strategic environmental assessment for further onshore … · “strategic environmental assessment...

“Strategic EnvironmentalAssessment for Further Onshore

Oil and Gas Licensing”

A response to DECC's publicconsultation on the

14th On-shore Oil and GasLicensing Round's Strategic

Environmental Appraisal

Paul Mobbs, Mobbs' Environmental Investigations,3 Grosvenor Road, Banbury OX16 5HN.

March 2014

© 2014 Paul Mobbs/Mobbs' Environmental Investigations

This report is made available under the The Creative Commons Attribution Non-

Commercial Share-Alike 2.0 Licence (CC BY-NC-SA 2.0 UK) – England & Wales. For a

copy of this licence go to the Free Range Activism Website (FRAW) –

http://www.fraw.org.uk/files/fraw/by_nc_sa-uk-2.html

Correspondence related to this report should be addressed to:

Paul Mobbs,

Mobbs' Environmental Investigations and Research,

3 Grosvenor Road,

Banbury OX16 5HN.

Email – [email protected]

For further information on Paul Mobbs/ Mobbs' Environmental Investigations and Research

go to – http://www.fraw.org.uk/mei/

http://www.fraw.org.uk/files/fraw/by_nc_sa-uk-2.htmln

http://www.fraw.org.uk/mei/index.shtml

mailto:[email protected]

“Strategic Environmental Assessment for

Further Onshore Oil and Gas Licensing”

A response to DECC's public consultation on the

14th On-shore Oil and Gas Licensing Round's

Strategic Environmental Appraisal

Paul Mobbs, Mobbs' Environmental Investigations,

3 Grosvenor Road, Banbury OX16 5HN.

March 2014

Report Contents

Introduction....................................................................................................3

1. Summary and general observations on the SEA report..........................5

2. Significant omissions from the SEA report............................................14

2A. The impact of pipeline networks linking to drill pads...................................14

2B. The omission of gas processing and compressor stations from the SEA.. .16

2C. The status of underground coal gasification................................................19

2D. The failure to model coalbed methane as a distinct processing..................19

2E. The assumed depth of unconventional gas drilling.....................................22

2F. The interaction of planning policy guidance and the SEA............................23

3. General themes/issues across the SEA study.......................................26

3A. BGS gas resource estimates ......................................................................26

3B. Well lifetime, leakage and integrity..............................................................28

3C. Fugitive gas emissions and the MacKay-Stone report................................29

3D. The Public Health England report................................................................31

4. Over-riding legal and procedural flaws in the SEA analysis.................35

4A. The assessment of alternatives...................................................................35

4B. The precautionary principle.........................................................................35

4C. Decision-making bias and likely malfeasance in public office.....................37

5. Conclusions and recommended actions................................................41

6. Background reports/references..............................................................42

© March 2014 Paul Mobbs/Mobbs' Environmental Investigations – http://www.fraw.org.uk/mei/ page 1

http://www.fraw.org.uk/mei/index.shtml

Introduction

This report provides a comprehensive review of the Department of Energy and Climate Change's

(DECC) Strategic Environmental Appraisal (SEA) of the 14th On-shore Oil and Gas Licensing Round1.

It has been produced as part of the public consultation on the SEA, and is intended to provide a

technical evaluation of the SEA in the light of the latest global evidence on the impacts of

unconventional gas developments.

The report has been produced in support of various individuals and small groups around Britain

who are concerned by the Government's push to develop various types of extreme energy

developments. The specific purpose behind the drafting of this report has been to highlight the areas

where the Government's viewpoint/data departs from the growing body of evidence regarding the

impacts of unconventional gas technologies.

Rather than focus on the narrow detail of DECC's SEA report, this review takes a number of broad

themes, examines how each of these themes is addressed within the SEA report, and then contrasts

the Government's approach/data with some of the latest research from around the globe.

Those assessing this response to the DECC consultation should note that specific

points/observations on the SEA report are shown in bold brown type. Each point is discussed, and

relevant references to background material cited, in the preceding text. Significant reports/studies are

listed in section 6, and are identified in the text/footnotes in [square brackets].

Note that references to research papers and reports are intended to be read alongside the text of

this report. In fact, one of the specific observations of this study is that the Government's SEA report

has failed to properly consider the available body of knowledge on unconventional gas developments.

About Paul Mobbs

Paul Mobbs has worked as an independent environmental consultant, author and lecturer for over

20 years. His first career was in the engineering industry. Since 1992 he has worked in many fields

within environmental policy and law – from planning/development and waste management to

environmental pollution and land contamination. He occasionally works as an information and

communications technology consultant, primarily for non-governmental/community groups.

Since 2002 he has spent a large amount of time carrying out research, writing and lecturing on the

issue of energy and the environment – and in particular the issue of the ecological limits to human

development and economic growth. Over this period has lectured at universities and written

journal/news articles on various aspects of this subject. His book on 'peak energy' in Britain, Energy

Beyond Oil, was published in 2005.

In 2009 he began research work on the proposals for unconventional gas development – initially

focussing on shale gas and underground coal gasification. In 2010 this expanded to include coalbed

methane proposals. This makes him one of the earliest 'community-based' researchers on this topic in

Britain.

From 2010 he has organised education/lecture tours of different regions where unconventional gas

development is likely to take place (2010/11 in Lancashire, 2012 in South Wales/the Midlands, 2013

in The Marches, South Wales and the Midlands) to disseminate information on unconventional gas

development. In 2013 he was appointed as an adviser to the University of London School of

1 Environmental report for further onshore oil and gas licensing [DECC 2013A]

page 2 “SEA for Further Onshore Oil and Gas Licensing” – A response to DECC's 14th Round SEA public consultation

Advanced Study's Extreme Energy Initiative2. He is currently working on a book on extreme energy in

the UK (to be published later in 2014/early 2015), as well as continuing his work assisting

communities around Britain which are likely to be affected by unconventional gas development.

2 Extreme Energy Initiative – http://extremeenergy.org/

“SEA for Further Onshore Oil and Gas Licensing” – A response to DECC's 14th Round SEA public consultation page 3

http://extremeenergy.org/

1. Summary and general observations on the SEA report

This first section is intended to set the framework for the specific observations which follow in the

following sections. It also summarises the content of the report.

To begin, let's take the main conclusion of DECC's SEA report3:

The assessment did not identify any likely significant environmental effects for conventional oil and gas

exploration and production, virgin coalbed methane or underground gas storage.

After studying the main report and its appendices, it is my view that the greatest errors and

inconsistencies within the SEA report relate to the fact that:

it is based upon a highly selective sample of data and sources – and does not attempt to

address the wider body of research and environmental data which has emerged over the last

few years which demonstrates the ecological impacts of unconventional gas development;

in contrast to the superseded 2010 SEA report which contained wholly unrealistic assessment

parameters, this new report has been drafted to reflect a policy position rather than address

the extant body of knowledge on the ecological impacts of on-shore oil and gas developments;

and finally,

it does not attempt, in defence of current government policy objectives, to defend the details of

the proposed development programme against criticism based in real-world experience from

elsewhere around the globe – principally the USA, Canada and Australia.

As a general summary, it is my view that the SEA report fails to adequately assess the

impacts of the proposed oil and gas development proposals – both due to errors of fact, and a

failure to consider the evidential uncertainties within the impacts of on-shore oil and gas

exploration and production. In turn, if the Government proceeds with its policy, it would open

itself to legal action from those aggrieved by this policy.

The impact of pipeline networks linking to drill pads

SEA requires an assessment of all “significant effects on the environment”. The SEA report has

clearly failed to do that because it omits a specific analysis of the pipeline networks linking well pads.

In fact, the SEA considers these impacts to be “minor” when demonstrably they are not.

Pipelines works have a direct impact upon soils and hedgerows. Where they cross watercourses

the disturbance can lead to silting and run-off which can damage the ecological value of

watercourses. Where trenching operations disrupt the hydrogeological conditions in the subsoil, this

can lead to changes in local hydrology which can have an on-going impact upon agriculture and local

ecology.

If we look at the first major field development planning applications, near Falkirk in Scotland, then

the impact of pipelines is a major component of the overall development area. A recent USGS study

of the impacts on unconventional gas developments in the USA found the impacts of the totality of

landscape changes to be, “often dramatic”.

The failure to model and analyse the impact of pipeline corridors on the environment is a

serious flaw in the SEA. Arguably the pipeline component of the proposed policy has an

impact upon a larger land area than the well pads; it will cross hedgerows, and watercourses,

and may disrupt soil hydrology, leading to longer-term ecological impacts. Without an analysis

of the pipeline impact, the SEA cannot be considered a fair and adequate examination of the

3Page 121, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]


totality of foreseeable policy impacts.

The omission gas processing and compressor stations from the SEA

The SEA contains a serious error in its model for gas field production, and hence for pollution and

risks impacts. At no point is there any discussion of gas treatment and compressor stations. This

intermediate stage between the gas pad and the supply grid also gives rise to some of the most

significant sources of solid, liquid and gaseous pollutants during the production phase.

Compressor stations concentrate and treat the gas from many wells before supply – to produce

gaseous, liquid and solid waste materials. When a treatment process “cleans” something it inevitably

produces a waste by-product. For gaseous pollutants, these are most often dumped into the

atmosphere. The method of treatment chosen for the raw gas stream will also influence whether non-

gaseous wastes are produced as a liquids, sludge or solid materials. And as these processes

concentrate the pollutants contained within the raw gas, the materials they produce can be highly

toxic – and/or radioactive.

Compressor stations therefore represent a major source of both toxic air pollutants, and solid/liquid

hazardous wastes. In addition, the storage of natural gas liquids (NGL) at the compressor stations

represents a significant risk from spillage and serious explosions/fires. The level and type of pollutants

potentially emitted at compressor stations also raises the possibility that, on the edge and within

urban areas, the additional inputs from the gas production might lead to an infringement of European

air quality standards. That AMEC neglected to include these details in the preparation of the SEA, and

that DECC did not pick-up on this omission during final approval, casts doubt as to the quality and

efficacy of this report as part of this quasi-judicial decision-making process.

The omission of gas treatment/compressor stations from the assessment methodology of

the SEA represents a serious flaw in the report. Failure to consider this easily identifiable and

quantifiable risk to environmental quality represents a severe deficiency in the case presented

by the Government. Without a proper characterisation of the impacts of gas treatment, and the

gaseous and solid/sludge waste streams this creates, the SEA cannot be considered to have

met the information requirements under Annex I of the SEA Directive.

The status of underground coal gasification

DECC is currently proposing, as part of regulatory reforms to make shale gas authorisation simpler,

to reform/simplify the process for UCG authorisation. Given that the need for SEA of unconventional

oil and gas policy has been established in law, it is difficult to see how DECC can proceed with their

policy proposals on UCG without first subjecting them to SEA.

The failure to include underground coal gasification in this SEA means that DECC's policies

in relation to underground coal gasification, enacted via the Coal Authority, are arguably

unlawful. There needs to be a clarification within DECC's policies as to whether UCG is to be

lumped together with other types of “native hydrocarbon” development, or whether it will be

subject to a separate SEA process.

The failure to model coalbed methane as a distinct process

The statements in the SEA – that coalbed methane (CBM) is similar to shale gas, and that CBM

doesn't normally involve hydraulic fracturing – are demonstrably incorrect based on recent

experience. Recent experience in Australia suggests that hydraulic fracturing is routinely used in CBM

operations, and that in future this will increase as more margin regions are tapped. In terms of their

ecological footprint – for example the propensity for CBM de-watering to affect sensitive aquatic


habitats by lowering groundwater levels, or the differing discharge profile and contaminant load of

each technology – they are not the same. Given these significant differences, it cannot be said that

the processes of shale gas and coalbed methane production are equivalent. Therefore SEA should

have assessed CBM as a distinct process to shale gas – and the SEA should have modelled its

impacts as a distinct process.

The greatest documented experience in relation to coalbed methane is in the states of Queensland

and New South Wales in Australia. This month, the New South Wales Government suspended all its

operational Petroleum Exploration Licences pending a review of the environmental impacts of past

CBM operations. In Queensland CBM development has been on-going for a slightly longer period. In

2013, leaks by a whistle-blower revealed evidence of corruption within the Queensland State

Government environmental department – where political pressure was used to force regulators to

speed up approvals of the licensing process, and to ignore the lack of environmental evidence to

support licence applications.

The longest history of CBM operations is in the USA. From the 1960s to the 2000s, particularly in

states such as Wyoming, there was extensive working of coal seams for gas. However, due to poor

historic regulation of the industry by individual US states, the bonds provided as part of those historic

permitting processes are no longer sufficient to pay for the plugging/clean-up of well sites – meaning

State governments must now step in to meet the cost as the companies involved declare themselves

insolvent.

The CBM industry in Australia, like shale gas in the USA, has developed over the last decade or so.

Therefore it is only recently that environmental scientists and health professionals have been able to

catch-up with the impacts of development to date. There have been local assessments impacts, and

more recently studies by medical community. Recent sampling by universities has discovered high

fugitive emissions rates within CBM fields

The SEA states that the levels of CBM activity in Britain remain broadly comparable with those for

conventional oil and gas. From my recent experiences working with communities around Britain, this

is not the case. Within many PEDLs issued under the 13th On-Shore Oil and Gas Licensing Round,

recent exploration activities have been centred around the potential for CBM. We have also seen

recent reports from the British Geological Survey looking at the CBM potential of the UK.

CBM, as shown by the last decade or so of experience in Australia, has definable impacts

upon the natural environment and human health. Likewise the regions where CBM potential

exists – predominantly former coalfield areas – have a distinct local geology and landscape

character compared to those areas being targeted for shale gas extraction. Not modelling the

distinct processes of coalbed methane operations – in particular the differing

qualities/quantities of produced water and the propensity to impact upon hydrogeology that

this creates – represents a significant failure within the method of the SEA report.

The assumed depth of unconventional gas drilling

The SEA gives differing figures for the depth of unconventional gas working. It is a simple process

to discover the depths of potential conventional/unconventional gas resources in the areas it is

proposed to licence under the 14th Round.

For example, the small box straddling the border of Buckinghamshire and Oxfordshire has been

drilled twice in the last century. The deepest bore drilled was just short of 100 metres below Ordnance

datum. Therefore the depth from the surface to gas-bearing strata is slightly less than 200 metres.

This is broadly similar to the depth of drilling/hydraulic fracturing at two sites in the USA where


significant groundwater pollution has affected local communities.

As the area identified here was missed it raises the question as to whether, in order to

provide a higher degree of safety, AMEC/DECC have adequately assessed the depth of gas-

bearing rocks across Britain. Given that this data is readily available from the British

Geological Survey's mapping system, it would be a relatively simple matter to assess the

depth the likely gas-bearing strata. Given the shallow depth in this area on the border of

Oxfordshire and Buckinghamshire, this block must be withdrawn from the 14th Round.

The interaction of planning policy guidance and the SEA

At various points during the discussion with the SEA report, potential problems picked up by the

assessment are dismissed because – it is stated – the details can be dealt with at the planning

application stage. The assessment of such impacts requires that the planning authority which

receives an application to develop a well pad site(s) assess the impacts of emissions, or the proximity

of polluting processes, upon public health. This is something which, in the Department for

Communities and Local Government's National Planning Policy Framework, local planning authorities

are expressly instructed not to do.

This position was reiterated in the specific planning guidance on on-shore oil and gas. Again, in the

context in which they are described in the SEA report, the planning authorities would not be permitted

within a strict interpretation of the guidelines to apply the type of control specified in the SEA.

