 1809-1820; Swaddle*, J. P., C. D. Francis*, J. R. Barber, C. B. Cooper, C. M. Kyba, D. M. Dominoni, G. Shannon, E. Aschehoug, S. E. Goodwin, A. Y. Kawahara, D. Luther, K. Spoelstra, M. Voss, and T. Longcore. 2015. A framework to assess evolutionary responses to anthropogenic light and sound. Trends in Ecology & Evolution:10.1016/j.tree.2015.1006.1009.
Joint first authors Bunkley, J.P., C.J. McClure, N.J. Kleist, C.D. Francis & J.R. Barber. (2015) Anthropogenic noise alters bat activity levels and echolocation calls. Global Ecology and Conservation 3, 62-71.
Francis, C.D., & J.R. Barber. (2013) A framework for understanding noise impacts on wildlife: an urgent
conservation priority. Frontiers in Ecology & the Environment 11, 305-313; McClain, C.R., P.A.P. Durstv, A.G. Boyer & C.D. Francis. (2013) Unravelling the determinants of insular body size shifts. Biology Letters 9, 10.1098/rsbl.2012.0989. vGraduate student author
Francis, C.D., N.J. Kleistv, C.P. Ortega, A. Cruz. (2012) Noise pollution alters ecological services:
enhanced pollination and disrupted seed dispersal. Proceedings of the Royal Society of London, Series B
279, 2727–2735; Medinav, I. & C.D. Francis. (2012) Environmental variability and acoustic signals: A multilevel approach in songbirds. Biology Letters 8, 928-931.
Francis, C.D., J.L. Blickley. (2012) Introduction: Research and perspectives on the study of anthropogenic noise and birds. Ornithological Monographs (Auk Supplement) 74, 1-5.
Guardian 12th June 2014
http://www.theguardian.com/science/2014/jun/12/climate-change-mitigation-global-warming-mark-walport
October 1st, 2013, UN
IEEM EcIA guidelines (2006), EcIA Guidelines (Terrestrial)
NB: The EcIA Guidelines (Terrestrial, Freshwater and Coastal, 2006) are currently under review. Until such time as a revised version is published, the 2006 version remains current.
- See more at: http://www.cieem.net/ecia-guidelines-terrestrial-freshwater-and-coastal-#sthash.TGcd2cr3.dpuf
HSE (2014) Guidance on Regulation of Well Construction; http://www.hse.gov.uk/shale-gas/about.htm
Hopkins, J et al (2007) Adaptation for High Biodiversity under climate change,
British Wildlife magazine and Climate Change series of meetings held at Birkbeck College.
IPCC (2014) Working Group 2 of the Intergovernmental Panel on Climate Change (IPCCWG2), Climate Change 2014: Impacts, Adaptation and Vulnerability
Lawton, J et al (2010) Making Space for Nature, a review of English wildlife sites
Michaels, C et al, (Sept 2010) Fractured Communities, Case Studies of the Environmental Impacts of Industrial Gas Drilling, Riverkeep – NY’s clean water advocate.
Natural England (2009), Green Infrastructure Report No 176
Natural England (2013) Standing Advice on Ancient Woodlands; Bats
Natural England (2009) Biodiversity 2020
Natural Environment and Rural Communities Act (2006) includes Biodiversity Duty for all public bodies and Schedule 41 list of Habitats and Species of Principal Importance.
Natural Gas Europe, May 2014 edition
SDNP Presentations October 15th, 2014, off their website, accessed November 2014
The Independent newspaper, 24/5/2014 item on publication of the BGS report
UKWIR (2014), Understanding the potential impacts of shale gas fracking on the UK water industry
Welsh Affairs Committee (June 2014), cross party of MPs, June 16th, 2014
West Sussex County Council (July 2003) Minerals Local Plan; WSCC County Structure Plan (2001-2016)
Wildlife and Countryside Act (1981)
HEALTH:
Choppin GR et al (1995). Radiochemistry and Nuclear Chemistry. Butterworth-Heinemann Ltd. Oxford
Colborn, Theo; Kwiatkowski, Carol; Schultz, Kim; Bacran, Mary; (Sept 2011) Natural Gas Operations from a Public Health Perspective, Human and Ecological Risk Assessment 1039-1056. Doi: 10. 1080/10807039.2011.605662
Development of Unconventional Natural Gas Resources, Science of the Total Environment, May 2012, Vol 424, 79-87
Fracking, Shale Gas and Health Effects – a round up of recent research on the potential health impacts of shale gas extraction and fracking.
