Planning Guidance for Fracking
Consultation to the Community and Local Government Select Committee on Fracking Guidance.
Written Evidence submitted by Transition Chester
Transition Chester is a voluntary community group whose aims and objectives are to work locally to reduce our member’s dependency on the fossil fuel based economy so that they become more resilient and independent from the negative economic, social and psychological effects which climate change and the politics of hydrocarbons inevitably bring.
Our reason for providing evidence to the select committee is to communicate why we consider fracking in the UK is a huge strategic mistake. If the UK is to be truly energy independent in the future and meet all its carbon targets then it must focus investing in the research, development and implementation of renewable sources of energy, energy storage and smart grid technology, not in extending old technologies for another twenty or more years.
Note on the meaning of fracking in this submission.
Fracking means the techniques developed in the USA since about 2007 to extract methane that is contained in multiple tiny fractures within an impermeable rock formation, such as shale. It includes the whole life process from drilling the vertical well until the well is deemed uneconomic and capped. The four separate technologies that were required to come together for fracking to be effective in extracting methane from impervious rocks were:
- Horizontal drilling which allows lateral drilling up to 2 miles in length
- Friction reduction chemistry for the fracking fluid which allows much higher pressures to be applied to the target foration.
- Modern fluid pumping equipment connected in series that can generate the pressures required to open naturally occurring fissures in target formations at great depths and great pressures of up to 20,000 lbs/inch2
- Multi-well pads which typically have eight wells per pad but can be many more.
Modern fracking technology is fundamentally different from the technology that was used to install the existing onshore oil and gas wells in the UK. The scale of its operations and technical complexities are many times more than conventional oil and gas exploration and operation and consequently so are the risks to climate change and for air, water and soil pollution, environmental damage and negative health impacts. Planning guidance needs to be updated to address all of these negative impacts and many more.
Q1 Is there need to update and improve the guidance available?
1.1 Yes. Fracking is an intensive industrial process which is planned to operate cheek by jowl with the country towns and villages in our area. It can only be economic if it is spacially intense and continually expands to extract gas that is everywhere in the shale formations underlying our area. It involves operating with huge fluid volumes and pressures and transporting and handling enormous volumes of water, chemicals, proppant materials and waste materials together with all the fracking equipment, casing pipes, ancillary structures and consumables for the multiple operations required. We therefore conclude that the enhanced risks fully justify a review of guidance and that no more applications should be approved until it is in place.
1.1.2 Fracking scales up many times the risks inherent in conventional oil and gas exploration and production. Its operating mechanisms are still evolving. It is by no means safe and proven. The problematic areas inherent in fracking include:
- Impact of the industrialisation of the countryside.
- Impact on climate change and at odds with government C02 emission targets.
- Adverse impact on human health and wellbeing
- Adverse impact on pollution to the air, water and surface soils
- Impact on available waste treatment facilities
- Impact of transport movements including increase in accidents
- Adverse impact on the environment and wildlife
New planning guidance should properly address these impacts to assure residents living alongside fracking that the impacts are reduced to such an extent that they do not negatively affect their lives. If this is not the case, there will be, nor should there be a social licence for the gas companies to operate in our area.
1.1.3 We are also concerned about other risks that could adversely affect us:
- Weak regulation, oversight and enforcement by the regulators and planning conditions
- Consequences of an under-capitalised fracking company becoming insolvent and leaving our borough council to deal with the mess.
- Risks of drilling/fracking in complex geology.
1.2 Since the gas is everywhere in the shale the aim of the gas company is to drill everywhere in the rock. The area of West Cheshire and Chester is 917 km2 and would require approx. 2750 drilled wells to frack the underlying shale, allowing 3 wells per km2 which is normal in the USA for shale gas extraction. Even if only half of the borough was covered, it would still be the intention of the developer to frack nearly 1400 wells.
1.21 The problem we have with the existing planning system is that it treats one application at a time without consideration for the final accumulative development. Planning guidance should state that the applicant provides the extent of the intended full gas field development for their licenced area with each individual well application. In West Cheshire and Chester just one company controls the drilling licences so we fully expect the whole of the borough to be fracked.
1.3 The Climate Change Act 2008 binds the UK to carbon reduction targets in 5 year increments up to 2050. The UK also signed up to the Paris Agreement with the commitment of the UK government to play there part in keeping global temperature rise to well below 2.0 deg. C compared to pre-industrial levels. The government’s Clean Growth Strategy emphasises the need to move away from carbon producing fuels and invest in carbon neutral energy technologies.
