26th January 2015: 'Do the EAC's plans for a 'fracking moratorium' go far enough?' » 2015 » Mobbsey's Musings » Paul Mobbs/MEI » FRAW

No, not David Cameron on fracking!
No, not David Cameron on fracking

When is "fracking" not "fracking"?:
Do the EAC's plans for a 'fracking moratorium' go far enough?

Paul Mobbs, "Mobbsey's Musings", 26th January 2015

Today could be an interesting day for the future campaign against unconventional oil and gas in Britain. Today we potentially turn a corner – or, quite possibly, not, if the fossil fuel lobby within the government get their way.

Published in 'The Ecologist', 26th January 2015, under the title,
"The EAC's plan for a 'fracking moratorium' in Britain doesn't go far enough"

Last week, Caroline Spelman let slip[1] that the Environment Audit Committee's (EAC) new report, the 'Environmental risks of fracking'[2], would call for a moratorium. Since then both the pro and anti[3] side of the debate has been buzzing in anticipation of the report's content, and whether today's vote on the Infrastructure Bill would call a halt to fracking in Britain.

The day before that, news emerged that planners at Lancashire County Council were recommending refusal of planning permission[4] for Cuadrilla's two new shale exploration sites – on the grounds of noise and traffic generation.

Shortly thereafter the North West Energy Task Force[5], a local 'astroturf'[6] lobby group funded by Centrica and Cuadrilla (their information allegedly ghost-written by Centrica and Cuadrilla's lobbyists, Westbourne Communications[7]), were quoted as saying that traffic and noise were "not grounds for objections"[8].

In Scotland there's an ongoing debate about a ban[9], fuelled by Dart Energy's proposed coalbed methane (CBM) developments around Airth[10], as well as Cluff Natural Resources plans for underground coal gasification (UCG) at Kincardine[11] in the Firth of Forth. It's even causing spats within the SNP[12].

Both CBM and UCG have, like shale gas, the potential to cause pollution. Question is, would either of these be caught within the EAC's proposals for a moratorium on 'fracking'?

The problem with the media-simplified debate over 'extreme energy'[13] in Britain is that has focussed, to its detriment, upon shale gas and "fracking". While shale gas inevitably involves hydraulic fracturing, coalbed methane does not always require it; and underground coal gasification is a wholly different, and arguably worse, process altogether.

I wrote a lengthy submission[14] to the EAC's inquiry[15], outlining these differences. In a follow-up article for The Ecologist[16], I challenged them to 'prove me wrong' – showing that they could hold an evidence-based, unbiased exploration of the issues.

While the EAC's new report certainly excels above previous reports by the Energy and Climate[17] or Economic Affairs[18] committees, it still contains some serious errors and omissions.

Top of my list of bullet points for consideration by the EAC's inquiry (paragraph 46 of my submission[14]) –

Decision-making must differentiate shale gas, from coalbed methane, from UCG, in order to recognise their unique 'fingerprint' upon the environment.

They did not do that. Consequently amendments proposed for the Infrastructure Bill contain a significant flaw.

Throughout the amendments to the bill[19] the terms 'shale gas' and 'hydraulic fracturing' are used. The amendment tabled by the EAC states –

leave out "the objective of maximising the economic recovery of UK petroleum, in particular through" and insert "not the objective of maximising the economic recovery of UK petroleum but ensuring that fossil fuel emissions are limited to the carbon budgets advised by the Committee on Climate Change and introducing a moratorium on the hydraulic fracturing of shale gas deposits in order to reduce the risk of carbon budgets being breached

If enacted, the terms of such a 'moratorium' would arguably not apply to coalbed methane – it could be developed (though less economically) without the use of high volume hydraulic fracturing. Coastal Oil and Gas in South Wales, or Dart (recently taken over by IGas[20]) could still go ahead with their extraction plans at Airth, or exploration in Shropshire and Cheshire.

And such a ban would arguably not affect, in any way, the proposed development of UCG by companies such as Cluff Natural Resources[21] or Five Quarter Energy[22].

The purpose of the Environmental Audit Committee is to consider how government policy contribute to environmental protection and sustainable development, and to audit their performance. In my view the Committee haven't done that. They did not seek to quantify the full range of impacts of the various 'unconventional' oil and gas technologies currently planned for development across Britain.