It is disingenuous to suggest in the manner described, as is done at various points within

the SEA report, that planning authorities have the freedom to consider the environmental and

health impacts of on-shore oil and gas developments. Therefore, unless the Department of

Energy and Climate Change significantly modify their policies, or unless DCLG withdraws

their prohibitions, the policy outlined in the SEA report cannot be enacted by local planning

authorities. This prevents DECC from achieving the environmental protection objectives

outlined in the SEA.

BGS gas resource estimates

Within the SEA a highly misleading statistic is quoted in order to support the policy objectives which

the report is seeking to justify – the British Geological Survey “1,300 trillion cubic feet” figure.

“1,300 tcf”, or 36.8 trillion cubic metres (tcm), represents a value for “gas in place”. This figure is

considered too unreliable by many financial institutions and stock exchanges, who instead use the

'P90' or “90% probability” figure – 23.3tcm, 37% lower than the headline BGS figure.

Current technology cannot recover all the gas within the rock strata. Various estimates suggest at

best it is 10%, and often as little as 2%. As the best locations in US shale gas plays are drilled,

average daily shale gas production per well is falling. Next we have to divide this figure by the

production period in order to produce an annualised figure. The SEA suggests as little as 20 years,

whilst a figure of 30 to 40 years might be more realistic. At the 'realistic' 2% recovery factor, that

produces between 23bcm/year (20 years) to 12bcm/year (40 years).

In 2012 the UK economy demanded 14.8bcm of natural gas. However, we are also losing North

Sea oil production, and we now import much of our coal. Expressed as natural gas, the UK's total

primary energy demand in 2012 was 43bcm. That figure itself is 10% lower than the peak of energy

consumption before the recent economic recession in 2005, 48bcm.

Just as 40 years ago Britain celebrated the commissioning of the North Sea, and now today we are

now try desperately to find another supply of energy, so what will we do 40 years from now? It is not a


new source of gas which Britain needs, but rather a new economic model.

The focus on producing more finite energy resources is deflecting the political capital

required to find a truly long-term solution to human sustainability. Not only does producing

more fossil fuels exacerbate current ecological difficulties, but it merely shifts an even greater

crisis onto the next generation. The whole approach of the Government's policy objectives,

based upon the short-term depletion of finite resources, does not meet any valid

“sustainability” criteria.

Well lifetime, leakage and integrity

The SEA report states that there is a risk of hydraulic fracturing causing groundwater

contamination, but the risk of contamination from fracturing activities is exceptionally low. That

position is not supported by other research studies.

Some oil and gas industry quote high failure rates, from 5% on the first day of installation to 60%

after 25 years. The most recent large-scale study covers a variety of conventional and unconventional

oil and gas wells. In relation to unconventional gas projects in Pennsylvania it quotes failure rates of

6%. The paper also notes that in the UK, where disused well sites are cleared and restored, the true

level of leakage is likely to be higher as these wells are not subject to on-going monitoring/after-care.

The problem with the debate over well leakage is that the discussion always focusses on

guaranteeing well integrity at the time of installation. Other assumptions based on installation-time

testing, such the likelihood of fugitive emissions increasing with time, are also invalidated by these

studies. Basing long-term projections/guarantees of environmental protection on the integrity tests

conducted at the time of installation has little relevance to real-world evidence on how oil and gas

wells fail.

By underplaying the role of well leakage, the SEA's position on well leakage does not

concur with currently available evidence. Oil and gas well leakage is a statistically quantifiable

phenomena. Thus the possibility groundwater contamination and gas migration arising from

the Government's oil and gas drilling proposals is a calculable value. Taking the range of well

numbers outlined in the SEA (180 to 2880), the number of wells we might expect to fail would

be at least 11 to 181 – although, as outlined in recent research, the problematic reporting and

lack of monitoring of past well bores is likely to make this an underestimate.

Fugitive gas emissions and the MacKay-Stone report

The Mackay-Stone report is a good example of how selective quoting of certain studies, and

directly misleading statements, are currently being used to mislead public opinion. It is representative

of an disturbingly close relationship between gas companies and the Government in order to manage

the public's view of unconventional gas.

The Mackay-Stone report was published in September 2013. Previous studies claimed that the

fugitive emissions on methane meant unconventional gas had a carbon footprint far higher than

conventional natural gas, one of the key claims in the Mackay-Stone report was that shale gas in

Britain would have an equivalent footprint to existing natural gas production.

The version published by DECC in September 2013 was incomplete – missing three vital

appendices. I requested the full version from DECC, which did not arrive for almost six weeks. The

critical appendix with regard to the comparison of unconventional shale gas and conventional natural

gas, Appendix B, stated, “In the absence of information about the quality of the UK’s shale gas we

have assumed that shale gas would produce similar emissions to those in the production and

processing of conventional gas.”


The report referenced a forthcoming report from the University of Texas – published shortly after the

DECC report. This new study claimed that methane/carbon emissions from unconventional oil and/or

gas wells were within the low range specified by the Mackay-Stone report. However, the University of

Texas study is a non-randomised sample of 190 natural gas sites in the United States, and therefore

cannot be directly related to unconventional oil/gas production as a whole.

As a result of this effort at media management, when we examine the detail the Mackay-

Stone report it does not demonstrate that unconventional gas development in Britain will be

equivalent in its climate change impacts to conventional gas; or better than other fossil fuels

such as coal. Likewise the University of Texas study, which DECC hoped would allay

criticisms from recent studies of fugitive emissions from unconventional gas sites, did not do

so because of its poor statistical construction.

The Public Health England report

Public Health England (PHE) published a report on the health impacts of unconventional gas

production in October 2013. Again, the purpose of the PHE report was to demonstrate an equivalence

between the health impacts of conventional gas production and unconventional gas.

The PHE's report was subtitled “draft for comment”. Arguably it is premature for DECC's SEA report

to quote or cite the PHE study before a final/authoritative version is produced.

When I first read the PHE report my immediate action was to check the PHE web site for details of

the consultation exercise – there were none. Then I checked the archived Health Protection Agency

site – again, no information. A month after contacting PHE I received an email which offered to extend

the comment period for myself, but did not answer the question as to the absence of a formal, publicly

advertised consultation exercise on the content of the report. No major media outlet noted the “draft

for comment” label, and all appeared to describe it as if it were a final statement on the issue of shale

gas and health.

The report itself contains no explicit instructions with regard to any consultation process; except

that is for the statement, “PHE has continued to assess the scientific evidence on the potential public

health impacts of exposures to chemical and radiological pollutants associated with shale gas

extraction, the references below have been reviewed and are not considered to affect the conclusions

of the draft report.”

The rest of section 13 then lists many of the latest research papers in the field of public health and

unconventional gas production which existed in journals at that time. To argue that these 50 papers –

without any detailed explanation or analysis – did not have a bearing on the outcome of PHE's study

offends the transparency principles which they are required to adopt in formulating public policy.

PHE's central claim is that, “Although shale gas extraction and related activities have the potential

to cause pollution to air, land and water, the currently available evidence indicates that the potential

risks to public health from exposure to the emissions associated with shale gas extraction are low if

the operations are properly run and regulated.” This cannot be substantiated given the available

evidence on the many issues related to unconventional gas development. In that respect, it is worth

laying the conclusions of the PHE study alongside the work of many recently published papers on

unconventional gas and health, in addition to the papers listed in PHE's “none of the below” list in

their report.

Note that not all the papers cited are “against” shale gas – some cast doubt, or do not find a

conclusive result. But that's critical the point; currently the evidence does not exist to provide an all-

conclusive statement either way: that “potential risks are low”, as PHE state; or that “shale gas is


inherently harmful”, which many opponents state. With regard to that, the Chief Medical Officer of

New Brunswick's report is far more balanced that the report provided by PHE.

PHE's report on the health impacts of unconventional gas is arguably biased, and is not

transparent between its assessment/collection of information and the inferences/conclusions

which it draws. Their unpublicised consultation exercise on the report was also highly suspect

– given it was merely a call for papers rather than analysis. Looking at the body of evidence

which exists art present, not enough information exists to support PHE's claim of “potential

risks are low” – nor to demonstrate the opposite conclusion either. Without the kinds of

extensive sampling/health monitoring identified by many of the recent reports cited here, and

rejected by PHE's report, such a categorical conclusion cannot be made.

The assessment of alternatives

The SEA report outlines a series of alternative proposals in order to mitigate impacts from on-shore

oil and gas production. However, these “alternatives” represent alternative strategies for awarding oil

and gas licences – not alternative methods of oil or gas production.

The assessment of alternatives within the SEA is questionable because it represents an

iteration of the same process – the issuing of oil and gas licences – rather than a true

exploration of alternative options – exploring differing methods/technologies which meet the

same objectives with a different impact upon the environment. Arguably the SEA report fails to

meet the terms of the SEA Directive.

The precautionary principle

The first paragraph of the preamble to the SEA Directive requires that protection of the environment

and human health, and the prudent and rational utilisation of natural resources, be based on the

precautionary principle. Article 191 of the Treaty of Lisbon modifies these objectives slightly –

additionally requiring action on the principle that preventive action should be taken, that environmental

damage should as a priority be rectified at source and that the polluter should pay.

The first stage in the application of the precautionary principle is the acceptance that uncertainty

exists; the characterisation of uncertainty then follows on from this acceptance. In my view the SEA

report seeks to deny that any uncertainty exists, and therefore blindly adopts measures which fit that

viewpoint rather than opening up the analysis to decide the scope and impact of those uncertain

outcomes. As I outline in relation to a number of points, this flaw can be seen in many aspects of the

SEA's analysis of policy impacts.

There are a number of grounds upon which the SEA report could be claimed to breach or

inadequately enact the requirements of Community law to apply the precautionary principle. In

that respect the whole SEA process is void – and should be restarted from the beginning. As

part of that review the SEA framework must properly be applied, so that environmental

protection flows from the policy, rather than the need to meet environmental objectives being

retroactively applied to policy afterwards.

Decision-making bias and potential malfeasance/misconduct in a public office

For me, this issue come to a head with the issue of oil and gas development – because so many

elements of our political processes are directly influenced by the fossil fuel lobby. There is, arguably, a

legal term which I believe encompasses the nature of these relationships... malfeasance or

misconduct in a public office.

These offences are based around the making of irrational decisions due to inducements or


deference whilst in a public position which, objectively on the basis of available evidence, could not be

made by the “average person”.

This is a serious matter, but in my view this has little to do with the alleged “corrupt practices” often

seen in the media. As I see it this is solely a matter of whether or not the decisions of ministers, due to

the influences upon them, are unreasonable to a degree which might be considered unlawful. But

over and above this, we must question whether the high-level access to decision-makers given to the

energy lobby by the present Government literally obstructs – as part of the strategic environmental

appraisal process – more generally obstructs our general rights to a fair and impartial tribunal.

The reason this issue has come to a head with the SEA process is because of the role this

mechanism has in European law. The SEA Directive, alongside recent revisions to the guiding

legislation of the European Union, enacts the Aarhus Convention on the rights to information and

access to decision-making on environmental matters through the SEA process. That is why the

Government are required to consult, and demonstrate that they have done so, from the beginning of

the process.

The over-bearing influence of the fossil fuel energy lobby within the UK Government raises

the question as to whether ministers, in discharging their quasi-judicial functions as part of

the SEA process, can fairly and impartially decide upon the evidence provided by the SEA

report, and any criticisms of that case supplied as part of the SEA consultation process. As a

specific objection, I raise this question as a criticism of the SEA report, and of the processes

which gave rise to that report, including the preparation of other related reports such as those

from PHE or Mackay & Stone. Therefore, in determining the outcome of this consultation

process, I raise specific questions as to whether:

The influence of the energy lobby upon ministers will lead to a perverse interpretation

of the requirements of SEA law, and therefore to a flawed and unreasonable decision on

the substance of the SEA's information report;

The flawed nature of this decision-making process might be considered so

unreasonable that it represents, to a potentially criminal level, malfeasance or

misconduct in a public office by those involved in the recent evolution of the UK's

policy on unconventional gas; and

Over and above any UK national legal statutes on unreasonableness, whether the

undue influence of energy interests within the UK Government obstructs the ability of

responsible minister to provide, in accordance with EU law on strategic environmental

appraisal –

• a fair and impartial assessment of the impact of UK Government policy upon the

environment;

• the means to work towards sustainable development, apply the precautionary

principle in decision-making, and to ensure that the environment and human health

are protected, both under the SEA Directive and the over-arching framework of

European law.

The above failings challenge the competency of UK ministers to make decisions over critical

environmental policy matters, and whether the EU must take action against the UK

government to secure guarantees of appropriate action in order to fairly and impartially enact

EU environmental law.

Due to the nature of the complaints raise in this report, I am doubtful as to whether the responsible


ministers are capable of making an objectively informed and impartial decision upon the content of the

SEA report, and the objections of the public to that report.

If we follow UK tradition, then I would envisage that the only way we might arrive at a balanced

outcome would be to suspend all further oil and gas activities on-shore, and then hold a Royal

Commission, where all representative groups (for and against) might put their case in front of a

demonstrably fair and impartial tribunal.

There are many recent research studies which highlight the issue of our ecological

sustainability. In this report I have outlined why I view the Government's current energy policy

for on-shore oil and gas is flawed, and why moves to expand on-shore oil and gas

development will exacerbate this situation. If members of the Government proceed with these

policies after having conducted this consultation – given the information provided by this

review and the many other similar studies on other topic over the years – then in my view that

would constitute criminal malfeasance; and I believe that those responsible should be made

personally liable for their actions in the promotion of this policy initiative.


2. Significant omissions from the SEA report

This section covers specific topics which are wholly missing from the SEA report, or which have

been inadequately assessed within the methodology of the SEA study.

2A. The impact of pipeline networks linking to drill pads

The objective of strategic environmental appraisal is4,

...to provide for a high level of protection of the environment and to contribute to the integration

of environmental considerations into the preparation and adoption of plans and programmes

with a view to promoting sustainable development, by ensuring that, in accordance with this

Directive, an environmental assessment is carried out of certain plans and programmes which

are likely to have significant effects on the environment.

The key to that process is the assessment of all “significant effects on the environment”. The SEA

report has clearly failed to do that with regard to one such impact – the development of pipeline

networks linking well pads, to gas treatment/compressor stations, and then on to connect with the

national gas grid.

The view given in the SEA report is that these pipelines have no significance when compared to the

central project of the policy under analysis – the extraction of natural gas. For example:

The scale and type of activities under Stage 3 (production development) are expected to be

largely similar to under Stage 2, with additional activities of provision of pipelines and facilities.

Given the small scale of this additional work, the assessment of effects for the majority of

objectives remains the same as Stage 2.5

Pad preparation and provision of associated infrastructure such as pipelines and road

connections during Stage 2 (exploration drilling) and Stage 3 (production development) are

likely to require the clearance of vegetation and loss of soil layers and compaction. Associated

adverse effects in terms of soil function and processes are likely to minor...6

Construction activity associated with pad preparation, road access, well construction and

(during Stage 3) pipeline works would have temporary, short-term effects on visual amenity and

landscapes.7

Additional landtake may also be required for road connections and the installation of pipelines

required to collect natural gas for transfer to the existing natural gas pipeline infrastructure.

Works are likely to require further clearance of vegetation and loss of soil layers and compaction

which may have a negative effect in terms of soil function and processes. However, it is

anticipated that sites would be restored following decommissioning such that effects would be

reduced in longer term.8

4 Article 1, [Directive 2001/42/EC]

5 Page 78, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]

6 Page 92, ibid.

7 Page 97, ibid.

8 Page B4.48, Appendix B, ibid.


While it is not possible to look at specific examples of pipeline impacts, when we average the

footprint of development over large areas we can arrive at a common measure of impacts. If we look

at the spacing of well pads, whilst individual pad spacing may vary it tends towards an average across

the field. In turn, as a function of spacing, the distance spanned by the pipelines connecting individual

pads will, on average, increase as a function of well pad spacing.