1.3.1 We consider it vital that each gas field application includes an estimate of the CO2 equivalent resulting from all the operations required within the application. This would include setting up the site(s), drilling, fracking, transport movements, ancillary equipment, venting or flaring of methane, rogue emissions from plant and site reinstatement with the LPA estimating emissions from leaking wells for the production period based on the extensive research from the USA.
1.3.2 It has been established in the USA by multiple studies that gas wells leak to an alarming extent. A typical study in 2012 concluded that 9% of new fracking wells in Pennsylvania were leaking. A USA government paper stated that 35% of all wells, both conventional and non-conventional, were leaking. It must also be borne in mind that all wells fail in time and can provide a pathway for methane and other pollutants to migrate to the atmosphere. Methane leaks from abandoned wells and poorly maintained pipelines. The methane concentration in the atmosphere has doubled since the start of the industrial revolution.
1.3.3 Methane is a potant greenhouse gas. It is 100 times more potant than CO2 after 20 years and 33 times more after 100 years. It is an essential requirement that baseline monitoring of methane is carried out as a condition of planning approval.
1.4 The adverse health effects of residents living near to fracking sites in the USA and Australia are well documented. The cause of such effects is consistent with methane, organic volatile compounds and other air borne pollutants released into the atmosphere during fracking operations. There are also many instances of private water wells being contaminated near to fracking sites. We consider it vital that applicants demonstrate how they will establish baseline measurements of air, surface water and shallow soils contamination around the well sites and provide real time readings to the public at all times during fracking operations.
1.4.1 The proposed fracking site at Upton, Chester is within a few hundred metres of several schools and dense residential housing. We do not believe that this is best practice, although present planning guidance allows it. We have been told by the fracking industry and government that regulations in the UK will be to a gold standard (we assume this term means to the highest standard). We therefore consider that well sites should be a least 1 km. from the nearest dwelling and preferably 2km and this should be a condition of approval.
1.4.2 Oil and gas is an important natural resource but not as vital to human health and well-being as clean potable water. Should an underground water source be contaminated by fracking operations there is no possible remedy to remove the contaminant(s) and the water remains unusable indefinitely. Therefore it must be incumbent on the applicant to monitor subterranean aquifers through which a gas well is drilled by, for example, by drilling an additional well from which water samples can be monitored. We believe that vital water resources cannot be put at risk by the existing reactive regime of the EA which is totally inadequate to manage the risks associated with contaminating the Sherwood Sandstone formation, a major aquifer below West Cheshire.
1.5 Fracking uses huge amounts of potable water and has to dispose of up to 50% of this as flowback fluids, containing some or all of the contaminants listed in para 1.5.1 below. Depending on the length of the laterals, rock permeability etc. fracking typically requires between 2,000,000 and 6,000,000 US gallons of fluid per well which means that an estimated average of 121,000 m3 or tonnes of water are required for each 8 well frack pad.
1.5.1 Fracking fluids return back to surface during fracking operations and continue to flow back as produced water in decreasing quantities during the life of the well. Flowback fluids contains proppant (usually sand), fracking chemicals, absorbed salts, volatile organic compounds (VOCs) and depending on the geology, heavy metals, radioactive materials and radon gas. Typically 20% – 50% of fracking fluid returns as flowback which means between 24,200m3 and 60,500m3 must be treated to remove contaminants for an 8 well frack pad.
1.5.2 There are no facilities to deal with these quantities of contaminated materials in the West Cheshire area. We consider it essential that planning applications provide realistic details of the fresh water sources they propose to use and the quantities of waste fluids to be treated, the likely contaminants and the treatment facilities which will take the waste at the rates required by site operations.
1.6 Fracking uses the road transport system exclusively to move all the equipment and materials necessary. This results in huge emissions of C02 and air pollution from diesel emissions. Assuming fluids are delivered/removed by road tanker we have calculated that 5,600 (+/- 30%) one-way movements are required for one 8 well pad over an average distance of 400,000 kilometres resulting in 480 tonnes of CO2 emissions. If half the area of the West Cheshire borough were fracked there would be approx. 175 pads. (NOTE – these figures need to be checked)
1.6.1 Movements are most intense during the injection of fluids to fracture the target rock and we have calculated that x one way movements will occure over a 3 week period.
1.6.2 Research carried out in the USA found that road traffic accidents around fracking sites can rise by up to 60% during fracking operations compared to data prior to fracking. This is completely unacceptable and not a price that we are prepared to pay in the Chester area. Planning guidance should require the applicant to demonstrate how they propose to minimise disruption to local traffic movements, especially at peak times and how they will prevent road traffic accidents with their vehicles.
1.7 We consider it essential that an Environmental Risk Assessment is mandatory for all applications for an UG development.