It has to be said, the Committee have made some good recommendations in their – admittedly rushed – report. However, they also appeared to accept evidence which was highly questionable.

For example (paragraph 78 of their report) –

Many of our witnesses acknowledged that the existing UK conventional onshore industry has a generally safe history, with over 200 producing wells and no pollution incidents from well design.

In fact recent research, by a part-industry-sponsored group, shows that[23]: we have no detailed knowledge of at least half of the 2000 or so deep wells drilled in Britain over the last century; there is no structured monitoring process to check their condition; and at least one well has failed – and none of those where subject to high volume hydraulic fracturing (HVHF).

The one well in Britain which has been subject to HVHF, at Preese Hall, has failed[24] – and the Health and Safety Executive's refusal to require the proper inspection of the well during construction is in part responsible for that failure.

The Committee also state (paragraph 36 of their report) –

The Researching Fracking In Europe consortium informed us that their "research has found that even in the 'worst case scenario', flux in the radioactivity of flowback fluid would not exceed the annual exposure limit set by the UK Environment Agency."

I tackled that paper, and its flaws, in an article for The Ecologist[25] last July.

It used a highly selective sample of some of the most radioactive natural mineral springs in order to state that the 'naturally occurring' radioactivity in flowback water is safe. It also makes some errors in its assumptions about dose limits, and fails to show all the data required to validate it findings against the international standard procedures for dose calculation.

That is why we need a proper public inquiry, testing the evidence. All assumptions and data, whatever its source, must be objectively tested to establish how much weight can be applied to them.

Perhaps my greatest difficulty with the EAC's report is that it largely concentrates on climate change and carbon emissions. That completely misses the broad range of impacts unconventional fossil fuels create.

We could completely eradicate the fugitive emissions from unconventional oil and gas, making it some of the cleanest fossil fuel production in the world, and the problems it creates would still make it highly damaging.

'Low carbon' or 'green completion'[26] unconventional oil and gas production would still generate large quantities of toxic and hazardous materials – with as yet no identified treatment facility or disposal location. These developments, in particular the pipelines and associated roads, would also damage large areas of the landscape and natural habitats – as outlined in recent US research[27].

And though it may create a short-term boom for certain vested interests – like the North West Energy Task Force – it would absolutely fail to tackle the greater imperative of addressing the ecological overshoot of our society.

There were two other events in the last week which passed by, seemingly un-noticed.

Firstly, Egdon Resources[28] applied for a permit from the Environment Agency[29] to test drill their Laughton site[30]. No fracking – yet – but it enlarges a new eastern development area in the Bowland shale.

More significantly, Third Energy[31] applied to use two existing, uneconomic wells for the disposal of the waste from other oil and gas operations – one permit for[32] their site at Ebberston[33] (on the border of the North Yorks. Moors National Park) and another permit[34] for their site near Pickering[35] (just south of the national park area). This represents a significant policy shift as, until now, Britain hasn't favoured disposal via deep injection. In the US, it is deep injection which appears to give rise to the greatest risks from groundwater pollution[36] and seismic activity[37].

Third Energy's current gas wells are 'conventional' (free flowing) gas wells. What's significant here is not the source of the wastewater – it's that this application could set a precedent for deep disposal from unconventional oil and gas sites.

Again, that's something the EAC's moratorium doesn't encompass.

What happens in Parliament today is significant, but it's not as important as what comes next.

If there's a moratorium, then we have to make sure that any inquiry processes which follow properly consider all the available evidence.

Alternately, if the Government force a vote to quash the call for a moratorium, that escalates nature of the debate. It will no longer be a reasoned debate over evidence. The Government will have abandoned any such pretence, and will instead impose their will purely because they can[38].

If the Government force their will upon Parliament, that's as big a problem for the Environmental Audit Committee as it is for the public. It basically says that their evidence gathering was a waste of time, and that they are not going to be listened to.

For the public, and anti-fracking campaigners in particular, it's a clear message. That democratic processes based upon evidence are no longer valid – and that in Britain, as in the USA, it is spin and lobbying[39] which now provide the justification for policy. If you wish to oppose the development of unconventional oil and gas, with all legal redress[40] closed off by current law reforms[41], your only option for doing so will be through direct action.


