Note: This submission gathers evidence from around the world to make the case against fracking in Nottinghamshire. Obviously the same arguments could be made against shale gas fracking elsewhere.
This is a response for the Nottinghamshire County Council’s Mineral Plan. It is about the potential development of shale gas and coal bed methane production in Nottinghamshire which has major and serious implications for the health and well being of people in Nottinghamshire and Nottingham. In this submission I gather evidence about both coal bed methane development, which is proposed in the north east of the country (the Gainsborough trough) and shale gas development in the south east (Widmerpool trough). Because the two are not quite the same I have tried to put together separate evidence for each.
According to the County Council document “there is no justifiable reason to separate shale gas from other hydrocarbon development”.
This statement appears to imply that shale gas fracking is much the same as the hydrocarbon extraction already going on a very small scale already in the county. This is a profound misconception. Shale gas extraction using fracking – and coal bed methane extraction too – are both much more aggressive techniques and have major implications. There are plenty of “justifiable reasons” and the evidence for those reasons can be found in reports published by or for authoritative agencies like the United Nations Environment Programme and the European Union – not to mention in so many peer reviewed scientific studies and so many newspaper reports from the USA and Australia that it is impossible to dismiss them all.
Thus, when the minerals plan document declares support for all stages of development of any hydrocarbon “provided they do not give rise to any unacceptable impacts on the environment or residential amenity” it should take into account the following well grounded scientific evidence about “impacts”:
(1) Impacts unavoidable. United Nations Environment Programme and EU Reports make the point that many impacts “may be UNAVOIDABLE” even if unconventional gas is extracted properly – more so if the extraction is not done properly. “Even if risk can be reduced theoretically (IEA, 2011), in practice many accidents from leaky or malfunctioning equipment as well as from bad practises are regularly occurring. This may be due to high pressure to lower the costs or to improper staff training, or to undetected leaks leading to contamination of the ground water.” 
This is particularly pertinent to Nottinghamshire because research has shown that the economics of unconventional gas in the UK is at best marginal. Since profitability is likely to be marginal questionable the temptation will be to cut corners. (For evidence on that remark see below). This undermines the argument that merely by adequate regulation things will turn out all right. In any case, as I will show here, the amount of regulation that would be needed will represent a considerable call on resources given the scale of industrialisation of the countryside that gas development would entail.
This would not be an easy industry to regulate. Press reports from the USA shows a huge number of regulatory violations by the shale gas industry. Already by August 2010 there were 1,500 violations in Pennsylvania alone – including 100 violations of the state Clean Stream Law, 268 for improper construction of waste water impoundments; 277 for poor erosion and sedimentation plans during well pad, road and piping construction; 16 for improper blowout prevention; and 154 for discharging industrial waste, including drilling waste water containing toxic chemicals, onto the ground or into streams. 
(2) Scale of Development. A large part of the reason for the difficulty of the regulation would be the sheer scale on which shale gas and coal bed methane sectors work. If going beyond the exploration to the development stage coal bed methane and shale gas developments could lead to a major industrialisation of the landscape.
To take coal bed methane first. For the purposes of comparison there is the St Juan Basin gas field on the New Mexico -Colorado border where the industry pumps 3 billion cubic feet of natural gas every day. To do this requires 3,000 compressors compressing gas from 23,000 wells over 2,160 square miles of land. Nottinghamshire is only 835 square miles altogether and if we assume that about 10% of the county was developed at this industrial intensity then this would mean about nearly 900 wells and an infrastructure of pipes for gas and waste water not to mention 116 compressor stations. Again for comparison, Dart Energy have applied to produce Coal Bed Methane near Airth in Scotland a year ago their eventual aim was for 600 wells – and their initial application was for 14 new sites, 22 new wells and 20 km of pipelines to go with them.