For example, the current planning application by Dart Energy to develop a coalbed methane field

near Falkirk in Scotland9 comprises 16 sites (2 pre-existing) and up to 20 kilometres of pipelines.

That's around 1.25km of pipeline per site. The largest drilling sites cover 4,000 square metres, or 0.4

hectares – much smaller than the 1 hectare specified in the SEA report10. The size of the corridor

required for pipeline installation varies according to the type of land being crossed – on very hard or

very soft land the additional plant required would require a wider corridor. For the purpose of this

analysis let's assume a 15 metre wide development corridor for pipeline installation. Therefore: the

land take for the 16 sites, at 0.4 hectares per site, would be 6.4 hectares; in contrast the land take for

20 kilometres of pipeline would be 30 hectares – 4½ times greater than the pad area.

Extending this principle to the SEA methodology is a little more difficult. The assumption of a 5

kilometre pad spacing – reflecting the minimum spacing of pads in urban areas – is a large distance

compared to experience in the USA (shale gas) and Australia (coalbed methane). Assuming that the

pipeline distance is directly equivalent to the pipeline spacing, for the 30 to 120 sites identified in the

SEA (arguably, from experience elsewhere, another significant under-estimate), that's a total of 150 to

600 kilometres of pipeline. Again assuming a 15 metre pipeline corridor, that's a total of 225 to 900

hectares of land affected by pipeline development – or between 2½ to 3¾ times the size of the area

affected by pad development.

That figure is undoubtedly an underestimate – the SEA's use of a large area for individual pads,

and a large spacing between pads, leads to an underestimate of the total number of pads and thus of

the distance of pipelines between those pads.

The assumption in the SEA is that pipeline development is largely a temporary disturbance to the

environment. That again is not supported by experience. The recent United States Geological Survey

study of landscape impacts from shale gas and coalbed methane development in Pennsylvania

demonstrates this point11:

With the accompanying areas of disturbance, well pads, new roads, and pipelines from both types

of natural gas wells, the effect on the landscape is often dramatic. Figure 2 shows a pattern of

landscape change from forest to forest, interspersed with gas extraction infrastructure. These

landscape effects have consequences for the ecosystems, wildlife, and human populations that

are colocated with natural gas extraction activities.

Pipelines have a direct impact upon soils and hedgerows. Where they cross watercourses the

disturbance can lead to silting and run-off which can damage the ecological value of watercourses.

9 This development comprises two applications, straddling local authority areas: Development For Coal Bed Methane Production, Including Drilling, Well Site Establishment at 14 Locations, Inter-

Site Connection Services, Site Access Tracks, a Gas Delivery and Water Treatment Facility, Ancillary Facilities, Infrastructure and Associated Water Outfall Point – Falkirk planning authority reference P/12/0521/FUL, August 2012.

Development for coal bed methane production, including drilling, well site establishment at 14 locations (only Sites D, E and G within Stirling Council area), inter-site connection services, site access tracks, a gas delivery and water treatment facility, ancillary facilities, infrastructure and associated water outfall point near Letham – Stirling planning authority 12/00576/FUL, August 2012.

10 Table 2.7, page 29, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]

11 Page 3, Landscape Consequences of Natural Gas Extraction in Bradford and Washington Counties [USGS 2012]


Where trenching operations disrupt the hydrogeological conditions in the subsoil, this can lead to

changes in local hydrology which can have an on-going impact upon agriculture and local ecology

due to: increased water-logging of soils, where trenching works decrease permeability in the soil; or

excess draining and a lowering of the water table due to the increase of permeability along the trench.

The failure to model and analyse the impact of pipeline corridors on the environment is a

serious flaw in the SEA. Arguably the pipeline component of the proposed policy has an

impact upon a larger land area than the well pads; will cross hedgerows, and watercourses,

and may disrupt soil hydrology, leading to longer-term ecological impacts. Without an analysis

of the pipeline impact, the SEA cannot be considered a fair and adequate examination of the

totality of foreseeable policy impacts.

2B. The omission of gas processing and compressor stations from the SEA

The SEA contains a serious error in its model for gas field production, and hence for pollution and

risks impacts.

If we summarise the SEA's logical structure for the gas field production phase it would be –

Well pad → Pipeline → National gas grid

This structure is implicit in the way that both conventional12 and unconventional13 gas production

has been assessed in the SEA. The assumption appears to be that the production phase requires the

creation of more well pads, and a series of pipelines which connect to the national gas grid. In relation

to both conventional and unconventional gas the SEA states –

This stage would require additional infrastructure including storage tanks, road connections and

the installation of pipelines required to collect natural gas for transfer to the existing natural gas

pipeline infrastructure.

At no point is there any discussion of gas treatment and compressor stations. This intermediate

stage between the gas pad and the supply grid gives rise to some of the most significant sources of

solid, liquid and gaseous pollutants during the production phase. That AMEC neglected to include

these details in the preparation of the SEA, and that DECC did not pick-up on this omission during

final approval, casts doubt as to the quality and efficacy of this report as part of this quasi-judicial

decision-making process.

If we summarise the logical structure of an on-shore gas production field, what we actually find is –

Well pad → Pipeline network → Compressor station → Pipeline → National gas grid↓ ↓

Road transport NGL Waste solids/effluents← → Disposal ↓ ↓

Fire/spill hazard Concentrated airborne emissions

The gas produced from geological formations is of varying quality, containing a variety of toxic and

problematic pollutants, and comprises a liquid hydrocarbon component which condensates out at the

well head and must be stored/collected and transported away. If we look at experience in the USA

and Australia, for every 80 to 120 gas wells there is a gas treatment and compressor station, where

12 Page B7.31/32, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]

13 Page B7.48/49, ibid.


the gas is cleaned before it is supplied to the gas grid.

However, the the operation of compressor stations, and the risk to the environment and human

health from their operation14, has been omitted from the methodology of the SEA. Instead, the

principal environmental impacts are limited to on-site plant emissions and gas flaring. For example –

The assessment has identified negative effects in respect of the air quality... This principally

reflects emissions to air from on-site machinery, HGV movements, drilling and hydraulic

fracturing which could result in air quality impacts on sensitive receptors including residents and

biodiversity. Additionally, there would also be emissions from flaring...15

We might assume from the SEA that once gas production begins, following pad installation, then

the majority of impacts cease. This appears to be the case, as outlined in the SEA report –

Whilst it is assumed that there would be a 5km distance between well pad sites (as per the

assumptions set out in Table 2.5) and activities would not be undertaken simultaneously (my

emphasis), which may reduce the potential for localised impacts on air quality arising from

multiple well pad sites...16

In fact, compressor stations operate 24 hours a day/365 days per year whilst gas production is

under way. Consequently the minimisation of air pollution impacts as a result of phased operation –

as intimated in the above quote from the SEA – does not represent a realistic analysis of the sources

of air pollution. Therefore the inference that air pollution impacts in any one location are transitory,

and largely cease after the exploration/pad installation phase, is clearly in error.

By combining the raw gas from many well sites, then concentrating the trace pollutants of that gas

into a single point source emission, the function of the compressor station increases the potential

harm of the airborne discharges from gas production17. For gaseous pollutants, these are most often

dumped into the atmosphere via a flare stack; which, even discounting occasional flare failure events

releasing unabated emissions, routinely lead to the formation of secondary pollutants from

combustion (e.g., nitrogen oxides).

Furthermore, the SEA fails to note, beyond the impacts of the drilling process and the production of

flowback water, that the gas production phase creates solid/sludge waste streams. As noted in the

SEA report, the assumption is that waste generation is part of drilling and site construction operations,

not production –

It is assumed that some hazardous wastes would be produced on exploratory drilling sites.18

Drilling operations at this stage would generate similar waste streams to those expected at Stage

2 but the scale of activity would increase substantially through the use of multiple well pads. This

would result in additional volumes of waste than expected under Stage 2.19

When a treatment process “cleans” something it inevitably produces a waste by-product.

Compressor stations concentrate and treat the gas from many wells before supply – to produce

gaseous, liquid and solid, often hazardous (in terms of the environmental toxicity/low flash point

14 Potential Public Health Hazards, Exposures and Health Effects from Unconventional Natural Gas [Adgate 2014]


16 Page 96, ibid.

17 An Exploratory Study of Air Quality near Natural Gas Operations [Colborn 2014]

18 In relation to conventional gas, page B8.40, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]

19 In relation to unconventional gas, page B8.53, ibid.


definition20), waste materials. The method of treatment chosen for the raw gas stream will also

influence whether non-gaseous wastes are produced as a liquids, sludges or solid materials. And as

these processes concentrate the pollutants contained within the raw gas, the materials they produce

can be highly toxic – and/or radioactive.

Compressor stations therefore represent a major source of both toxic air pollutants, and solid/liquid

hazardous wastes. In addition, the storage of natural gas liquids21 (NGL) at the compressor stations

represents a significant risk from spillage and, as often seen in the USA, serious explosions/fires22.

The pollution from shale gas operations, and the health and environmental impacts this creates,

represents a quantifiable level of both environmental and economic impacts23 – and these impacts

should have been properly quantified as part of the SEA methodology.

Especially around urban areas, compressor stations represent a concentrated point source of

pollutants which would exacerbate existing air quality in the area24. Although the Government has to

date been dismissive of the environmental impacts of gas developments, recent research

demonstrates that the failure to adequately quantify impacts is largely down to a failure to provide

adequate monitoring of gas developments to date25 – and the approach of the SEA typifies the

systemic flaws in why regulators are failing the public in the identification and monitoring of

environmental hazards.

The level and type of pollutants potentially emitted at compressor stations also raises the possibility

that, on the edge and within urban areas, the additional inputs from the gas production might lead to

an infringement of European air quality standards26. The European Commission is already bringing a

prosecution against the UK27 for failure to meet air pollution reduction standards by the required date.

Arguably more intense natural gas development would exacerbate this problem because it would

make it harder to reach the required standard within the time frame required. In addition the nature of

these pollutants, especially the volatile organics component, are precursors in the formation of

secondary air pollutants such as ground level ozone – which again, is a serious issue in urban areas

during the summer time28.

The omission of gas treatment/compressor stations from the assessment methodology of

the SEAs represents a serious flaw in the report. Failure to consider this easily identifiable and

quantifiable risk to environmental quality represents a severe deficiency in the case presented

by the Government. Without a proper characterisation of the impacts of gas treatment, and the

gaseous and solid/sludge waste streams this creates, the SEA cannot be considered to have

met the information requirements under Annex I of the SEA Directive.

20 National Policy Statement for Hazardous Waste [DEFRA 2013]

21 NGL: 'natural gas liquids'. For information see http://en.wikipedia.org/wiki/Natural-gas_processing

22 Explosion rocks natural gas compressor station, Laura Legere, Times-Tribune (Pennsylvania), 30th March 2012 http://thetimes-tribune.com/news/explosion-rocks-natural-gas-compressor-station-1.1292502

23 Estimation of regional air-quality damages from Marcellus Shale natural gas extraction in Pennsylvania [Litovitz 2013]

24 Evaluation of impact of shale gas operations in the Barnett Shale region on volatile organic compounds in air and potential human health risks [Bunch 2014]

25 Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical Review [Moore 2014]

26 Protecting and enhancing our urban and natural environment to improve public health and wellbeing, DEFRA, updated March 2014. https://www.gov.uk/government/policies/protecting-and-enhancing-our-urban-and-natural-environment-to-improve-public-health-and-wellbeing/supporting-pages/international-european-and-national-standards-for-air-quality

27 Commission takes action against UK for persistent air pollution problems, European Commission press release, 20th February 2014. http://europa.eu/rapid/press-release_IP-14-154_en.htm

28 Air pollution by ozone across Europe during summer 2013 [EEA 2014]


http://europa.eu/rapid/press-release_IP-14-154_en.htm

https://www.gov.uk/government/policies/protecting-and-enhancing-our-urban-and-natural-environment-to-improve-public-health-and-wellbeing/supporting-pages/international-european-and-national-standards-for-air-quality



http://thetimes-tribune.com/news/explosion-rocks-natural-gas-compressor-station-1.1292502

http://thetimes-tribune.com/news/explosion-rocks-natural-gas-compressor-station-1.1292502

http://en.wikipedia.org/wiki/Natural-gas_processing

2C. The status of underground coal gasification

Over the last few years the Coal Authority has issued a number of licences for underground coal

gasification29 (UCG) around the coast of Britain – and there is currently an application for the first on-

shore UCG site in Warwickshire. This policy has not yet been subject to a strategic environmental

appraisal, despite the fact that developers are currently engaged in bringing forward proposals for

test/exploratory plants around Britain.

DECC is currently proposing, as part of regulatory reforms to make shale gas authorisation simpler,

to reform/simplify the process for UCG authorisation30. Given that the need for SEA of unconventional

oil and gas policy has been established in law, it is difficult to see how DECC can proceed with their

policy proposals on UCG without first subjecting them to SEA.

UCG has a poor history. It was trialled in Britain in the 1950s and abandoned. The most recent trials

in Queensland, Australia, have led to pollution of the local environment31. Two of the three companies

involved have subsequently left Australia to develop plants elsewhere.

The failure to include underground coal gasification in this SEA means that DECC's policies

in relation to underground coal gasification, enacted via the Coal Authority, are arguably

unlawful. There needs to be a clarification within DECC's policies as to whether UCG is to be

lumped together with other types of “native hydrocarbon” development, or whether it will be

subject to a separate SEA process.

2D. The failure to model coalbed methane as a distinct processing

According to the position stated in the SEA32 –

The effects of exploration and production activities associated with virgin coalbed methane

(VCBM) are similar to those described in the assessment of effects of unconventional oil and gas

(Stages 1 to 6) above, although hydraulic fracturing is not normally required.

Both statements – that coalbed methane (CBM) is similar to shale gas, and that CBM doesn't

normally involve hydraulic fracturing – are demonstrably incorrect based on recent experience.

The greatest documented experience in relation to coalbed methane is in the states of Queensland

and New South Wales in Australia (note, CBM in Australia is called 'coal seam gas', or CSG).

CBM/CSG began to expand across the east of Australian a little over a decade ago (Western

Australia tends to concentrate on shale gas). As a result, Australia today has a mass public movement

which seeks to oppose CBM that, arguably, is better organised and has been far more effective than

their shale gas counterparts in the USA.

This month, the New South Wales Government's Minister for Resources and Energy suspended all

its operational Petroleum Exploration Licences (PELs), and halted the consideration of new/in process

applications. All regulatory activities have been halted pending a review of the environmental impacts

29 Underground Coal Gasification in the UK, Coal Authority. http://coal.decc.gov.uk/en/coal/cms/publications/mining/gasification/gasification.aspx

30 Seventh Statement of New Regulation – January-June 2014, DECC, December 2013.https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/266300/DECC_SNR7_V0_3.pdf

31 Independent Scientific Panel Report On Underground Coal Gasification Pilot Trials, Independent Scientific Panel on Underground Coal Gasification, Queensland Department of Environment and Resource Management, June 2013.http://www.fraw.org.uk/files/extreme/derm_2013.pdf



http://www.fraw.org.uk/files/extreme/derm_2013.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/266300/DECC_SNR7_V0_3.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/266300/DECC_SNR7_V0_3.pdf

http://coal.decc.gov.uk/en/coal/cms/publications/mining/gasification/gasification.aspx

of past CBM operations, and the perceived need to introduce a tighter regulatory regime33. This

change in policy has been driven by rising public and professional concerns about the impacts of

CBM/CSG. In Queensland CBM development has been on-going for a slightly longer period, and

there too significant public opposition exists. Following leaks by a whistle-blower, in 2013 ABC News

revealed evidence of corruption within the Queensland State Government environmental

department34 – where political pressure was used to force regulators to speed up approvals of the

licensing process, and to ignore the lack of environmental evidence to support licence applications.