  1. Ban fracking, says former Tory environment secretary Caroline Spelman, Damian Carrington, Guardian On-line, Thursday 22nd January 2015 – http://www.theguardian.com/environment/2015/jan/22/ban-fracking-says-former-tory-environment-secretary-caroline-spelman
  2. Environmental risks of fracking, Eighth Report of Session 2014-15 (HC856), House of Commons Environmental Audit Committee, 26th January 2015 – http://www.publications.parliament.uk/pa/cm201415/cmselect/cmenvaud/856/856.pdf
  3. UK MPs call for fracking moratorium, Shale Energy Insider, 23rd January 2015 – http://www.shaleenergyinsider.com/2015/01/23/uk-mps-call-for-fracking-moratorium/
  4. Controversial Lancashire fracking plans 'should be refused', Damian Carrington, Guardian On-line, Wednesday 21st January 2015 – http://www.theguardian.com/environment/2015/jan/21/cuadrilla-lancashire-fracking-should-be-refused
  5. North West Energy Task Forcehttp://www.nwenergy.org.uk/
  6. Wikipedia: 'Astroturfing'https://en.wikipedia.org/wiki/Astroturfing
  7. Powerbase: 'North West Energy Task Force'http://powerbase.info/index.php/North_West_Energy_Task_Force
  8. Fracking: Lancashire County Council poised to approve two controversial shale gas sites, despite objections, Independent On-line, Sunday 25th January 2015 – http://www.independent.co.uk/news/uk/politics/fracking-lancashire-county-council-poised-to-approve-two-controversial-shale-gas-sites-despite-objections-10000842.html
  9. SNP and Labour move to suspend fracking and onshore gas mining, Scottish Herald, Sunday 25th January 2015 – http://www.heraldscotland.com/news/environment/snp-and-labour-move-to-suspend-fracking-and-onshore-gas-mining.116881015
  10. PEDL 133, Dart Energy Scotland – http://www.dartenergyscotland.co.uk/assets/pedl133.html
  11. Projects, Cluff Natural Resourceshttp://www.cluffnaturalresources.com/projects.aspx
  12. Bitter row between Joan McAlpine, Fergus Ewing over shale gas sparks complaint to Sturgeon, Scottish Herald, Sunday 25th January 2015 – http://www.heraldscotland.com/news/environment/msps-clash-over-shale-gas-sparks-complaint-to-sturgeon.116871742
  13. Extreme Energy Initiativehttp://extremeenergy.org/
  14. Written evidence submitted by Mobbs' Environmental Investigations, Environmental Audit Committee, January 2015 – http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/environmental-audit-committee/environmental-risks-of-fracking/written/17051.pdf
  15. Environmental Audit Committee: 'Environmental risks of fracking inquiry'http://www.parliament.uk/business/committees/committees-a-z/commons-select/environmental-audit-committee/inquiries/parliament-2010/environmental-risks-of-fracking-inquiry/
  16. Parliament's fracking examination must be inclusive and impartial, Paul Mobbs, The Ecologist, 13th January 2015 – http://www.theecologist.org/blogs_and_comments/commentators/2711765/parliaments_fracking_examination_must_be_inclusive_and_impartial.html
  17. Shale Gas, Fifth Report 2010-12 Session (HC795), Energy and Climate Change Committee, May 2011 – http://www.publications.parliament.uk/pa/cm201012/cmselect/cmenergy/795/795.pdf
  18. The Economic Impact on UK Energy Policy of Shale Gas and Oil, Third Report 2013-14 Session (HL172), Economic Affairs Committee, May 2014 – http://www.publications.parliament.uk/pa/ld201314/ldselect/ldeconaf/172/172.pdf
  19. Notices Of Amendments, House of Commons, Wednesday 21 January 2015 – http://www.publications.parliament.uk/pa/bills/cbill/2014-2015/0154/amend/infrastructureaddednames.pdf
  20. IGas Energy plchttp://www.igasplc.com/
  21. Cluff Natural Resourceshttp://www.cluffnaturalresources.com/
  22. Five Quarter Energyhttp://www.five-quarter.com/