As regards hydraulic fracturing for shale gas it should be pointed out that 8 wells per square mile are common in the US and Australia . In Bradford County in Pennsylvania, in an area 1.45 times the size of Nottinghamshire, 2000 shale gas wells were sunk in a 4 year period . This would translate into over 1,300 gas wells if spread over the whole county – and at least several hundred if shale gas was exploited in the Widmerpool trough area to the south of Nottingham. For comparison 800 shale gas wells are projected for Lancashire.
Just keeping track of a comparable number of installations and pipes would be a heavy regulatory burden which in a time of cuts is likely to be inadequate, with the best will in the world.
(3) Industrialisation of landscape. Many wells will probably require access roads, foundations, floodlights and enclosures. This pattern of development will divide the countryside, threaten rights of way, damage and slowly destroy the natural beauty and diversity of an area. Wildlife corridors and biodiversity are bound to be disrupted. The compressor stations will be a source of noise and light pollution as well as toxic emissions. In the St Juan basin two and a half miles of new road were put in for every square mile of land to facilitate the gas extraction process. In Nottinghamshire there would undoubtably be a massive increase in volume of heavy traffic – for example to remove drilling mud and wastes from sites in tankers and trucks. A single frack for shale gas uses 5-10 Olympic size swimming pools of water – which has to be delivered to the wellhead in tankers. Quite apart of the resulting massive disruption of the quiet life in villages and towns along the development area there would be a big increase in road maintenance and associated costs.
(4) Incompatibility with animal husbandry, agriculture and tourism. According the reports from the USA for the St Juan basin “There’s the constant traffic of water-hauling and maintenance trucks, heavy machinery scraping away at the muddy roads, drilling and fracturing rigs. Animals get hit. They drink from temporary reserve pits, catch basins, and puddles containing the by-products of gas production: methanol, glycol, antifreeze used to defrost transmission pipes .
Peer reviewed research in academic journals, drawing on multiple case studies, shows that that animal and human health suffer. Full knowledge of the impacts is inhibited by incomplete testing and non disclosure of chemicals used plus non disclosure agreements because (in the USA) people have their medical costs and compensation paid in return for not talking – a deeply unethical practice by the companies. However, a study based on interviews with 24 animal owners who live near gas drilling operations published in a journal of environmental and occupational health found multiple serious health problems with farm animals, pets and their owners .
The study concludes: “Documentation of cases in six states strongly implicates exposure to gas drilling operations in serious health effects on humans, companion animals, livestock, horses, and wildlife…. given the many apparent adverse impacts on human and animal health, ban on shale gas drilling is essential for the protection of public health. ” (Note although shale gas is not identical to coal bed methane extraction in practice many of the issues are the same)
(5) Quite apart from toxicity the extraction and use of water could eventually be in competition with local farmers. It should be remembered that it was not that long ago that Nottinghamshire was one of a number of areas whose farmers were affected by drought . The fracking industry removes a large amount of water from the water cycle and turns clean water into polluted water that must be treated and disposed of. In the US, water auctions have had farmers bidding against the oil and gas industry for water. It is not the responsbility of the county council to regulate water – but there are major economic issues if local farmers are unable to access water. The potential problem is clearly there in this statement by Water UK: “where water is in short supply there may not be enough available from public water supplies or the environment to meet the requirements for hydraulic fracturing.” 
(6) Effects on human health. According to the United Nations Environment Programme Report “When occurring in densely populated areas, UG production raises several specific threats to well-being. The most direct concern is the risk of explosion from the construction of new pipelines . Other consequences have a slower onset, such as release of toxic substances into air, soil and water.” It should be remembered that to prepare the way for unconventional gas in the United States, legal protection against water was removed to allow the industry to develop.
A report commissioned for the European Commission gives a summary risk assessment for different phases of the development of the fracking industry. The overall cumulative risk rating across all phases of the development process are listed as follows: High risk – groundwater contamination, surface water contamination, water resources, release to air, land take, risk to biodiversity, noise, traffic. Moderate cumulative risk impact – visual impact. Low cumulative impact – seismicity .