The longest history of CBM operations is in the USA. The difficulty with the situation in the USA is

that the impacts to date, certainly in comparison to recent studies in Australia, are largely

undocumented.

From the 1960s to the 2000s, particularly in states such as Wyoming, there was extensive working

of coal seams for gas – although large parts of these fields are today being run down as investment

has shifted towards the shale gas industry. However, due to poor historic regulation of the industry by

individual US states, there is growing concern about “orphaned” CBM wells35. Until very recently the

scale of pollution from CBM wells was unforeseen when permits to develop CBM fields were issued.

Today the bonds provided as part of those historic permitting processes are no longer sufficient to pay

for the plugging/clean-up of well sites – meaning State governments must now step in to meet the

cost as the companies involved declare themselves insolvent.

Recent experience in Australia suggests that hydraulic fracturing is routinely used in CBM

operations36, and that in future this will increase as more margin regions are tapped – with perhaps up

to 80% of CBM wells being fractured. In practice the necessity to 'frack' is largely determined on an

economic analysis of the area concerned, rather than by policy. The gas resource properties of coal

seams vary across the field. As more marginal areas of fields are being exploited, so the economic

case to frack to initiate or to maintain production volumes improves.

In relation to environmental impacts the SEA report further states37 –

Scale and duration of activities: VCBM exploration drilling and production sites are usually

smaller than unconventional oil and gas drilling sites whilst commercially viable VCBM

containing formations tend to be shallower (200-1,500m depth) and drilling times may also be

relatively shorter. In consequence, it is likely that negative effects on SEA objectives relating to,

for example, biodiversity, health, land use, geology and soils, air quality, waste and climate

change due to emissions to air, waste generation and noise arising from construction activities

and drilling would be less.

Again, the practical evidence on CBM extraction does not corroborate this view. This is especially

true of the recent history of CBM working in Australia.

The CBM industry in Australia, like shale gas in the USA, has developed over the last decade or so.

Therefore it is only recently that environmental scientists and health professionals have been able to

33 NSW Government Freezes Petroleum Exploration Licence Applications, New South Wales State Government, 26th March 2014. http://www.csg.nsw.gov.au/__data/assets/pdf_file/0020/41834/rel_roberts_20140326_petroleum_exploration_licence_applications.pdf

34 GAS LEAK! [ABC 2013]

35 Coalbed methane bust leaves thousands of orphaned gas wells in Wyoming, High Country News, 23rd December 2013. https://www.hcn.org/issues/45.22/the-coalbed-methane-bust-has-left-orphaned-gas-wells-across-wyoming

36 Hydraulic Fracturing in Coal Seam Gas Mining [NTN 2011]



https://www.hcn.org/issues/45.22/the-coalbed-methane-bust-has-left-orphaned-gas-wells-across-wyoming

https://www.hcn.org/issues/45.22/the-coalbed-methane-bust-has-left-orphaned-gas-wells-across-wyoming

http://www.csg.nsw.gov.au/__data/assets/pdf_file/0020/41834/rel_roberts_20140326_petroleum_exploration_licence_applications.pdf

http://www.csg.nsw.gov.au/__data/assets/pdf_file/0020/41834/rel_roberts_20140326_petroleum_exploration_licence_applications.pdf

catch-up with the impacts of development to date. There have been local assessments of

environmental38 and health impacts39 in CBM field areas, and more recently debate has been growing

in the medical community40. Recent sampling by universities has also discovered – as with similar

studies of shale gas operations in the USA – high fugitive emissions rates within CBM fields41. Also,

due to the high levels of salt which CBM operations deposit in rivers in the areas affected42, and the

hydrogeological impacts of CBM de-watering operations on an already drought-stressed region, CBM

development is increasingly causing conflicts with the agricultural community too43.

One of the key differences in the production of CBM and shale gas is the amount of

produced/flowback water – as outlined briefly in the SEA44. With shale gas, a large proportion of the

flowback water is the result of the high volumes of water injection during the hydraulic fracturing

process. With CBM the coal seam are actually de-watered – pumping water from the seams in order

to force the gas from the rock. Unlike shale gas, which is trapped in pore spaces, the gas trapped in

coal seams is released by the change in pressure and saturation created by de-watering; causing gas

trapped in the 'cleats' (the bedding planes of the coal seam) to be liberated. Hydraulic fracturing can

assist this process by creating pathways for migration within less permeable seams, speeding the

movement of gas and thus increasing production volumes within a shorter time span.

The result is that whilst the rate of flowback water exponentially decreases with shale gas

production, to maintain gas flow in CBM operations the volume of pumped water must be maintained

– or even increased – over time. Even where fracturing is not used to initiate gas flow, at a later date

there many be an economic case to undertake hydraulic fracturing to maintain gas flow as the field

depletes.

The large quantities of produced water from coal seams, due to their differing geological history

compared to shale and the presence of high levels of organic carbon, contain differing levels of trace

contaminants. This gives rise to a differing pollution load within the produced water, and given that

water volumes must be maintained, this pollution load is maintained for a longer period. This

translates to a higher volume of wastes resulting from water treatment, and the potential for a higher

pollution load being discharged into aquatic ecosystems.

Given these significant differences, it cannot be said that the processes of shale gas and coalbed

methane production are equivalent. In terms of their ecological footprint – for example the propensity

for CBM de-watering to affect sensitive aquatic habitats by lowering groundwater levels, or the

differing discharge profile and contaminant load of each technology – they are not the same.

Therefore SEA should have assessed CBM as a distinct process to shale gas – and the SEA should

have modelled its impacts as a distinct process.

Finally, the SEA states that45 –

38 Submission to the NSW Chief Scientist and Engineer – Review of coal seam gas activities in NSW [CHA 2013]

39 Symptomatology of a gas field [McCarron 2013]

40 Harms unknown: health uncertainties cast doubt on the role of unconventional gas [Coram 2014]

41 Enrichment of Radon and Carbon Dioxide in the Open Atmosphere of an Australian Coal Seam Gas Field [Tait 2013]

42 Assessing the salinity impacts of coal seam gas water on landscapes and surface streams, Australian/Queensland StateGovernment, February 2013. htt://www.dnrm.q p ld.gov.au/__data/assets/pdf_file/0019/106093/csg-irrigation-salinity-risk-assessment.pdf Coal Seam Gas: Produced Water and Solids, Office of the NSW Chief Scientist and Engineer, New South Wales State Government, 22nd November 2013. http://www.chiefscientist.nsw.gov.au/__data/assets/ pdf_file/0006/38157/OCSE-Final-Report-Stuart-Khan-Final.pdf

43 The Agri-Gas Fields of Australia: Black Soil, Food, and Unconventional Gas [de Rijke 2013]




http://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0006/38157/OCSE-Final-Report-Stuart-Khan-Final.pdf

http://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0006/38157/OCSE-Final-Report-Stuart-Khan-Final.pdf

http://www.dnrm.qld.gov.au/__data/assets/pdf_file/0019/106093/csg-irrigation-salinity-risk-assessment.pdf




Unlike shale gas or oil, for which exploration in the UK has only just begun, VCBM in the UK

has been the subject of active exploration for over a decade, and a number of small-scale

production projects already exist. The levels of activity however remain broadly comparable with

those for conventional oil and gas. There seems no reason to expect any substantial change in

outlook, and no attempt has been made in the assessment to provide a separate indication of low

and high levels of activity for VCBM.

Again, from my recent experiences working with communities around Britain, this is not the case.

Also we must differentiate between the very different process of Coal Mine Methane (CMM), of which

a number of projects exists across Britain (usually tied to pre-existing disused conventional coal mine

workings), and CBM, for which only a few exist. Arguably CBM has not seen major developments in

the UK for many of the same reasons that shale gas did not take-off here when it did in the USA

around 1999/2000 – until the peak and decline of North Sea gas production, and the higher prices this

created within Europe, the economics of unconventional gas were not viable in the European market.

Many of the PEDLs issued under the 13th On-Shore Oil and Gas Licensing Round in 2008 –

especially in South Wales, the Marches, the East Midlands and Scotland – are targeting coal seams.

Deeper shale deposits may also be tapped, but, to take Dart Energy as an example (an Australian

company with a history of CBM/CSG working, and who left Australia in 201346 to concentrate its

activities in markets where they considered the regulatory regime to be less demanding), their recent

exploration activities have been centred around the potential for CBM.

We have also seen recent reports from the British Geological Survey, following on from the interest

created by the PEDL licences granted under the 13th Round, describing the CBM potential of the

UK47, and of individual regions such as the East Midlands48. Therefore to assume that the present low

uptake of CBM will continue in the future is not borne-out by current exploration trends, or the studies

currently being carried out into the future potential for CBM as a result of the 14th Round.

CBM, as shown by the last decade or so of experience in Australia, has definable impacts

upon the natural environment and human health. Likewise the regions where CBM potential

exists – predominantly former coalfield areas – have a distinct local geology and landscape

character compared to those areas being targeted for shale gas extraction. Not modelling the

distinct processes of coalbed methane operations – in particular the differing

qualities/quantities of produced water and the propensity to impact upon hydrogeology that

this creates – represents a significant failure within the method of the SEA report.

2E. The assumed depth of unconventional gas drilling

The SEA gives differing figures for the depth of unconventional gas working:

Quantification of Activity Scenarios for Unconventional Oil and Gas Exploration and Production

Exploration drilling and hydraulic fracturing: Depth of well – Variable, 500m to 3000m or

more.49

46 Dart Energy slashes costs amid CSG changes, Sydney Morning Herald, 2nd April 2013. http://news.smh.com.au/breaking-news-business/dart-energy-slashes-costs-amid-csg-changes-20130402-2h3wj.html

47 The Unconventional Hydrocarbon Resources Of Britain's Onshore Basins – Coalbed Methane [BGS 2012A]

48 Can New Technologies be Used to Exploit the Coal Resources in the Yorkshire-Nottinghamshire Coalfield? [BGS 2013]

49 Table 2.7, page 29, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]


http://news.smh.com.au/breaking-news-business/dart-energy-slashes-costs-amid-csg-changes-20130402-2h3wj.html

http://news.smh.com.au/breaking-news-business/dart-energy-slashes-costs-amid-csg-changes-20130402-2h3wj.html

...the geological context of shale gas or oil in the UK is one of considerable distances between

the target strata to be fractured and likely sources of groundwater (likely to be in excess of

1,000m).50

The use of these figures, given the depth of gas-bearing rocks at at least one of the locations it is

proposed to licence, raises the question as to whether AMEC have actually assessed the likely depths

of shale gas working in all the areas identified in the SEA study.

Map NTS151 shows the areas assessed as part of the SEA. It is a simple process to discover the

depths of potential conventional/unconventional gas resources in these area. For example, let's

examine the small box which straddles the boundaries of Buckinghamshire and Oxfordshire. The

knowledge of gas deposits is based on early drilling carried out before World War I, and more

intensive drilling carried out by BP in the early 1960s – both instances produced large gas flows52.

As part of these historic drilling operations, the deepest bore drilled was just short of 100 metres

below Ordnance datum. Therefore the depth from the surface to gas-bearing strata, given the

average height of the local landscape, is slightly less than 200 metres. This is broadly similar to the

depth of drilling/hydraulic fracturing at two sites in the USA – Pavillion in Wyoming and Dimock in

Pennsylvania – where significant groundwater pollution has affected local communities.

If the primary safety feature of shale gas is that it lies beneath a great depth of the rock, then it

should be a simple matter to exclude those areas which have a short distance to the gas-bearing

strata. At just under 200 metres, the search area allocated on the border of Oxfordshire and

Buckinghamshire is less than half the depth of the minimum figure suggested in the SEA report. This

should have been picked up in the assessment of the areas proposed for licensing under the 14th

Round.

As the area identified here was missed it raises the question as to whether, in order to

provide a higher degree of safety, AMEC/DECC have adequately assessed the depth of gas-

bearing rocks across Britain. Given that this data is readily available from the British

Geological Survey's mapping system, it would be a relatively simple matter to assess the

depth of the likely gas-bearing strata. Given the shallow depth in this area on the border of

Oxfordshire and Buckinghamshire, this block must be withdrawn from the 14th Round.

2F. The interaction of planning policy guidance and the SEA

At various points during the discussion with the SEA report, potential problems picked up by the

assessment are dismissed because – it is stated – the details can be dealt with at the planning

application stage. For example:

There is the potential for activities associated with unconventional oil and gas exploration and

production to have negative effects on the population objective through disturbance to local

community, particularly during well site construction, exploration drilling and production

development stages (Stages 2-3) arising from an increase in vehicle movements. However, any

50 Page 96, ibid.

51 Page 6, ibid.

52 Mineral Resource Information in Support of National, Regional and Local Planning Buckinghamshire and Milton Keynes,British Geological Survey (ref. CR/03/77N), 2004. http://www.bgs.ac.uk/downloads/start.cfm?id=2591 The Unconventional Hydrocarbon Resources of Britain's Onshore Basins – Shale Gas [BGS 2012B]


http://www.bgs.ac.uk/downloads/start.cfm?id=2591

such effects can be expected to be mitigated through planning controls.53

There is the potential for activities associated with unconventional oil and gas exploration and

production to have negative effects on human health, particularly during the more intensive and

intrusive stages (Stages 2-5). However, any such effects can be expected to be mitigated through

planning controls.54

Whilst it is assumed that there would be a 5km distance between well pad sites... and activities

would not be undertaken simultaneously, which may reduce the potential for localised impacts on

air quality arising from multiple well pad sites, effects could be significant where sites are

located within or in close proximity to areas where there are existing air quality issues (such as

Air Quality Management Areas) and/or sensitive receptors. However, 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.55

The assessment of impacts above requires that the planning authority which receives an

application to develop a well pad site(s) assess the impacts of emissions, or the proximity of polluting

processes, upon public health. This is something which, in the Department of Communities and Local

Government's (DCLG) National Planning Policy Framework, local planning authorities are expressly

instructed not to do56 –

...local planning authorities should focus on whether the development itself is an acceptable use

of the land, and the impact of the use, rather than the control of processes or emissions

themselves where these are subject to approval under pollution control regimes. Local planning

authorities should assume that these regimes will operate effectively. Equally, where a planning

decision has been made on a particular development, the planning issues should not be revisited

through the permitting regimes operated by pollution control authorities.

This position was reiterated in the DCLG's specific planning guidance on on-shore oil and gas57 –

The planning system controls the development and use of land in the public interest and, as

stated in paragraphs 120 and 122 of the National Planning Policy Framework, this includes

ensuring that new development is appropriate for its location taking account of the effects

(including cumulative effects) of pollution on health, the natural environment or general amenity,

and the potential sensitivity of the area or proposed development to adverse effects from

pollution. In doing so the focus of the planning system should be on whether the development

itself is an acceptable use of the land, and the impacts of those uses, rather than any control

processes, health and safety issues or emissions themselves where these are subject to approval

under other regimes. Minerals planning authorities should assume that these non-planning

regimes will operate effectively.

