Thursday, 29 January 2015

Shale gas health studies from the USA: Are they relevant to the UK?

Public Health England has looked into the potential health impacts of shale gas extraction in the UK, and concluded that "the potential risks to public health from exposure to the emissions associated with shale gas extraction will be low if the operations are properly run and regulated".

Nevertheless, it is clear that concerns remain among the public at large, promoted in no small part by the claims of anti-fracking groups. Claims about the public health impacts of shale gas extraction seem to run amok, but there are precious few peer-reviewed publications that actually document actual public health impacts from the process.

Indeed, the only peer reviewed studies to document any such effect is that published by the Colorado School of Public Health, McKenzie et al. (2012) and McKenzie et al. (2014). These papers feature prominently in  anti-fracking literature. Indeed, they are a particular favourite of electrical engineer Mike Hill, who features prominently in the Lancashire anti-fracking movement (and recently gave evidence to the Lancashire County Council on Cuadrilla's current planning applications). In his much-vaunted letter to the Lancet, the McKenzie papers are the only cited papers that document any potential health impacts.

As an aside, note that the claims made by Mr Hill in his public presentations on the topic, as documented on the Drillordrop website, are not actually backed up in his Lancet letter. Mr Hill claims to cite peer-reviewed papers by MIT and Princeton, however no such papers are present in his Lancet letter. He claims that he "conclude[s] that there was a 30% increase in birth defects if you live within 10 miles of a fracking well [and] there was a 38% increase in cancers and congenital heart defects". However, a brief perusal of the Lancet letter itself will reveal that Mr Hill made no such conclusions.

The failings of the McKenzie papers have been discussed at length. In the 2012 paper, McKenzie et al. fail to account for the fact that her "drilling" samples were taken 1 mile downwind of a major interstate (motorway), while her baseline samples were taken 4 miles upwind of the motorway. It is hardly surprising therefore that they found an increase in air pollution in the "drilling" samples.  

Meanwhile, the 2014 paper was publicly disavowed by Dr. Larry Wolk, Chief Medical Officer and Executive Director of the Colorado Department of Public Health and Environment. In his rebuttal, he noted that
"the authors did not consider the effect that other risk factors may have played (examples: smoking, drinking, mother’s folic acid intake during pregnancy, access to prenatal care, etc)" 
"the study showed decreased risk of pre-term birth with greater exposure. [...] Example: The study data showed that the nearer the mother lived to a well, the less likely the mother was to give birth prematurely or to have a low-birth-weight baby." 
"the statistical differences in birth defects were minuscule"
concluding that:
"we disagree with many of the specific associations with the occurrence of birth defects noted within the study. Therefore, a reader of the study could easily be misled to become overly concerned."
However, lets leave these criticisms and rebuttals to one side for a minute, and pretend that the McKenzie et al. findings are robust and genuine. Would they in that case be relevant to the current UK discussion?

No, they would not. The data collected by McKenzie et al. cover practices that are not allowed in the UK. Therefore the McKenzie data is meaningless for the UK context, and self-professed "experts" such as Mr Hill should desist from claiming otherwise.

From McKenzie et al. (2012) we learn about the activities being conducted at the well pads examined in their studies:
"The GCPH worked closely with the NGD operators to ensure these air samples were collected during the period while at least one well was on uncontrolled (emissions not controlled) flowback into collection tanks vented directly to the air." 
"Samples were collected over 24 to 27-hour intervals, and samples included emissions from both uncontrolled flowback and diesel engines." 
"Of the 12 wells on this pad, 8 were producing salable natural gas; 1 had been drilled but not completed; 2 were being hydraulically fractured during daytime hours, with ensuing uncontrolled flowback during nighttime hours; and 1 was on uncontrolled flowback during nighttime hours."
Uncontrolled flowback, where gases are vented directly to the atmosphere, is not allowed in the UK. Operators will be required by the Environment Agency to use green completions, where these emissions are captured. From the government response to the MacKay and Stone report:
"The Environment Agency considers that ‘green completions’ are BAT (Best Available Technology) for production facilities. Making green completions part of BAT will mean that producers will be required to use new technologies that will help limit or stop emissions"
To conclude, the McKenzie et al. papers are the only peer-reviewed documentation of shale gas public health impacts. The flaws in these papers are well established. Even so, the data they present are not relevant to a UK setting, because they are measuring processes that are not allowed in the UK. When commentators refer to important differences between USA and UK regulations, this is the kind of thing they are talking about. Self-appointed "experts" who reference these papers in a UK context without highlighting this important distinction are misleading the public.

Monday, 26 January 2015

Environmental Audit Committee on Shale Gas: A Foregone Conclusion?

Today's news is the release of the Parliamentary Environmental Audit Committee on the "Environmental Risks of Fracking".

The eagle-eyed among you will note that Professor Michael Kendall and I submitted written evidence to the inquiry. It's not the first time we have submitted evidence to such an inquiry, having done so for the Select Committee on Energy and Climate Change's report on CCS.

It's worth documenting the differences I noted between the two inquiries. The CCS inquiry received 38 written submissions. It called 18 witnesses to give oral evidence, over a period of 3 months, starting several months after the written submissions had been received. The final report was released more than 3 months after the final session of oral evidence.