As regards water contamination threats to human health, the experience of coal seam gas in Queensland can be judged by a report in the Syney Morning Herald. It shows that coal seam gas extraction produces carcinogenic water – this is not necessarily because carcinogens have been sent down by the technology but because of the way that water that has been “marinating in the coal seam” over a long time and is brought to the surface by the technology with all the contaminants in it.
“The Queensland government is investigating a gas field west of Brisbane after the discovery of traces of cancer-causing chemicals at five bores. Benzene, toluene and xylene were discovered during routine tests of 14 bores used to monitor the company’s coal seam gas (CSG) dams at the Tipton West and Daandine gas fields near Dalby, Arrow Energy said in a statement on Sunday .
Peer reviewed scientific studies shows that people living hear to unconventional gas wells are at greater risk as a result of air pollution. One preliminary study concludes: “These preliminary results indicate that health effects resulting from air emissions during unconventional NGD warrant further study. Prospective studies should focus on health effects associated with air pollution.” 
Another peer reviewed study found that:
“Methylene chloride, a toxic solvent not reported in products used in drilling or hydraulic fracturing, was detected 73% of the time; several times in high concentrations. A literature search of the health effects of the NMHCs revealed that many had multiple health effects, including 30 that affect the endocrine system, which is susceptible to chemical impacts at very low concentrations, far less than government safety standards. Selected polycyclic aromatic hydrocarbons (PAHs) were at concentrations greater than those at which prenatally exposed children in urban studies had lower developmental and IQ scores. The human and environmental health impacts of the NMHCs, which are ozone precursors, should be examined further given that the natural gas industry is now operating in close proximity to human residences and public lands.” 
(7) Noise. From exploration through site abandonment, noise is generated by truck traffic, heavy equipment, seismic explosions, drilling rigs, motors that power pumps, and gas compressors. There will be constant noise from pumps and compressors with quality of life consuequences for people and negative impacts on livestock and wildlife.
(8) Coal Seam Gas wells leak.A 2010 report by the State of Queensland, Department of Employment, Economic Development and Innovation involved inspecting 58 gas wells in the Tara field developed by British Gas – 26 of 58 were leaking – in one case above the lower explosion limit of methane and in a further 4 cases close to that limit. . 5 cases over or near the lower explosion limit is nearly 9% of cases. Applying that percentage to a possible 900 wells in Nottinghamshire would be 78 wells. What is not generally known is that leaks from gas wells are as old as the industry. Oil services company Schlumberger estimates that up to 60% of gas wells will be leaking within 30 years. 
The UK Society of Petroleum Engineers found 34% of North sea Gas wells have integrity issues . The Federal Environment Protection Agency in the USA found that of 1.2 million oil and gas wells in the USA 200,0000 were not properly plugged and 40,000 – 50,000 wells could cause pollution problems .
The point here is that ALL gas wells leak eventually – and the problems caused by gas wells will still be there a very long time after the industry has moved on – indeed possibly after the companies no longer exist. Even “world class regulation” will not solve this – especially “world class regulation” done with radically reduced staffing.  
This is a YouTube video of a leaking coal seam gas well in Australia:
(10) Greenhouse Gas/Climate Implications. It is sometimes claimed that because natural gas, when burned, gives rise to less CO2 than the combustion of coal, that natural gas is a climate friendlier and this is an argument often put forward by the industry to promote the production of shale gas. The argument neglects the following however – firstly methane is a much more powerful greenhouse gas than CO2 (100 times worse over a 20 year time span) so the existence of fugitive emissions from leaking gas wells and pipelines may make it more greenhouse damaging than coal depending on the rate of leakage. Estimates of typical rates of leakage and the effects vary – according to the US Environmental Protection Agency the average rate of leakage is about 2.4% per annum. Many experts believe it is much more than this. For example, Howarth, Santoro and Ingraffea of Cornell University estimate it at 8% pa . Tom Wigley found that unless leakage rates could be kept below 2% substituting gas for coal is not an effective way of reducing greenhouse gas emissions .