1.8 If the fracking companies install wells at the rates that make them economic, the LA’s and the regulatory bodies do not have the resources to execute their responsibilities to protect the environment and public from the many risks that fracking poses. They barley have enough resources to even perform their current reactive duties, dealing with problems after they have occurred. It is pointless to impose planning conditions and gold standard regulation without gold standard oversight and enforcement, as well as operation. We have already witnessed weak enforcement by LA’s and the regulatory bodies, whilst independent oversight seems to be non-existent.
1.8.1 We do not see the point of imposing planning conditions only to be relaxed at a later date. Planning guidance must state that there will be no relaxation of a condition and that ignoring a condition negates the approval and requires the applicant to submit a new application.
1.9 There seems to be a major problem with the financing of the emerging fracking industry in the UK. This must be a major concern to Government and LA’s alike. We believe it is imperative that LA’s are not left financially exposed by fracking companies going into liquidation. Planning guidance must address this possibility so that a financial burden does not fall on the rate payer or the tax payer.
1.9.1 Due to the size, weight and frequency of HGV movements on country roads not designed for such traffic, there is bound to be damage to roads and verges and probably drains, culverts, bridges etc. Guidance is required for how the applicant is to make good these damages. In some states of the USA, fracking companies are required to pay a substantial sum up front so that litigation is avoided when disputes arise over who is responsible for such damages.
1.10 When fracking in areas of known faulting, guidance needs to specify the special measures that are required to avoid loss of integratory of the well.
Q2 Is there the need for a comprehensive document incorporating existing and updated guidance?
It would certainly be more convenient to have all the guidance in one document. However, the Government need to be giving clear leadership on its priorities as far as energy policy is concerned. As we pointed out in clause 1.3 Government has committed to binding agreements and an energy strategy which requires action now to decarbonise energy. On the other hand it removes legislation that was growing the renewable energy sector to deliver the required carbon reductions and investment in renewables has stalled. At the same time the leadership announces that UGE is going to give us cheap gas and energy security. As pointed out in clauses 1.3.1 and 1.3.2 fracked gas is not going to give reductions in CO2 equivalent reductions. If the policy is to decarbonise with all due haste then investment needs to go into renewables which will provide more good jobs and create a foundation for Britain to be a world leader in the next generation of energy technologies, especially wind turbines. The shortfall in gas supply can be provided by imports in the same way that our shortfall in food production is. By investing in energy generation technologies that do not require the combustion of carbon fuels we will be building energy security and controlling the cost of energy for the future. The signal to invest in technology rather than fossil fuels needs to come from the Government without equivocation.
Q3 What is the status – in planning terms – of the extant Government guidance?
3.1 No comment
Q4 Should applications for fracking be dealt with as national infrastructure under the 2008 Planning Act?
4.1 No. Fracking is neither infrastructure nor national. It’s footprint in the UK will be confined to specific regions, mainly in the north. In Chester, the proposed well site at Dutton’s Lane, Upton aroused huge public interest and this reaction by the public is evidenced generally. Residents living near to well sites deserve to have their say during planning consultation as the potential impacts of fracking are more onerous than any other form of development. We don’t know of any fracking development in the UK that has social licence to proceed.
4.2 In the whole history of the industrial revolution there has never been such a threat to the environment, water supplies, air pollution and public health as there is by the fracking industry. It is inconceivable that decisions on planning applications for gas wells in the Chester area are taken in Westminster without knowledge, experience or connection with our historic heritage and pristine countryside. The people who have to live with the nuisance, health risks and long term uncertainties of leaking wells deserve to have their say at the planning stage.
4.3 In recent years there has been a trend towards devolved power. National assemblies have been established and the Localism Act 2011 was introduced to give local people more power over development in their area by contributing to Neighbourhood Plans. More recently, the Cities and Local GovernmentDevolution Act 2016 included planning within the devolved powers.
4.4 In 2015 Communities Secretary, Gregg Clark, proudly announced that local residents must have their say over whether wind farm applications get the go ahead in their area. Since it is logical to assume that wind farms are just as much a national infrastructure as fracking, it poses the question why is fracking out of step with the government’s general trend towards devolved powers. This is a pertinent question for the select committee to fully investigate.
4.5 The threat of fracking has engaged local people in the planning process and this is to be commended. True democracy comes from the people for the people and should be encouraged by a progressive government. We have never witnessed ordinary residents so motivated and dedicated to a cause as we have with stopping fracking in and around Chester. The opposition to fracking includes people of all political persuasions and sections of the community and it is a spontaneous democratic movement to project the precious natural resources on which we are all completely dependent.
Final Comment – Precautionary principle
We believe that the precautionary principle should be applied in the case of fracking in the UK. There is much science based evidence from the USA that a high probability exists for fracking to cause harm to humans and the environment.