Jackson R. B., et al, Research and Policy Recommendations for Hydraulic Fracturing and Shale-Gas extraction, Center on Global Change, Duke University, Durham, NC.
Kibble, A et al, Public Health England (PHE) (Nov 2013; June 2014), Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of the Shale Gas Extraction Process, PHE
McKenzie, L.M. et al (2014), Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado, Environmental Health Perspectives, 28 Jan, 2014. http://dx.doi.org/10.1289/ehp.1306722
McKenzie, L.M. et al (2012), Human health risk assessment of air emissions from development of unconventional natural gas resources, Science of the Total Environment, 2012.
Doi:10.1016/j.scitotenv.2012.02.018
McKenzie, Lisa M; Guo, R; Witter, R,Z; Savitz, D. A.; Newman, L.S; Adgate, J.L. (2014), Birth Outcomes and Maternal Proximity to Natural Gas Development in Rural Colorado. Environmental Health Perspectives, 122, 412-417, soi: 10.1289/ehp.1306722
McKenzie, Lisa, M.; Witter, Raoxan Z.; Newman, Lee S.; Adgate, John L. (2012) Human Health Risk Assessment of Air Emissions from shale gas
Methane Contamination of Drinking Water Accompanying Gas-Well Drilling and Hydraulic Fracturing. It finds that “in active gas-extraction areas (one or more gas wells within 1 km), average and maximum methane concentrations in drinking water wells increased with proximity of the nearest gas well and were 29.2 and 64 mg CH4 L-1 (n=26), a potential explosion hazard.)
MEDACT, 2016, Shale Gas Production in England – an updated public health assessment
MEDACT, 2014, Health & Fracking: the impacts & opportunity costs
MidWest Energy News (2014) concerning well integrity
National Policy Statement, NPS for Energy EN-1:
South Downs National Park (SDNP) website – Information session presentations October 15th, 2013
Vidic, R.D.; Brantley, S.L.; Vandenbossche, J.K.; Yoxtheimer, D.; Abad, J.D. (May 2013) Impact of Shale Gas Development on Regional Water quality, Science May 2013, Vol 340, No 6134. Doi: 10.1126/science.1235009
METHANE
DECC (2013), Mackay D, and Stone, T, Potential greenhouse gas emissions associated with shale gas production and use
DECC (2014), Mackay, D and Stone, T, Fracking UK shale: climate change
Howarth, R. (2014), A bridge to nowhere: methane emissions and the
greenhouse gas footprint of natural gas Energy Science and Engineering
Howarth R. and Ingraffea A (2013), Shale gas: Time to go slow. World Energy Monitor, World Energy Forum. United Nations
Howarth, R. (2013) Shale gas extraction. In Book: Berkshire Encyclopedia of Sustainability
Howarth R. et al, (2012) Venting and leakage of methane from shale gas development: Reply to Cathles et al. In Climatic Change
Howarth R. et al, (2012) Methane emissions from natural gas systems. Background Paper: National Climate Assessment
Howarth R.W. and Ingraffea A., (2011) Should fracking stop? Yes, it is too high risk. In Nature 477:271-273
Howarth R, W. R. Santoro and A. Ingraffea, (2011), Methane and the greenhouse gas footprint of natural gas from shale formations. In Climatic Change Letters 106(4):679-690, DOI:10.1007/s10584-011-0061-5.
Proceedings of the National Academy of Sciences (PNAS) (2013) Anthropogenic Emissions of Methane in the United States. Sought to quantify the current levels, regions and sectors that are the key sources of the potent greenhouse gas. The study found that current US methane emissions appear to be significantly higher than previous estimates – 1.5 x greater than those by the US Environmental Protection Agency (EPA) and 1.7 x greater than data from the European EA’s emission database for global atmospheric research.
PHE, (Oct 2013), Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive pollutants as a Result of Shale Gas Extraction (Oct 2013)
Santoro et al, (2011), Indirect emissions of carbon dioxides from Marcellus shale gas development. Technical Report
The Lancet 2014, The health implications of fracking, Comment section p 757, Vol 383 March 1, 2014
NORM and RADON
September 2016
[1] DECC/AMEC SEA Shale Gas Env report, 2013 CD48.12 ; Shale Gas Rural economy Impacts (REDACTED) 2014 CD42.16 and full report 2015.
[2] Talk given at Oxted Village Hall, 6/2/2016 – confirmed in email, paper awaited
[3] Author of 2 books: Shale Gas and Fracking - the science behind the controversy and Returning Carbon to Nature