The guidance on on-shore oil and gas – in paragraphs 30-32 – then lists various criteria which local


54 Page 90, ibid.

55 Page 96, ibid.

56 Paragraph 122, National Planning Policy Framework, Department for Communities and Local Government, March 2012.https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

57 Paragraph 29, Planning practice guidance for onshore oil and gas, Department for Communities and Local Government,July 2013. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/ 224238/Planning_practice_guidance_for_onshore_oil_and_gas.pdf


https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/224238/Planning_practice_guidance_for_onshore_oil_and_gas.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/224238/Planning_practice_guidance_for_onshore_oil_and_gas.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf

planning authorities either can or cannot consider when determining planning applications. Again, in

the context in which they are described in the SEA report, the planning authorities would not be

permitted within a strict interpretation of the guidelines to apply the type of control specified in the

SEA.

It should be noted that the planning guidance on on-shore oil and gas was not consulted upon –

despite the fact that it has significant implications for the environment and public participation. It was

imposed without public consultation. It is arguable therefore that these guidelines may violate the

consultation requirements of the Aarhus Convention58, and therefore may arguably be unlawful and

hence unenforceable. In any case, large parts of European Law – for example on waste or

air/groundwater pollution – have direct effect upon local authorities. Therefore, given that in law

permitting oil and gas development may violate these laws, and because evidence from other nations

where these processes have been carried out suggest that regulation cannot guarantee to protect the

environment, it would be open to local authorities to challenge the reasonableness of these

guidelines.

It is disingenuous to suggest in the manner described, as is done at various points within

the SEA report, that planning authorities have the freedom to consider the environmental and

health impacts of on-shore oil and gas developments. Such consideration has been expressly

prohibited by recent DCLG guidance. Therefore, unless the Department of Energy and Climate

Change significantly modify their policies, or unless DCLG withdraws their prohibitions, the

policy outlined in the SEA report cannot be enacted by local planning authorities. This

prevents DECC from achieving the environmental protection objectives outlined in the SEA.

58 The Aarhus Convention: An Implementation Guide (Second Edition), United Nations Economic Commission for Europe, April 2013. http://www.fraw.org.uk/files/ukgov/unece_2013.pdf


http://www.fraw.org.uk/files/ukgov/unece_2013.pdf

3. General themes/issues across the SEA study

Rather than examining specific flaws in the report, this section outlines wider deficiencies within the

SEA. With reference to other studies and research papers, the observations in this sections show how

the latest research and evidence/observations invalidate elements of the SEA, and by extension the

policies being pursued by DECC.

3A. BGS gas resource estimates

Within the SEA a highly misleading statistic is quoted in order to support policy objectives59 –

A recent report by the British Geological Survey, while estimating the gas in place within the

Bowland Shale of northern England to be substantial (mid-point estimate 36.8 trillion cubic

metres/1,300 trillion cubic feet), noted that the assessment of shale gas resources in the UK is as

yet still in its infancy. DECC has subsequently stated that while shale gas has potential in the

UK, little drilling or testing has taken place and therefore it is not possible to make meaningful

estimates of how much shale gas may be practically and commercially recoverable, which is to

say that it is not yet possible to estimate the size of the reserves.

During July 2013, following the publications of the British Geological Survey's Bowland Shale Gas

Study60, this “1,300 trillion cubic feet” figure was repeated regularly. Unfortunately it was never

adequately stated exactly what this figure meant – not even in DECC's publication designed to

explain what the figure meant61.

The “1,300 trillion cubic feet” figure – from now on expressed using the metric 36.8 trillion cubic

metre (tcm) figure – represents a value for “gas in place”. That is an estimate of the gas physically

present in the rock. However, this is what's known as the 'P50' or “50% probability” figure. This means

that there's an evens chance that this amount of gas exists in the rock.

This figure is considered too unreliable by many financial institutions and stock exchanges, who

instead use the 'P90' or “90% probability” figure. This figure expresses that there's a 90% chance that

the figure is at or below that stated value, and is used by stock markets for reserves reporting

because it is considered a far more reliable estimate of the gas likely to be produced by a certain

geological unit. The P90 figure from the BGS study is 23.3tcm – 37% lower than the figure which was

used across the media in July 2013.

This figure is still for “gas in place”. Current technology cannot recover all the gas within the rock

strata. Various estimates from the US suggest that the figure may be, within the best locations, 10%,

and often as little as 2%. In fact, as the best locations in US shale gas plays, and more marginal

locations are drilled, average daily shale gas production per well has been falling62. Therefore

assuming that the figure were to lie between 2% and 10%, the amount of gas produced would be

between 0.446 to 2.33tcm – or 466 billion cubic metres (bcm) to 2,330bcm.


60 Bowland Shale Gas Study, BGS/DECC, July 2013. https://www.gov.uk/government/publications/bowland-shale-gas-study

61 Resources vs Reserves: What do estimates of shale gas mean?, DECC, 27th July 2013. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/256358/Publication_Resources_vs_Reserves_June13.pdf

62 A reality check on the shale revolution [Hughes 2013]


https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/256358/Publication_Resources_vs_Reserves_June13.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/256358/Publication_Resources_vs_Reserves_June13.pdf

https://www.gov.uk/government/publications/bowland-shale-gas-study

This is the total production. Next we have to divide this figure by the production period in order to

produce an annualised figure. The SEA suggests as little as 20 years, whilst a figure of 30 to 40 years

might be more realistic given the lower financial returns likely within the European market. Calculating

the annualised figure for each period, between the 2% (typical) and 10% (exceptional) recover factor:

20 years – 23.3 to 117 bcm/year; 30 years – 16 to 78 bcm/year; 40 years – 12 to 58 bcm/year.

It should be noted that in 2012 (the last full year of official statistics63) the UK produced around

7.8bcm/year of gas, but in that same year the economy demanded 14.8bcm – the deficit of 7bcm

being imported from abroad. However, we are also losing North Sea oil production, we now import

much of our coal, and there are no viable uranium resources in Britain. Expressed as a value of

natural gas, the UK's total primary energy demand in 2012 was 43bcm. That figure itself is 10% lower

than the peak of energy consumption before the recent economic recession in 2005, 48bcm.

Therefore there are great uncertainties within the Government's policies on unconventional gas.

Using a realistic projection (P90 'gas-in-place' figure and 2% recovery factor), if it takes longer than 40

years to produce the Bowland formation – or the BGS study turns out to be an over-estimate – then

we will not maintain natural gas production. More importantly, given that natural gas accounts for less

than two-fifths of the UK energy economy, whilst we may address the “gas issue”, there are other

energy and non-energy resources facing production bottle-necks due to resource depletion64.

Just as 40 years ago Britain celebrated the commissioning of the North Sea, today we are trying

desperately to find another supply of energy; what will we in 40 years from now? Government policy,

based upon the consumption of finite energy resources, cannot solve Britain's long-term energy and

economic problems65. More importantly, whilst gas is quite important to the UK economy, in terms of

the global economy of which Britain is a part, petroleum is a far more important component66 – and

current global trends indicate that conventional crude oil production has been on a long-term plateau

since 2004/567, and production may begin to decline over the next two years or so.

It is not a new source of gas which Britain needs, but rather a new economic model68. The current

proposals for unconventional gas production simply shift the problems of energy supply into the next

generation, whilst at the same time creating a more damaged and toxic global environment69 – which

by no sense of the definitions of “sustainable development” called for under the SEA Directive, and

other community legislation, can be described as a environmentally sustainable option.

The focus on producing more finite energy resources is deflecting the political capital

required to find a truly long-term solution to human sustainability. Not only does producing

more fossil fuels exacerbate current ecological difficulties, but it shifts an even greater crisis

onto the next generation. The whole approach of the Government's policy objectives, based

upon the short-term depletion of finite resources, does not meet any valid “sustainability”

criteria.

63 Digest of UK Energy Statistics (DUKES) 2013, DECC. https://www.gov.uk/government/collections/digest-of-uk-energy-statistics-dukes

64 A Comparison Of The Limits To Growth With Thirty Years Of Reality [CSIRO 2008]

65 The Second Law of Economics: Energy, Entropy, and the Origins of Wealth, Reiner Kümmel, Springer, June 2011. ISBN9781-4419-9364-9. See also Ecological Economics Comes of Age [Czech 2013]

66 Economic vulnerability to Peak Oil [Kerschner 2013]

67 Oil's Tipping Point has Passed [Murray-King 2013]

68 The Need for a New, Biophysical-Based Paradigm in Economics for the Second Half of the Age of Oil [Hall 2006]

69 State of the Planet Declaration [UNCED 2013]


https://www.gov.uk/government/collections/digest-of-uk-energy-statistics-dukes

3B. Well lifetime, leakage and integrity

The SEA report states –

There is a risk of hydraulic fracturing causing groundwater contamination, principally due to

leakages of methane as a result of inadequacies in well cementing... Taking into account the

requirements for discharge consents/permits and EA/SEPA policy in respect of groundwater

protection, it is considered reasonable to suggest that any risk of contamination from fracturing

activities is exceptionally low.70

That position is not supported by a variety of other research studies. For example, of the oft-quoted

paper71 from the oil and gas industry's own journal Oilfield Review, which used data from a wide

range of conventional oil and gas wells to show that 1 in 20 (5%) of wells fail (i.e., show gas leakage)

on the first day; and that failure rate increases to 3 in 5 (60%) after 25 years. Other studies from that

period begin to characterise one of the principal flaws of well bores – the cement job which is

intended to prevent contaminant migration72. This is an issue which has been revisited in recent

papers looking at well leakage in shale gas fields in Pennsylvania73.

The most recent large-scale study, released this month, and which examines a variety of

conventional and unconventional wells, states in relation to recent US gas projects in Pennsylvania –

Of the 8030 wells targeting the Marcellus shale inspected in Pennsylvania between 2005 and

2013, 6.3% of these have been reported to the authorities for infringements related to well

barrier or integrity failure. In a separate study of 3533 Pennsylvanian wells monitored between

2008 and 2011, there were 85 examples of cement or casing failures, 4 blowouts and 2 examples

of gas venting.

The paper concludes –

Well barrier and integrity failure is a reasonably well-documented problem for conventional

hydrocarbon extraction and the data we report show that it is an important issue for

unconventional gas wells as well.

The paper also noted that in the UK – where disused well bores are usually plugged, removed

below surface level and then the site is restored – the true level of leakage over the installed lifetime

of the well is likely to be higher, because these wells are not subject to on-going monitoring/after-care.

The problem with the debate over well leakage is that the discussion focusses on guaranteeing well

integrity at the time of installation – when in fact the evidence suggests that failure rates, and hence

the likelihood of pollutant migration, increases with time. Therefore a well which performs adequately

for a few years may, some years later, fail and allow the vertical migration of pollutants.

Other assumptions based on installation-time testing, such the likelihood of fugitive emissions

increasing with time, are also invalidated by these studies – and help to explain the gap between the

official industry/regulator position on leakage, and recent studies of high levels of contaminants found

in the atmosphere around gas fields74. Basing long-term projections/guarantees of environmental

protection on the integrity tests conducted at the time of installation therefore has little relevance to

70 Page 95/6, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]

71 From Mud to Cement – Building Gas Wells [Brufatto 2003]

72 Why Oilwells Leak: Cement Behavior and Long-Term Consequences [SPE 2000]

73 Fluid Migration Mechanisms Due To Faulty Well Design And/Or Construction [Ingraffea 2013]

74 Fugitive Emissions from Coal Seam Gas [Santos 2012]Enrichment of Radon and Carbon Dioxide in the Open Atmosphere of an Australian CSG Field [Tait 2013]


real-world evidence on how oil and gas wells fail. Neither the SEA report, nor DECC's oil and gas

policies more generally, specify conditions for the long-term after-care of well sites.

By underplaying the role of well leakage, the SEA's position on well leakage does not

concur with currently available evidence. Oil and gas well failure and leakage is a statistically

quantifiable phenomena. Thus the possible impacts of groundwater contamination and gas

migration arising from the Government's oil and gas drilling proposals is calculable. For

example, taking the range of well numbers outlined in the SEA (180 to 2880), the number of

wells we might expect to fail would be at least 11 to 181 – although, as outlined in recent

research, the problematic reporting and lack of monitoring of past well bores is likely to make

this an underestimate.

3C. Fugitive gas emissions and the MacKay-Stone report

Recent disclosures75 relating to communications between DECC officials and the staff of gas

companies demonstrate the close media management. For example, one email from the Department

of Energy to Centrica in September 2013 stated76 –

Our polling shows that academics are the most trusted sources of information to the public so we

are looking at ways to work with the academic community to present the scientific facts around

shale.

Given that DECC put such emphasis on “academic” information in order to sway public opinion, it

was not surprising that the shale gas public relations agenda was dominated by three academic

reports during 2013:

the BGS' Bowland study in July (covered in 3A above);

the Mackay-Stone report (dealt with below); and

the Public Health England study (dealt with in section 3D which follows).

The difficulty with all these studies is that – as they are intended to provides a “positive spin” on the

unconventional gas issue – the scientific uncertainties over unconventional gas production, and

omissions/partial emphasis within the case made within each study, do not provide a balanced view of

the issue to the public.

The Mackay-Stone report is one such example of how selective quoting of certain studies, and

directly misleading statements, have been used to mislead public opinion. According to the

statements made in the SEA report77 –

It is estimated that GHG emissions associated with Stage 2 and Stage 3 could be up to 0.96M

tCO2eq per annum... This estimate is based on the median values of GHG emissions from a range

of source data, as detailed in a recent report by MacKay and Stone (2013) concerning potential

GHG emissions associated with shale gas extraction and use... In this respect, a recent study by

75 Emails reveal UK helped shale gas industry manage fracking opposition, Damian Carrington, The Guardian, Friday 17th January 2014. http://www.theguardian.com/environment/2014/jan/17/emails-uk-shale-gas-fracking-opposition

76 File 'EMAIL DECC TO CENTRICA 19.09.13.pdf', available as part of a ZIP archive from FOI release: Correspondence and meetings between the Office of Unconventional Gas and Oil, UKOOG, Centrica and Igas, DECC, 15th January 2014. https://www.gov.uk/government/publications/correspondence-and-meetings-between-the-office-of-unconventional-gas-and-oil-ukoog-centrica-and-igas



https://www.gov.uk/government/publications/correspondence-and-meetings-between-the-office-of-unconventional-gas-and-oil-ukoog-centrica-and-igas

https://www.gov.uk/government/publications/correspondence-and-meetings-between-the-office-of-unconventional-gas-and-oil-ukoog-centrica-and-igas

http://www.theguardian.com/environment/2014/jan/17/emails-uk-shale-gas-fracking-opposition

http://www.theguardian.com/environment/2014/jan/17/emails-uk-shale-gas-fracking-opposition

Allen et al (2013) concerning methane emissions at natural gas production sites in the United

States concludes that the application of current good practice is more successful in reducing well

completion emissions than previously estimated...

The Mackay-Stone report was published on 9th September 201378. Previous studies had claimed

that fugitive emissions of methane meant unconventional gas had a carbon footprint far higher than

conventional natural gas79. One of the key claims in the Mackay-Stone report was that shale gas in

Britain would have an equivalent footprint to existing natural gas production. As Energy Minister Ed

Davey said at the launch of the report80 –

This report shows that the continued use of gas is perfectly consistent with our carbon budgets

over the next couple of decades... It should help reassure environmentalists like myself, that we

can safely pursue UK shale gas production and meet our national emissions reductions targets

designed to help tackle climate change.

The version published by DECC at the launch in September 2013 was incomplete – missing three

vital appendices (B, C and D) which defined the methodology under which the “headline” results of

the report had been constructed. A few days later, after reading the report, I requested the full version

from DECC. This did not arrive for almost six weeks. The critical appendix with regard to the

comparison of unconventional shale gas and conventional natural gas, Appendix B, stated –

In the absence of information about the quality of the UK’s shale gas we have assumed (my

emphasis) that shale gas would produce similar emissions to those in the production and

processing of conventional gas.