Bang up to date 15 leading US scientists from Harvard, NOAA, and the Lawrence Berkeley National Lab titled “Anthropogenic emissions of methane in the United States.” This is based on “comprehensive atmospheric methane observations, extensive spatial datasets, and a high-resolution atmospheric transport model,” rather than the industry-provided numbers Environmental Protection Agency uses and show that the EPA figures are not accurate. (Could that be because they use figures from the industry one wonders?) Thus, the Proceedings of the National Academy of Sciences study by Scot Miller et al takes the unusual step of explicitly criticizing the EPA: “ The US EPA recently decreased its CH4 emission factors for fossil fuel extraction and processing by 25–30% (for 1990–2011), but we find that CH4 data from across North America instead indicate the need for a larger adjustment of the opposite sign.”
The study found greenhouse gas emissions from “fossil fuel extraction and processing (i.e., oil and/or natural gas) are likely a factor of two or greater than cited in existing studies.” In particular, they concluded, “regional methane emissions due to fossil fuel extraction and processing could be 4.9 ± 2.6 times larger than in EDGAR, the most comprehensive global methane inventory.”
This suggests the methane leakage rate from natural gas production, which EPA recently decreased to about 1.5%, is in fact 3% or higher.
For consideration in Nottinghamshire is the fact that the industry can often have much higher leakage rates in particular places. For example a 2013 study from 19 researchers led by NOAA concluded “measurements show that on one February day in the Uinta Basin, the natural gas field leaked 6 to 12 percent of the methane produced, on average, on February days.” 
Secondly, even if it were the case that gas was more climate friendly than coal it would only be helpful in reducing greenhouse gas emissions sufficiently if gas actually replaced coal and is not used additionally to coal. In the USA increased natural gas production has led to some coal being exported instead of being used domestically – a part of this has been to the UK where low coal prices have led to UK power generators using more coal. The carbon intensity of UK power generation rose last year because of this. Thirdly, to avert a climate catastrophe the International Panel on Climate Change is arguing for a carbon budget to prevent global temperature rises overshooting a 2 degree increase. This means effectively a 6% per annum reduction in emissions for the next few decades. For this speed to be achieved it is not only necessary to radically reduce energy use but to transform the energy system directly over to renewables not to go through some intermediate process via an allegedly slightly more benign fossil fuel. According to research led by the Grantham Research Institute (under the leadership of Lord Nicholas Stern ) “Between 60-80% of coal, oil and gas reserves of publicly listed companies are already ‘unburnable’ if the world is to have a chance of not exceeding global warming of 2°C” .
(11) These “impacts”, as costs should be set against the benefits of the gas extraction process. But what will these benefits be and who will get them?
(a) It has been claimed that gas extraction of this type will bring down gas prices for consumers. Because of depletion in the North Sea Britain has been an importer of natural gas since 2006 and this has led to UK gas prices being effectively set in the european gas market. In order to have an effect on natural gas prices the coal bed methane extracted (plus other domestic resources from shale gas etc) would need to be on a sufficient scale and extracted as a sufficiently low cost to enable a disconnect from the european gas market by Britain. That would then enable Britain to become self sufficient in gas and have an export surplus to sell in europe. Even under wildly optimistic scenarios this is never going to happen – particularly as gas production in the UK is likely to be much more expensive to extract than in the USA because we do not have the necessary onshore skills and infrastructure here. See the evidence of Bloomberg New Energy Finance Research Team to the House of Lords .
(b) Will it produce LOCAL employment? Many of the higher skilled posts and technical jobs necessary to the industry will not be filled locally but by workers who will come into the area – or will be carried out at a distance in national or even international offices. In the USA a temporary influx of non local workers in the establishment phase of the industry has brought in some business to local hotels and bars – but also increased the costs of local policing and other services. Most jobs will be short term while the industry is being set up – perhaps for 4 to 9 years at the most .