  23. Oil and gas wells and their integrity: Implications for shale and unconventional resource exploitation, Davies et al., Marine and Petroleum Geology (preprint), March 2014 – http://www.fraw.org.uk/files/extreme/davies_2014.pdf
  24. The Only Fracked Site in the United Kingdom Suffered Structural Failure, Ben Bryant, Vice News, 2nd December 2014 – https://news.vice.com/article/the-only-fracked-site-in-the-united-kingdom-suffered-structural-failure
  25. An abuse of science – concealing fracking's radioactive footprint, Paul Mobbs, The Ecologist, 8th July 2014 – http://www.theecologist.org/News/news_analysis/2469495/an_abuse_of_science_concealing_frackings_radioactive_footprint.html
  26. Experts: EPA Shale Gas Emission Rules "Too Little, Too Late", PR Newswire, 30th April 2012 – http://www.digitaljournal.com/pr/687314
  27. Landscape Consequences of Natural Gas Extraction in Bradford and Washington Counties, Pennsylvania, 2004-2010, Slonecker et al., United States Geological Survey, 2012 – http://www.fraw.org.uk/files/extreme/usgs_2012.pdf
  28. Egdon Resourceshttp://www.egdon-resources.com/
  29. Egdon Resources UK Limited: Environmental permit application advertisement, Environment Agency, 23rd January 2015 – https://www.gov.uk/government/publications/dn21-3pt-egdon-resources-uk-limited-environmental-permit-application-advertisement/dn21-3pt-egdon-resources-uk-limited-environmental-permit-application-advertisement
  30. Streetmap: 'Laughton'http://streetmap.co.uk/map.srf?X=485365&Y=397911&A=Y&Z=120
  31. Third Energyhttp://www.third-energy.com/
  32. Regulated facility location: Ebbertson South Wellsite, Malton Cote Road, Ebbertson, North Yorkshire, Environment Agency, 23rd January 2015 – https://www.gov.uk/government/publications/yo13-9pt-third-energy-uk-gas-limited-environmental-permit-application-advertisement--2/yo13-9pt-third-energy-uk-gas-limited-environmental-permit-application-advertisement--2
  33. Streetmap: 'Ebberston'http://streetmap.co.uk/map.srf?X=490115&Y=487070&A=Y&Z=120
  34. Pickering Wellsite, Malton Road, Pickering, North Yorkshire, Environment Agency, 23rd January 2015 – https://www.gov.uk/government/publications/yo18-8ea-third-energy-uk-gas-limited-environmental-permit-application-advertisement--2/yo18-8ea-third-energy-uk-gas-limited-environmental-permit-application-advertisement--2
  35. Streetmap: 'Pickering'http://streetmap.co.uk/map.srf?X=479685&Y=482190&A=Y&Z=120
  36. Injection Wells: The Poison Beneath Us, Abrahm Lustgarten, ProPublica, 21st June 2012 – http://www.propublica.org/article/injection-wells-the-poison-beneath-us
  37. The 2001-Present Induced Earthquake Sequence in the Raton Basin of Northern New Mexico and Southern Colorado, Rubinstein et al., Bulletin of the Seismological Society of America, vol.104 no.5, October 2014 – http://www.fraw.org.uk/files/extreme/rubinstein_2014.pdf
  38. Fracking Britain: without debate, the Government imposes its 'right to rule', Paul Mobbs, The Ecologist, 21st July 2014 – http://www.theecologist.org/campaigning/2486001/fracking_britain_without_debate_the_government_imposes_its_right_to_rule.html
  39. "Behind every picture lies a story" – statistical reality versus PR-hype within the political project of unconventional gas in Britain, Paul Mobbs, 25th July 2013 – http://www.fraw.org.uk/mei/musings/2013/20130725-behind_every_picture_lies_a_story.html
  40. How Chris Grayling is killing off judicial review – and why it matters, Caroline Criado-Perez, New Statesman, 9th December, 2014 – http://www.newstatesman.com/politics/2014/12/how-chris-grayling-killing-judicial-review-and-why-it-matters
  41. 'Incompetent' Grayling condemned by ex-Tory MP as 'off his trolley', Nigel Morris, Independent On-line, Friday 23rd January 2015 – http://www.independent.co.uk/news/uk/politics/incompetent-grayling-condemned-by-extory-mp-as-off-his-trolley-9999560.html