Therefore the claims in the report, reiterated by the Energy Minister, are based upon an assumption

rather than real-world data analysis. Of course, due to the prolonged delay by DECC in sending a

copy of the complete report, six weeks after the event this was no longer a live media issue which I

could comment upon.

There was one further twist in the impression of the “science” given at the launch of the Mackay-

Stone report. The report referenced a forthcoming report from the University of Texas – which was

published81 shortly after their report. This new study claimed that methane/carbon emissions from

unconventional oil and/or gas wells were within the low range specified by the Mackay-Stone report.

However, there is a critical factor not stated within the DECC report – the University of Texas study is

a non-randomised sample of 190 natural gas sites in the United States.

In other words, of the the 8000 or so wells drilled in the USA that year the study team were told

which 190 sites they were to monitor. Furthermore, the failure to define precisely what type of wells

were being monitored (either tight oil/gas, shale, coalbed methane, and in which geological formation

these were located) means that a comparison with the values given in other studies is difficult to carry

out. The fact that the study is based upon a non-randomised sample also means that – in

contradiction to the assertions of DECC and the Energy Minister – its results cannot be directly

78 Potential Greenhouse Gas Emissions Associated with Shale Gas Extraction and Use [DECC 2013B]

79 Methane and the greenhouse-gas footprint of natural gas from shale formations [Howarth 2011]Venting and Leaking of Methane from Shale Gas Development [Howarth 2012]Increased stray gas abundance in a subset of drinking water wells near Marcellus shale gas extraction [Jackson 2013]Methane emissions estimate from airborne measurements over a western United States natural gas field [Karion 2013]

80 Davey: UK shale gas development will not be at expense of climate change targets, Department for Energy & Climate Change, 9th September 2013. https://www.gov.uk/government/news/davey-uk-shale-gas-development-will-not-be-at-expense-of-climate-change-targets

81 Measurements of methane emissions at natural gas production sites in the United States [Allen 2013]


https://www.gov.uk/government/news/davey-uk-shale-gas-development-will-not-be-at-expense-of-climate-change-targets

https://www.gov.uk/government/news/davey-uk-shale-gas-development-will-not-be-at-expense-of-climate-change-targets

related to unconventional oil/gas wells as a whole82.

As outlined in the email conversations between gas companies and DECC, the unconventional gas

project in Britain is increasing an issue of media management rather than objective fact. That's a

problem because it means that politics, and thus the media, are no longer relating a transparent case

which will enable the public to objectively consider the potential risks and benefits of the

Government's unconventional gas project.

As a result of this effort at media management rather than objective reporting, when we

examine the detail in the Mackay-Stone report it does not demonstrate that unconventional

gas development in Britain will be equivalent in its climate change impacts to conventional

gas; or better than other fossil fuels such as coal. Likewise the University of Texas study,

which DECC hoped would allay criticisms from recent studies of fugitive emissions from

unconventional gas sites, did not do so because of its poor statistical construction.

3D. The Public Health England report

A month after the Mackay-Stone report, Public Health England (PHE) published a report on the

health impacts of unconventional gas production83. As with the report by Mackay & Stone, the PHE

study was a largely theoretical exercise, based upon a partial examination of the evidence available

on the links between unconventional gas exploration/production and health. Again, the purpose of the

PHE report was to demonstrate an equivalence between the health impacts of conventional gas

production and unconventional gas. As stated in the SEA report84 –

Effects on health are likely to be similar to those identified in respect of conventional oil and gas,

although the scale, duration and magnitude of effects would be greater (commensurate with the

number of wells, average well depth and also the requirement hydraulic fracturing) and could

include air quality, noise and vibration impacts from construction works, HGV movements,

drilling, fracturing and flaring. Taking into account expected regulatory controls, the temporary

nature of individual activities and the implementation of appropriate management procedures, it

is generally anticipated that adverse effects on either public or worker health would be minor. In

this respect, Public Health England has recently published a review of the available evidence on

potential public health impacts. While noting that caution is required in extrapolating evidence

from overseas into the UK context, they consider that the potential risks to public health are low

if the operations are properly run and regulated.

Whilst the main text presents the position of PHE as apparently certain, the PHE report contains a

significant qualification of its status on the front cover – “draft for comment”. Arguably it is premature

for DECC's SEA report to quote or cite the PHE study before a final/authoritative version is produced.

However, apart from the “draft for comment” label in the footnote on page 91, the SEA report provides

no qualification to the status of the PHE report, or how that affects its standing.

Public Health England is a new body, created out of the former Health Protection Agency, and with

different powers and responsibilities as a result of the new structure for public health services created

by the Health and Social Care Act 2012. According the recent review of PHE by the Commons Health

82 New Gas Industry Methane Emission Study Is Not Representative Of US Natural Gas Development [Shonkoff 2013]

83 Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction [PHE 2013]

84 Page 90/91, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]


Select Committee85, the work on PHE's unconventional gas study began in 2012 under the banner of

the former Health Protection Agency. As a result of that Committee's investigation, it appears that this

report was given undue priority over other pressing health concerns by the senior management of

PHE86 –

The Committee is concerned that the responses to Committee questions on shale gas extraction

suggest that PHE has not yet established prioritised programmes of work which reflect the

objectives of the organisation and have been endorsed by the Board. We believe it was unwise for

PHE to follow through the work on shale gas extraction which had been initiated by the HPA

without first taking care to satisfy itself that this work reflected both the public health priorities of

PHE, and the research quality criteria embraced by the new organisation. The resulting report

did nothing to build public confidence in PHE as the premier guardian of public health in

England.

When I first read the PHE report my immediate action was to check the PHE web site for details of

the consultation exercise – there were none. Then I checked the archived Health Protection Agency

site – again, no information. On 8th November I sent an email to PHE's Chief Executive, querying the

status of the report, its ownership, and asking for details of the consultation exercise. I received a

response to that email on the 6th December stating –

Please note that in light of our delayed response to your enquiry, we would be happy to extend

the comment period (detailed below) to receive any additional peer reviewed or published

reports in the scientific literature that are relevant to the scope, findings and recommendations of

the report... This report was published as a draft ‘for comment’ for one month, from the 31

October to 29 November 2013.

Although it was helpful to extend the period for comment, the email did not answer the question as

to the absence of a formal, publicly advertised consultation exercise on the content of the report. In

fact, neither Reuters87, the Telegraph88, the BBC89 nor New Scientist90 noted the “draft for comment”

aspect as part of their coverage of the report (the BBC called it a “new official report”), and all

appeared to describe it as if it were a final statement on the issue of shale gas and health.

That the report was passed off as an authoritative statement is one thing. The greater problem here

is that the consultation exercise carried out by PHE was itself a paper exercise. What the “comment”

aspect of the “draft” required was examples of further research into unconventional gas and public

health. The report itself contains no explicit instructions with regard to any consultation process;

except that is for the text at the top of section 13 ('Addendum') which stated –

PHE has continued to assess the scientific evidence on the potential public health impacts of

exposures to chemical and radiological pollutants associated with shale gas extraction, the

85 Health Select Committee: Eighth Report, 2013/14 – Public Health England, HC840, 4th February 2014. http://www.publications.parliament.uk/pa/cm201314/cmselect/cmhealth/840/840.pdf

86 Paragraph 30, page 16, ibid.

87 Shale gas fracking a low risk to public health - UK review, Kate Kelland, Reuters London, Thu 31st October 2013. http://uk.reuters.com/article/2013/10/31/uk-britain-health-fracking-idUKBRE99U0KK20131031

88 Fracking 'low' threat to public health, Nick Collins, Telegraph On-line, 31st October 2013. http://www.telegraph. co.uk/health/healthnews/10418199/Fracking-low-threat-to-public-health.html

89 'Low health risk' from fracking, says UK agency, David Shukman, BBC News, 31st October 2013. http://www.bbc.co.uk/news/science-environment-24761980

90 UK fracking should not threaten public health, Michael Marshall, New Scientist, 5th November 2013. http://www. newscientist.com/article/dn24527-uk-fracking-should-not-threaten-public-health.html


http://www.newscientist.com/article/dn24527-uk-fracking-should-not-threaten-public-health.html

http://www.newscientist.com/article/dn24527-uk-fracking-should-not-threaten-public-health.html

http://www.bbc.co.uk/news/science-environment-24761980

http://www.telegraph.co.uk/health/healthnews/10418199/Fracking-low-threat-to-public-health.html

http://www.telegraph.co.uk/health/healthnews/10418199/Fracking-low-threat-to-public-health.html

http://uk.reuters.com/article/2013/10/31/uk-britain-health-fracking-idUKBRE99U0KK20131031

http://uk.reuters.com/article/2013/10/31/uk-britain-health-fracking-idUKBRE99U0KK20131031

http://www.publications.parliament.uk/pa/cm201314/cmselect/cmhealth/840/840.pdf

references below have been reviewed and are not considered to affect the conclusions of the draft

report. PHE invites submission of additional relevant articles from the scientific literature for

consideration if these have not been considered in the report or identified below.

The rest of section 13 then lists many of the latest research papers in the field of public health and

unconventional gas production which existed in journals at that time. To argue that these 50 papers –

without any detailed explanation or analysis – did not have a bearing on the outcome of PHE's study

not only offends the transparency principles which they are required to adopt in formulating public

policy. It also casts doubt (together with the facts of the 'undue priority' highlighted by the Health

Committee's investigation) upon the objectives of their review, and its purposes.

The PHE reports central claim91 –

Although shale gas extraction and related activities have the potential to cause pollution to air,

land and water, the currently available evidence indicates that the potential risks to public health

from exposure to the emissions associated with shale gas extraction are low if the operations are

properly run and regulated. Most evidence suggests that contamination of groundwater as a

result of borehole leakage is an area of concern, but that contamination of groundwater from the

underground fracking process itself is unlikely.

– cannot be substantiated given the available evidence on the many issues related to

unconventional gas development; from well leakage and fugitive emissions, to the observed

concentrations of airborne pollutants and health impacts noted within many studies. In that respect, it

is worth laying the conclusions of the PHE study alongside the work of:

• the 2012 report of the Chief Medical Officer of Health, New Brunswick Department of Health92;

• the 2013 report by the Department of Health, Queensland Government93;

• the 2013 article by McDermott-Levy in the American Journal of Nursing94;

• the 2014 paper by Colborn published in Human and Ecological Risk Assessment95;

• the 2014 paper by Adgate published in Science of the Total Environment96;

• the 2014 article by Coram in the Medical Journal of Australia97;

• the 2014 paper by Litovitz in Environmental Research Letters98;

• the 2014 paper by Moore in Science of the Total Environment99;

• the 2014 paper by Tait published in Environmental Science and Technology100;

• the 2014 paper by Bunch published in Science of the Total Environment101; and

• in addition to the above updates, see the papers listed in PHE's “none of the below” list in section13 of their report – many of which are available from the Free Range On-line Library.102.

91 Summary, page 32, Review of the Potential Public Health Impacts of Exposures as a Result of Shale Gas [PHE 2013]

92 CMO of Health's Recommendations Concerning Shale Gas Development in New Brunswick [New Brunswick 2012]

93 Coal seam gas in the Tara region: Summary risk assessment of health complaints [Queensland 2013]

94 Fracking, the Environment, and Health: New energy practices may threaten public health [AJN 2013]

95 An Exploratory Study of Air Quality near Natural Gas Operations [Colborn 2014]

96 Potential Public Health Hazards, Exposures and Health Effects from Unconventional NG Development [Adgate 2014]

97 Harms unknown: health uncertainties cast doubt on the role of UG in Australia's energy future [Coram 2014]

98 Estimation of regional air-quality damages from Marcellus Shale natural gas extraction in Pennsylvania [Litovitz 2013]

99 Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical Review [Moore 2014]

100 Enrichment of Radon and Carbon Dioxide in the Open Atmosphere of an Australian Coal Seam Gas Field [Tait 2014]

101 Evaluation of impact of shale gas operations in the Barnett Shale region on volatile organic compounds in air and potential human health risks [Bunch 2014]

102 Free Range On-line Library: 'Extreme Energy'. http://www.fraw.org.uk/library/extreme.html


http://www.fraw.org.uk/library/extreme.html

Note that not all the above papers are “against” shale gas – some cast doubt, or do not find a

conclusive result. But that's the critical point; currently the evidence does not exist to provide an all-

conclusive statement either way: that “potential risks are low”, as PHE state; or that “shale gas is

inherently harmful”, which many opponents state. With regard to that continuum of uncertainty, the

Chief Medical Officer of New Brunswick's report is far more balanced that the report by PHE.

At the same time, without the kind of additional monitoring/sampling which many of the above

papers call for in order to better define the parameters of such a conclusion, there is not sufficient

evidence to demonstrate an unequivocal link to health impacts. In that context the approach of the

Mackay-Stone report – that they clearly state an “assumption” of equivalence between conventional

and unconventional gas production – is a more honest appraisal than the opaque dismissal of

hazards within PHE's report.

PHE's report on the health impacts of unconventional gas is arguably biased, and is not

transparent between its assessment/collection of information and the inferences/conclusions

which it draws. Their unpublicised consultation exercise on the report is also highly suspect –

given it was merely a call for papers rather than analysis. Looking at the body of evidence

which exists at present, not enough information exists to support PHE's claim that “potential

risks are low” – nor to demonstrate the opposite conclusion either. Without the kinds of

extensive sampling/health monitoring identified by many of the recent reports cited here, and

rejected by PHE's report, such a categorical conclusion cannot be made.


4. Over-riding legal and procedural flaws in the SEA analysis

In this final section I make what can best be viewed as “matters of submission” – observations on

the legal and procedural conduct of the compilation of the SEA report, and the consultation exercise.

4A. The assessment of alternatives

The SEA report outlines a series of alternative proposals in order to mitigate impacts from on-shore

oil and gas production103. However, these “alternatives” represent alternative strategies for awarding

oil and gas licences – not alternative methods of oil or gas production.

Article 5(1) of the SEA Directive states104 –

Where an environmental assessment is required under Article 3(1), an environmental report shall

be prepared in which the likely significant effects on the environment of implementing the plan or

programme, and reasonable alternatives taking into account the objectives and the geographical

scope of the plan or programme, are identified, described and evaluated.

The operative term in this paragraph is, “likely significant effects on the environment” – and

therefore the assessment of alternatives must also consider differing environmental effects. What the

SEA advocates is varying methods of the same operation – allocating PEDL licences. Whilst this will

cause differing environmental effects, it does not represent an “alternative”, merely a gradation of

impacts from the same process.

In formulating policy under SEA, it is necessary to consider alternatives which meet the same ends.

The purpose of the Government's policy is not the issuing of “paper licences”, it is the production of oil

and gas energy sources. Therefore the assessment of alternatives should have considered alternative

sources of oil and gas, not differing levels of licence allocation. For example, the production of

fossil/unconventional oil and gas could be assessed alongside the production of biofuels or biogas,

the off-setting of the demand for oil/gaseous fuels using conservation measures to reduce demand, or

transitioning demand into electricity.

The assessment of alternatives within the SEA is questionable because it represents an

iteration of the same process – the issuing of oil and gas licences – rather than a true

exploration of alternative options – exploring differing methods/technologies which meet the

same objectives with a different impact upon the environment. Arguably the SEA report fails to

meet the terms of the SEA Directive.

4B. The precautionary principle

The first paragraph of the preamble to the SEA Directive specifies –

...the Treaty provides that Community policy on the environment is to contribute to, inter alia, the

preservation, protection and improvement of the quality of the environment, the protection of

human health and the prudent and rational utilisation of natural resources and that it is to be

based on the precautionary principle.