(c) The extent of the benefits will also depend on the depletion profile of the extraction process. Coal bed methane extraction involving fracking is not a long lasting process and may be quite short lived. The lifetime of each coal bed methane well is only 2 to 5 years. The same very rapid depletion profile applies to shale gas extraction. A typical depletion profile for shale gas wells in the Barnet area in the USA is 61% in the first year, 32% in the second year, 24% in the third year. These wells do not last long . After just a few years the industry would move on leaving an industrialised and contaminated wasteland behind – with some of the problems only beginning to emerge when the companies are long gone. For example, within 15 years 50% of all gas wells are leaking and the well structures of steel and concrete cannot be removed – they will stay in the geology, slowly decaying, a toxic legacy to the future generations that live in Nottinghamshire.
(d) At this stage it is not impossible that many of the companies involved will have gone into liquidation. Studies in the USA suggest that the shale gas boom is a bubble promoted by Wall Street because it earns fees through merger and acquisition activity but with very little future. .
There are profits to be made in duping people that an industry has more going for it than it really has – it enables supplier companies to keep providing the inputs for the industry and it enables industry insiders to get out by selling on their shares to suckers who take the loss. In the meantime banks and financial institutions make a killing in the transaction fees as a failing industry is sold on to dupes. But for this to happen the illusion must be kept going for as long as possible. In the meantime real communities and real environments can get seriously damaged.
In conclusion – the draft County Council document declares support for shale gas and coal bed methane development ‘provided they do not give rise to unacceptable impacts’. Approval and support would therefore mean that the above evidence of a large number of destructive effects are considered “acceptable” for the residents of Nottinghamshire. No doubt Notts politicians and officials will wish to try to arrive at some kind of compromise as politics is usually about give and take and compromise. They will probably be tempted to impose stringent conditions on the industry, even to ask them to do environmental impact assessments, and then let them go ahead nevertheless, hoping for the best. In this case however it is necessary to remind that, as the United Nations Environment Programme study argues, these impacts are unavoidable. They cannot be mitigated sufficiently to bring them into the range of being acceptable, and will inevitably do great damage to the people and environment of Nottinghamshire. The county does not have the regulatory resources to hold the industry to account and, in any case, the industry does not have the technological ability to prevent problems emerging because the technology is simply not up to it. It is hubristic to believe otherwise. This is an industry with a track record of alienating communities and doing a great deal of damage – in the USA and Australia. Sitting on the fence and various fudges by politicians is thus not an option. This is because on the other side of the fence there is a destructive delusion, namely that the industry and its PR consultants would like everyone to believe that they can do it safely – when there is massive evidence that they cannot.
These are unambiguously unacceptable impacts and the county council should have the courage and integrity to draw the appropriate conclusions.
1. United Nations Environment Programme. Global Environment Alert Service Nov 2012. http://www.grid.unep.ch/products/3_Reports/GEAS_Nov2012_Fracking.pdf
Read more: Read more: http://www.post-gazette.com/environment/2010/08/03/Report-Well-drilling-violations-near-1-500-for-Marcellus-Shale/stories/201008030175#ixzz2m1LvKiic
9. Rahm D (2011). “Regulating hydraulic fracturing in shale gas plays: The case of Texas”, Energy Policy, 39, 2974 -2981
14. http://mines.industry.qld.gov.au/assets/petroleum-pdf/tara_leaking_well_investigation_report.pdf (see page 4).
19. http://www.dailyexaminer.com.au/news/methane-higher-in-csg-areas/1622910/ http://scu.edu.au/coastal-biogeochemistry/index.php/70/
Featured image: Frack job in process. Author: Joshua Doubek. Source: http://en.wikipedia.org/wiki/File:Frac_job_in_process.JPG