103 Section 2.6, page 31, 'Environmental Report', SEA for Further Onshore Oil and Gas Licensing [DECC 2013A]

104 Article 5, [Directive 2001/42/EC]


For some time it has been arguable as to the exercisability of the precautionary principle directly

within UK law. However, in this case the Directive mandates the application of the precautionary

principle in the preamble. Furthermore, as part of the harmonisation of European environmental and

planning policy, Article 191 of the Treaty of Lisbon/the Treaty on the Functioning of the European

Union (which post-dates the introduction of the Directive) modifies these objectives slightly –

Union policy on the environment shall aim at a high level of protection taking into account the

diversity of situations in the various regions of the Union. It shall be based on the precautionary

principle and on the principles that preventive action should be taken, that environmental

damage should as a priority be rectified at source and that the polluter should pay.

For a working definition of the precautionary principle we could take the definitions outlined in the

UK Sustainable Development Strategy105 –

In dealing with outputs of human activity which may have an impact on natural resources (e.g.

emissions, waste, chemicals, GMOs), we are... integrating the precautionary principle –

minimising the risk of harmful releases to the environment through better knowledge of potential

impacts and better management.

In this case, the policy expressed later in that report is also applicable106 –

There are, however, still instances where decisions on managing natural resources will have to be

taken on the basis of partial information. In these instances, and where, firstly, there is a risk of

significant adverse environmental effects occurring and secondly, any possible mitigation

measures seem unlikely to safeguard against these effects, the precautionary principle will be

adopted.

The first stage in the application of the precautionary principle is the acceptance that uncertainty

exists; the characterisation of uncertainty – which is arguably a more practical aspect of “science”

than the statement of what is certain – then follows on from this acceptance. In my view the SEA

report seeks to deny that any uncertainty exists, and therefore blindly adopts measures which fit that

viewpoint rather than opening up the analysis to decide the scope and impact of those uncertain

outcomes.

In this case of the 14th On-shore Oil and Gas Licensing round SEA, it is arguable that:

The SEA report does not apply the precautionary principle effectively, because it fails to identify

the uncertain with regard to the exploration and production of oil and gas, and identify criteria

which enable the risks involved to be assessed. For example, the statements that certain details

over environmental impacts might be left to the planning system, when arguably local planning

authorities are procedurally barred to considering them (see section 2F), represents an

inadequate attempt to satisfy the precautionary principle because it increases uncertainty.

There are great uncertainties as to the availability, and future economic viability of finite

resources – both in terms of liquid fossil fuels but also non-renewable resources generally – as

we arguably move towards 'the ecological limits to growth' (see section 3A). This could arguably

have catastrophic consequences in the near-term for the global economy. Therefore, the current

105 Developing our vision for natural resources, page 99, Securing The Future: Delivering UK Sustainable Development Strategy, Cm6467, March 2005. https://www.gov.uk/government/uploads/system/uploads/system/uploads/attachment_data/file/69412/pb10589-securing-the-future-050307.pdf

106 Page 101, ibid.


https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69412/pb10589-securing-the-future-050307.pdf

https://www.gov.uk/government/uploads/system/uploads/

government policy of seeking the ongoing maintenance and growth in fossil fuel supply, while at

the same time rolling back measures which might move us towards lowering consumption and

securing renewable energy sources – in the context of the SEA process for this policy objective

of producing more oil and gas – represents a failure to enact the precautionary principle.

The growing body of evidence of the existence of known/quantifiable flaws in oil and gas

production wells (see section 3B) represents another example where the approach of the SEA

report derogates from, and thus fails to enact the precautionary principle.

The use of the Mackay & Stone report to make certain arguments in relation to climate change

and fugitive emissions is another example of failure to consider uncertainty (see section 3C) –

since the arguments used in that report are based upon assumptions which fit the requirements

of policy, not objectively quantified risks. Furthermore, the reliance of that report upon

unrepresentative studies, to argue the case for the equivalence of conventional and

unconventional gas production, represents a spurious argument – since it seeks to advance

certainty where no such certainty can be demonstrated. Note also that the general mitigation

point made in the Mackay & Stone report107 – that “the potential increase in cumulative

emissions could be counteracted if equivalent and additional emissions-reduction measures are

made somewhere in the world” – could be interpreted as contrary to the position expressed in

Article 191 of the Treaty on the Functioning of the European Union – “that environmental damage

should as a priority be rectified at source”.

Finally, the Public Health England report on unconventional gas advocates a position108 that the

“potential risks are low”, when in fact there is currently a very high degree of uncertainty as to the

nature and extent of the health impacts from unconventional oil and gas production. At the same

time it seeks to dismiss a large body of evidence on the existence of uncertainties by listing a

large number of these studies as being irrelevant to the conclusions of the report. Therefore it

makes absolutely no attempt to consider the precautionary approach in defiance – in the context

of its application within the SEA process – of Community law on the precautionary principle.

There are a number of grounds upon which the SEA report could be claimed to breach or

inadequately enact the requirements of Community law to apply the precautionary principle. In

that respect the whole SEA process is void – and should be restarted from the beginning. As

part of that review the SEA framework must properly be applied, so that environmental

protection flows from the policy, rather than the need to meet environmental objectives being

retroactively applied to policy afterwards.

4C. Decision-making bias and likely malfeasance in public office

The human species is arguably approaching a tipping point. Not just in relations to the “headline”

environmental issues such as climate change – but across a number of less well publicised ecological

and economic factors which are combining to make the future survival of human society as we know it

untenable. If we look at the evidence which exists today – from agriculture, to economics, to energy

policy, to ecotoxicology, and overarching all of these the ecological overshoot of the human system –


108 Summary, page 32, Review of the Potential Public Health Impacts of Exposures as a Result of Shale Gas [PHE 2013]


we have sufficient knowledge of the factors involved, if not total certainty, to question the rationality of

many currently totemic policies with the contemporary conception of the “Western lifestyle”.

This in turn raises a question in the mind of many who are aware of these trends – why is the

political system incapable of action?

There comes a point where, as citizens, we have to ask whether our political system has the

capacity to adapt and change, and to address itself to these foreseeable challenges; or whether this

inaction is self-perpetuating because our political process has become so compromised by interests

which seek to enact policies which exacerbate our objective ecological situation.

This issue comes to a head with the issue of oil and gas development – because so many elements

of our political processes are directly influenced by the fossil fuel lobby. For example:

Consider the Prime Minister's special adviser (SPAD) on energy –

• David Cameron's first energy SPAD was Ben Moxham, who had been a vice president

of Riverstone, the energy finance company which bought out a large potion of Cuadrilla,

Britain's leading “fracking” company.

• In May 2013, Ben Moxham was succeeded by Tara Singh, a lobbyist with Centrica,

who, shortly after her appointment, in addition to their other unconventional gas

interests, also took a financial stake in Cuadrilla.

• Therefore must we assume that one of the requirements of being the Prime Ministers

special adviser on energy requires that the person's corporate alma mater must have a

stake in Britain's leading fracking company?

We might also consider Lynton Crosby, the Prime Minister's principal special adviser –

• Lynton Crosby was a founding member of the Australian public relations agency Crosby

Textor.

• Crosby Textor represent various fossil fuel interests, including the Australian Petroleum

Production and Exploration Association, APPEA.

• An APPEA member with interests in unconventional gas in Britain is Dart Energy,

Britain's “no.2” fracking company.

Next let us consider The Chancellor –

• George Osborne's father-in-law is Lord Howell, former energy minister in the Thatcher

government, recently retired minister at the Foreign Office where he promoted British

energy interests around the globe and wrote William Hague's speeches, but more

importantly, has extensive links to all sectors of the energy industry through his

presidency of the British Institute for Energy Economics and connections with other

energy policy interests.

• Over the course of this Parliament the Chancellor has become more directly involved in

energy policy, giving greater tax breaks to fossil fuel companies while trying to reduce

support for other competing sources of energy or energy efficiency programmes.

• In April 2011, renewable energy minister Nick Boles was removed from his position

because his brother had a job with Siemens, a large multinational engineering and

construction company who have interests in wind farm contracts, and this was

perceived to be a conflict of interest.

• Therefore are we to assume that, when you are Chancellor, your links to the largest


fossil fuel interests in the energy sector via your father-in-law, and to whom you are

giving major financial assistance through tax reliefs and regulatory reforms, and upon

whose behalf you are lobbying for changes in law and policy, are above reproach; but

that a connection via your brother to minor group within a much larger engineering and

construction corporation is not acceptable?

Next let's consider Lord Browne, non-executive minister at the Cabinet Office –

• Lord Browne is a managing director at Riverstone, Ben Moxham's former employer,

who still have a major stake in Cuadrilla as well as other global energy interests.

• Lord Browne is also the Chairman of Cuadrilla.

• It was recently revealed that environment minister Owen Paterson organised meeting

between Lord Browne, chair of the Environment Agency Chris Smith, and other fracking

interests in order to set up new regulatory agreements relating to the future roll-out of

unconventional gas developments in England.

• Therefore are we to assume, even where a direct conflict of interest is vested in a single

person who can magically change his identity within the corridors of power, that this

does not represent an unacceptable conflict of interest?

To demonstrate that this trend extends outside of the core of politics, I could also note that my

own local MP, Tony Baldry, is deputy chair of an oil investment company, Woburn Energy.

Finally, so as not to be party political about this, it should be pointed out that all three major

parties receive funding from leading energy interests, LibDem business minister Vince Cable

was once the senior economist at Shell (and has reputedly been called the contact minister

for Shell).

There is, arguably, a legal term which I believe encompasses the natire of these relationships...

malfeasance or misconduct in a public office.

These offences are based around the making of irrational decisions due to inducements or

deference whilst in a public position which, objectively on the basis of available evidence, could not be

made by the “average person”.

There is a fundamental principle of international law – enacted through the European Convention

on Human Rights, the various Treaties of the European Union, but in large part already running

through the British legal tradition since we were histrionically involved in the drafting many of the

world's international laws and treaties – which underpins all justice procedures; the right to a fair and

impartial tribunal. Due to the levels of corporate influence across all political parties, and increasingly

across major parts of out media and culture, it is arguable that the public's access to a fair and

impartial tribunal in relation to the Government's quasi-judicial responsibilities for policy-making are

being diminished by these conflicts of interests, and by the larger system of corporate inducements to

political parties.

This is a serious matter, but in my view this has little to do with the alleged “corrupt practices” of the

political class which are often trawled through the media. As I see it this is solely a matter of whether

or not the decisions of ministers, due to the influences upon them, are unreasonable to a degree

which might be considered unlawful. But over and above this, we must question whether the high-

level access to decision-makers given to the energy lobby by the present Government literally

obstructs – as part of the strategic environmental appraisal process – our general rights to a fair and


impartial tribunal.

The reason this issue has come to a head with the SEA process is because of the role this

mechanism has in European law. The SEA Directive, alongside recent revisions to the guiding

legislation of the European Union, enacts the Aarhus Convention on the rights to information and

access to decision-making on environmental matters through the SEA process. That is why the

Government are required to consult, and demonstrate that they have done so, from the beginning of

the process.

The current deference of ministers to energy interests over the unconventional gas issue –

demonstrated through both their behind-closed-doors links and by the woefully inadequate way in

which the SEA report deals with the impacts of oil and gas development – arguably infringes our right

to due process, and to a fair and impartial hearing, via the SEA Directive and European law.

The over-bearing influence of the fossil fuel energy lobby within the UK Government raises

the question as to whether ministers, in discharging their quasi-judicial functions as part of

the SEA process, can fairly and impartially decide upon the evidence provided by the SEA

report, and any criticisms of that case supplied as part of the SEA consultation process. As a

specific objection, I raise this question as a criticism of the SEA report, and of the processes

which gave rise to that report, including the preparation of other related reports such as those

from PHE or Mackay & Stone. Therefore, in determining the outcome of this consultation

process, I raise specific questions as to whether:

The influence of the energy lobby upon ministers will lead to a perverse interpretation

of the requirements of SEA law, and therefore to a flawed and unreasonable decision on

the substance of the SEA's information report;

The flawed nature of this decision-making process might be considered so

unreasonable that it represents, to a potentially criminal level, malfeasance or

misconduct in a public office by those involved in the recent evolution of the UK's

policy on unconventional gas; and

Over and above any UK national legal statutes on unreasonableness, whether the

undue influence of energy interests within the UK Government obstructs the ability of

responsible minister to provide, in accordance with EU law on strategic environmental

appraisal –

• a fair and impartial assessment of the impact of UK Government policy upon the

environment;

• the means to work towards sustainable development, apply the precautionary

principle in decision-making, and to ensure that the environment and human

health are protected, both under the SEA Directive and the over-arching

framework of European law.

The above failings challenge the competency of UK ministers to make decisions over critical

environmental policy matters, and whether the EU must take action against the UK

government to secure guarantees of appropriate action in order to fairly and impartially enact

EU environmental law.


5. Conclusions and recommended actions

Due to the nature of the complaints raise in this report, I am doubtful as to whether the responsible

ministers are capable of making an objectively informed and impartial decision upon the content of the

SEA report, and the objections of the public to that report.

If we follow UK tradition, then I would envisage that the only way we might arrive at a balanced

outcome would be to suspend all further oil and gas licensing activities on-shore, and then hold a

Royal Commission – with appropriate technical assessors to advise the chair, and where all

representative groups (for and against) might put their case in front of a demonstrably fair and

impartial tribunal.

That is my only straightforward, consensus-based suggestion for resolving this issue. The

alternative, as I see it, would be for the EU to take action for an arguable breach of EU law.

Taking all these points together, it is my view that the Government's policies on energy and the

environment are based upon an ideologically-driven view, given expression through a set of flawed

political and economic objectives. That ideological viewpoint is influenced and materially supported by

those who have a vested interest in it.

If we take a more objective and rational view of the available research data – not just on oil and gas

development but on the wider issue of human ecological viability – it is clear that these policies not

only fail to shift development towards a more sustainable basis, but also hasten the acceleration

towards an ecological collapse. That is not a certain outcome; there are large uncertainties. But it is

these very uncertainties that policies such as the precautionary principle have been devised so that

we might work towards a higher probability of achieving long-term sustainability.

There are many recent research studies which highlight the issue of our ecological

sustainability. In this report I have outlined why I view the Government's current energy policy

for on-shore oil and gas as flawed. If members of the Government proceed with these policies

after having conducted this consultation – without any attempt to address the deficiencies

within the SEA information report and its associated documents – then in my view that would

constitute criminal malfeasance; and I believe that those responsible should be made

personally liable for their actions in the promotion of this policy initiative.


6. Background reports/references

ABC 2013 GAS LEAK!, Matthew Carney and Connie Agius, 'Four Corners', ABC TV

(Australia), 1st April 2013. http://www.abc.net.au/4corners/stories/2013/04/01/3725150.htm

Adgate 2014 Potential Public Health Hazards, Exposures and Health Effects from

Unconventional Natural Gas Development, John L. Adgate, Bernard D. Goldstein,

Lisa M. McKenzie, Science of the Total Environment (undated preprint), March

2014http://www.fraw.org.uk/files/extreme/adgate_2014.pdf

AJN 2013 Fracking, the Environment, and Health: New energy practices may threaten public

health, Ruth McDermott-Levy, Nina Kaktins, Barbara Sattler, American Journal of

Nursing, vol.113 no.6 pp.45-51, June 2013. http://www.fraw.org.uk/files/extreme/ajn_2013.pdf

Allen 2013 Measurements of methane emissions at natural gas production sites in the United

States, David T. Allen, Vincent M. Torres, James Thomas, David W. Sullivan,

Matthew Harrison, Al Hendler, Scott C. Herndon, Charles E. Kolb, Matthew P.

Fraser, A. Daniel Hill, Brian K. Lamb, Jennifer Miskimins, Robert F. Sawyer, John

H. Seinfeld, PNAS, 16th September 2013. http://www.fraw.org.uk/files/extreme/allen_2013.pdf

BGS 2012A The Unconventional Hydrocarbon Resources Of Britain's Onshore Basins –

Coalbed Methane (CBM), BGS/Department for Energy and Climate Change,

December 2012.http://www.fraw.org.uk/files/extreme/decc_cbm_2012.pdf

BGS 2012B The Unconventional Hydrocarbon Resources of Britain's Onshore Basins – Shale

Gas, BGS/Department for Energy and Climate Change, December 2012. http://www.fraw.org.uk/files/extreme/decc_shale_2012.pdf

BGS 2013 Can New Technologies be Used to Exploit the Coal Resources in the Yorkshire-

Nottinghamshire Coalfield?, S. Holloway, N.S. Jones, D.P. Creedy, K. Garner,

British Geological Survey/Wardell Armstrong, April 2013.http://www.fraw.org.uk/files/extreme/holloway_2013.pdf

Brufatto 2003 From Mud to Cement – Building Gas Wells, Claudio Brufatto et. al., Oilfield Review,

vol.15 no.3 pp.62-76, 2003. http://www.fraw.org.uk/files/extreme/brufatto_2003.pdf

Bunch 2014 Evaluation of impact of shale gas operations in the Barnett Shale region on volatile

organic compounds in air and potential human health risks, A.G. Bunch, C.S. Perry,

L. Abraham, D.S. Wikoff, J.A. Tachovsky, J.G. Hixon, J.D. Urban, M.A. Harris, L.C.

Haws, Science of the Total Environment, 468-469 pp.832–842, January 2014http://www.fraw.org.uk/files/extreme/bunch_perry_2014.pdf

CHA 2013 Submission to the NSW Chief Scientist and Engineer – Review of coal seam gas

activities in NSW, Climate and Health Alliance, April 2013.http://www.fraw.org.uk/files/extreme/cha_2013.pdf

Colborn 2014 An Exploratory Study of Air Quality near Natural Gas Operations, Theo Colborn,

Kim Schultz, Lucille Herrick, Carol Kwiatkowski, Human and Ecological Risk

Assessment, vol.20 no.1 pp.86-105, January 2014http://www.fraw.org.uk/files/extreme/colborn_2014.pdf


http://www.fraw.org.uk/files/extreme/colborn_2014.pdf

http://www.fraw.org.uk/files/extreme/cha_2013.pdf

http://www.fraw.org.uk/files/extreme/bunch_perry_2014.pdf

http://www.fraw.org.uk/files/extreme/brufatto_2003.pdf

http://www.fraw.org.uk/files/extreme/holloway_2013.pdf

http://www.fraw.org.uk/files/extreme/decc_shale_2012.pdf

http://www.fraw.org.uk/files/extreme/decc_cbm_2012.pdf

http://www.fraw.org.uk/files/extreme/allen_2013.pdf

http://www.fraw.org.uk/files/extreme/ajn_2013.pdf

http://www.fraw.org.uk/files/extreme/adgate_2014.pdf

http://www.abc.net.au/4corners/stories/2013/04/01/3725150.htm

Coram 2014 Harms unknown: health uncertainties cast doubt on the role of unconventional gas

in Australia's energy future, Alicia Coram, Jeremy Moss, Grant Blashki, Medical

Journal of Australia, vol.200 no.4 pp.210-213, 3rd March 2014.http://www.fraw.org.uk/files/extreme/coram_2014.pdf

CSIRO 2008 A Comparison Of The Limits To Growth With Thirty Years Of Reality, Graham

Turner, CSIRO, June 2008. http://www.fraw.org.uk/files/limits/csiro_2008.pdf

Czech 2013 Ecological Economics Comes of Age, Brian Czech, chapter 6, Supply Shock:

Economic Growth at the Crossroads and the Steady State Solution, May 2013. http://www.fraw.org.uk/files/peakoil/czech_2013.pdf

Davies 2014 Oil and gas wells and their integrity: Implications for shale and unconventional

resource exploitation, Richard J. Davies et. al., Marine and Petroleum Geology

(preprint), March 2014. http://www.fraw.org.uk/files/extreme/davies_2014.pdf

DECC 2013A Environmental report for further onshore oil and gas licensing, Department of

Energy & Climate Change, 17th December 2013.https://www.gov.uk/government/consultations/environmental-report-

for-further-onshore-oil-and-gas-licensing

DECC 2013B Potential Greenhouse Gas Emissions Associated with Shale Gas Extraction and

Use, David J.C, MacKay, Timothy J. Stone, Department of Energy and Climate

Change, 9th September 2013. http://www.fraw.org.uk/files/extreme/decc_2013-2.pdf

DEFRA 2013 National Policy Statement for Hazardous Waste: A framework document for

planning decisions on nationally significant hazardous waste infrastructure,

DEFRA, June 2013https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/205568/pb13927-hazardous-waste-policy-20130606.pdf

de Rijke 2013 The Agri-Gas Fields of Australia: Black Soil, Food, and Unconventional Gas, Kim

de Rijke, Culture, Agriculture, Food and Environment, vol.35 no.1 pp.41-53, June

2013. http://www.fraw.org.uk/files/extreme/de_rijke_2013-3.pdf

Directive 2001/42/EC The Assessment of the Effects of Certain Plans and Programmes on the

Environment, European Parliament and Council, 27th June 2001.http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001L0042

EEA 2014 Air pollution by ozone across Europe during summer 2013, EEA Technical report ,

No 3/2014 , European Environment Agency, March 2014.http://www.eea.europa.eu/publications/air-pollution-by-ozone-across-1/at_download/file

Hall 2006 The Need for a New, Biophysical-Based Paradigm in Economics for the Second

Half of the Age of Oil, Charles A.S. Hall, Kent A. Klitgaard, International Journal of

Transdisciplinary Research, vol.1 no.1 pp.4-22, 2006. http://www.fraw.org.uk/files/peakoil/hall_klitgaard_2006.pdf

Howarth 2011 Methane and the greenhouse-gas footprint of natural gas from shale formations,

Robert W. Howarth, Renee Santoro, Anthony Ingraffea, Climatic Change, vol.106

no.4 pp.679-690, June 2011. http://www.fraw.org.uk/files/extreme/howarth_2011.pdf

Howarth 2012 Venting and Leaking of Methane from Shale Gas Development: Response to


http://www.fraw.org.uk/files/extreme/howarth_2011.pdf

http://www.fraw.org.uk/files/peakoil/hall_klitgaard_2006.pdf

http://www.eea.europa.eu/publications/air-pollution-by-ozone-across-1/at_download/file

http://www.eea.europa.eu/publications/air-pollution-by-ozone-across-1/at_download/file

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001L0042

http://www.fraw.org.uk/files/extreme/de_rijke_2013-3.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/205568/pb13927-hazardous-waste-policy-20130606.pdf

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/205568/pb13927-hazardous-waste-policy-20130606.pdf

http://www.fraw.org.uk/files/extreme/decc_2013-2.pdf

https://www.gov.uk/government/consultations/environmental-report-for-further-onshore-oil-and-gas-licensing

https://www.gov.uk/government/consultations/environmental-report-for-further-onshore-oil-and-gas-licensing

http://www.fraw.org.uk/files/extreme/davies_2014.pdf

http://www.fraw.org.uk/files/peakoil/czech_2013.pdf

http://www.fraw.org.uk/files/limits/csiro_2008.pdf

http://www.fraw.org.uk/files/extreme/coram_2014.pdf

Cathles et al., Robert W. Howarth, Renee Santoro, Anthony Ingraffea, Climatic

Change, vol.113 no.2 pp.537-549, July 2012. http://www.fraw.org.uk/files/extreme/howarth_2012.pdf

Hughes 2013 A reality check on the shale revolution, J. David Hughes, Nature, vol.494 pp.307-

308, 21st February 2013. http://www.fraw.org.uk/files/extreme/hughes_2013.pdf

Ingraffea 2013 Fluid Migration Mechanisms Due To Faulty Well Design And/Or Construction: An

Overview And Recent Experiences In The Pennsylvania Marcellus Play, Anthony

R. Ingraffea, Physicians Scientists & Engineers for Healthy Energy, January 2013. http://www.fraw.org.uk/files/extreme/ingraffea_2013.pdf

Jackson 2013 Increased stray gas abundance in a subset of drinking water wells near Marcellus

shale gas extraction, Robert B. Jackson, Avner Vengosh, Thomas H. Darrah,

Nathaniel R. Warner, Adrian Down, Robert J. Poreda, Stephen G. Osborn,

Kaiguang Zhaoa, Jonathan D. Karr, PNAS, vol.110 no.28 pp.11250-11255, 24th

June 2013. http://www.fraw.org.uk/files/extreme/jackson_2013.pdf

Karion 2013 Methane emissions estimate from airborne measurements over a western United

States natural gas field, Anna Karion, Colm Sweeney, Gabrielle Pétron, Gregory

Frost, R. Michael Hardesty, Jonathan Kofler, Ben R. Miller, Tim Newberger, Sonja

Wolter, Robert Banta, Alan Brewer, Ed Dlugokencky, Patricia Lang, Stephen A.

Montzka, Russell Schnell, Pieter Tans, Michael Trainer, Robert Zamora, Stephen

Conley, Ceres, 27th August 2013. http://www.fraw.org.uk/files/extreme/karion_2013.pdf

Kerschner 2013 Economic vulnerability to Peak Oil, Christian Kerschner, Christina Prell, Kuishuang

Feng, Klaus Hubacek, Global Environmental Change, October 2013. http://www.fraw.org.uk/files/peakoil/kerschner_2013.pdf

Litovitz 2013 Estimation of regional air-quality damages from Marcellus Shale natural gas

extraction in Pennsylvania, Aviva Litovitz, Aimee Curtright, Shmuel Abramzon,

Nicholas Burger, Constantine Samaras, Environmental Research Letters, vol.8,

13th January 2013.http://www.fraw.org.uk/files/extreme/litovitz_2013.pdf

McCarron 2013 Symptomatology of a gas field: An independent health survey in the Tara rural

residential estates and environs, Geralyn McCarron, April 2013.http://www.fraw.org.uk/files/extreme/mccarron_2013.pdf

Moore 2014 Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical

Review, Christopher W. Moore, Barbara Zielinska, Gabrielle Pétron, Robert B.

Jackson, Science of the Total Environment (undated preprint), March 2014.http://www.fraw.org.uk/files/extreme/moore_2014.pdf

Murray-King 2013 Oil's Tipping Point has Passed, James Murray, David King, Nature, vol.481 pp.433-

435, 26th January 2012. http://www.fraw.org.uk/files/peakoil/murray_king_2012.pdf

New Brunswick 2012 Chief Medical Officer of Health's Recommendations Concerning Shale Gas

Development in New Brunswick, Office of the Chief Medical Officer of Health, New

Brunswick Department of Health, September 2012. http://www.fraw.org.uk/files/extreme/new_brunswick_2012.pdf

NTN 2011 Hydraulic Fracturing in Coal Seam Gas Mining: The Risks to Our Health,

Communities, Environment and Climate, Mariann Lloyd-Smith, Rye Senjen,

National Toxics Network (Australia), September 2013.


http://www.fraw.org.uk/files/extreme/new_brunswick_2012.pdf

http://www.fraw.org.uk/files/peakoil/murray_king_2012.pdf

http://www.fraw.org.uk/files/extreme/moore_2014.pdf

http://www.fraw.org.uk/files/extreme/mccarron_2013.pdf

http://www.fraw.org.uk/files/extreme/litovitz_2013.pdf

http://www.fraw.org.uk/files/peakoil/kerschner_2013.pdf

http://www.fraw.org.uk/files/extreme/karion_2013.pdf

http://www.fraw.org.uk/files/extreme/jackson_2013.pdf

http://www.fraw.org.uk/files/extreme/ingraffea_2013.pdf

http://www.fraw.org.uk/files/extreme/hughes_2013.pdf

http://www.fraw.org.uk/files/extreme/howarth_2012.pdf

http://www.fraw.org.uk/files/extreme/ntn_2011.pdf

PHE 2013 Review of the Potential Public Health Impacts of Exposures to Chemical and

Radioactive Pollutants as a Result of Shale Gas Extraction, A Kibble, T Cabianca,

Z Daraktchieva, T Gooding, J Smithard, G Kowalczyk, N P McColl, M Singh, S

Vardoulakis, R Kamanyire, Centre for Radiation, Chemical and Environmental

Hazards, Public Health England, 30th October 2013. http://www.fraw.org.uk/files/extreme/phe_2013.pdf

Queensland 2013 Coal seam gas in the Tara region: Summary risk assessment of health complaints

and environmental monitoring data, Department of Health, Queensland

Government, March 2013. http://www.fraw.org.uk/files/extreme/queensland_2013.pdf

Santos 2012 Submission on National Greenhouse and Energy Reporting (Measurement)

Determination 2012 – Fugitive Emissions from Coal Seam Gas, Isaac Santos,

Damien Maher, Southern Cross University, 19th October 2012. http://www.fraw.org.uk/files/extreme/santos_maher_2012.pdf

Shonkoff 2013 Gas Industry Study: New Edf And Gas Industry Methane Emission Study Is Not

Representative Of US Natural Gas Development, Not The Promised Definitive

Study, Seth B. Shonkoff, Physicians, Scientists, and Engineers for Healthy Energy,

16th September 2013. http://www.fraw.org.uk/files/extreme/pse_allen_2013.pdf

SPE 2000 Why Oilwells Leak: Cement Behavior and Long-Term Consequences, Maurice B.

Dusseault, Malcolm N. Gray, Pawel A. Nawrocki, Society of Petroleum Engineers

International Oil and Gas Conference, November 2000. http://www.fraw.org.uk/files/extreme/spe_2000.pdf

Tait 2013 Enrichment of Radon and Carbon Dioxide in the Open Atmosphere of an

Australian Coal Seam Gas Field, Douglas R. Tait, Isaac R. Santos, Damien T.

Maher, Tyler J. Cyronak, Rachael J. Davis, Environmental Science and Technology,

vol.47 pp.3099-3104, 27th February 2013.http://www.fraw.org.uk/files/extreme/tait_2013.pdf

UNCED 2013 State of the Planet Declaration, Planet Under Pressure, UNCED, March 2012. http://www.fraw.org.uk/files/limits/pup_sotpd_2012.pdf

USGS 2012 Landscape Consequences of Natural Gas Extraction in Bradford and Washington

Counties, Pennsylvania, 2004-2010, E.T. Slonecker, L.E. Milheim, C.M. Roig-Silva,

A.R. Malizia, D.A. Marr, G.B. Fisher, United States Geological Survey, 2012.

http://www.fraw.org.uk/files/extreme/usgs_2012.pdf


http://www.fraw.org.uk/files/extreme/usgs_2012.pdf

http://www.fraw.org.uk/files/limits/pup_sotpd_2012.pdf

http://www.fraw.org.uk/files/extreme/tait_2013.pdf

http://www.fraw.org.uk/files/extreme/spe_2000.pdf

http://www.fraw.org.uk/files/extreme/pse_allen_2013.pdf

http://www.fraw.org.uk/files/extreme/santos_maher_2012.pdf

http://www.fraw.org.uk/files/extreme/queensland_2013.pdf

http://www.fraw.org.uk/files/extreme/phe_2013.pdf

http://www.fraw.org.uk/files/extreme/ntn_2011.pdf

strategic environmental assessment for further onshore … · “strategic environmental assessment...

Documents