In contrast, the EAC fracking report received 71 written submissions. Nevertheless, it only called 8 witnesses to give oral evidence, and did so only 2 weeks after the written evidence had been gathered. The final report has been released only 1 week after the evidence sessions.

The speed of this release suggests to me that the EAC went into this inquiry having already decided on their course of action - a call for a moratorium - and that they have not properly considered the evidence in front of them, nor sought a proper breadth of representation from their oral witnesses.

This suggestion is only furthered when one considers the content of the report.

With regards the climate change argument, the report totally fails to consider the prospect of CCS. Almost every study that outlines how the UK might reach its low-carbon electricity targets accepts that CCS will be required. Even Friends of the Earth's report on "Clean British Energy" finds that CCS is necessary. The use of CCS to capture CO2 emissions means that the EAC conclusions on shale gas and carbon budgets are blown completely out of the water.

The EAC report spends a lot of time considering whether shale gas might end up substituting for coal or for renewables. However, the question it asks misses the most obvious substitution: that shale gas might substitute for LNG imported from Qatar, and/or gas piped from Eastern Europe. The Committee on Climate Change concluded that domestic shale gas would likely have a lower greenhouse-gas footprint than such imports. While the EAC report does mention this fact, it is not accounted for in the EAC conclusions.

It also fails to consider the likely amount of gas we will be using in the future. This is surely the most important question to ask when considering whether shale gas might be compatible with future UK energy policy. Discussion of carbon targets is important, but it is equally important to consider the likely state of our energy system in 10 - 20 years time.

Ultimately, we need to estimate how much gas we will be using in the future (in all sectors, not just electricity). We also need to estimate how much gas we will still be producing from other sources (mainly the North Sea, but also biomass etc.). If the total we produce is lower than that we consume, we will have to import gas, in which case there is a clear argument for domestic shale gas production to substitute for imported gas, at it is more beneficial for our economy, and will have a lower GHG footprint. If we will produce more domestically than we are expected to consume, then there is no case for shale development. I am not aware of any study that thinks that in 20 years time we will be producing more natural gas than we consume. Ergo a clear case, both in terms of climate and economy, for domestic shale gas production.

Probably the most reliable and respected estimator of the future of our energy systems is the National Grid, in their Future Energy Scenarios documents. These reports have been completely neglected by the EAC, which is a poor omission. The NG come up with a range of scenarios for future energy systems, from the most optimistic (lots of renewables, lots of efficiency etc) to the most pessimistic (business as usual etc), to ensure that they cover all the bases.

The two low-carbon cases are the "Gone Green" and "Low-Carbon Life" scenarios. At present, our total gas demand is a shade under 800 TWh/yr. By 2035 (when UK shale gas production would be in full swing), under the Gone Green Scenario our total gas demand will be approximately 700TWh/yr, while under the Low-Carbon Life Scenario it actually increases slightly to over 800TWh/yr. Even the slight fall under the Gone Green Scenario is nowhere near enough to account for the expected drop off in North Sea gas production.

By failing to consider these scenarios, the EAC has left a gaping hole in its arguments. Perhaps to be expected from a report cobbled together in less than a week.

In terms of local environmental risks, the EAC report accepts that
"The evidence from a range of government bodies and institutions is generally in agreement that fracking can proceed in the UK safely and without harm to the environment provided proper environmental safeguards are introduced and adhered to." 
Given this consensus, it is not clear what a moratorium for further study, as recommended by the EAC, would hope to achieve. Should we just re-publish the same studies in a couple of years' time?

The EAC report goes on to consider risks in more detail. However, it consistently ignores evidence provided by experts, such as the Environment Agency, various academics etc., and relies instead on evidence from either activists, or people with no apparent qualification or experience.

A non-exhuastive list of examples follows:

1. The EAC report cites the "Frack Free Balcombe Residents Association":
"The Frack Free Balcombe Resident’s Association raised concerns that 'wells or fractures intersecting with natural faults could easily become conduits for leaking gases and liquids'"
but completely ignores the evidence provided by myself and Professor Kendall, which provides extensive documentation from peer-reviewed scientific literature that this is extremely unlikely to happen.

2. The Environment Agency state that
"the regulatory 'regime that we currently have is sufficient,' and sufficiently incorporates the precautionary principle."
However, the EAC seems to place more weight on the "Safety in Fossil Fuels Alliance" (an anti-fracking group):
"SaFE believed however that 'the Government is putting people and the environment at significant risk' because it is not applying the precautionary principle"
3. The Environment Agency confirmed that it will only allow "non-hazardous" substances to be used in fracking fluids. However, the EAC seems to prefer instead evidence from FFBRA, who claim, erroneously that:
"the access rights provision in the Infrastructure Bill (paragraph 7) effectively allows 'any substance to be injected into and left in the lateral wells ... drilled under our property.'"
(For an extended discussion of why this isn't true, see my post here).

4. The EAC report quotes prominently comments made by Frack Off Fife:
"It is without doubt that each of these [underground extraction] processes pose a threat to our water supplies. Why the Government need to re-query this is unnecessary as there’s an abundance of scientific evidence to support the facts that the chemicals used in the drilling and fracturing processes, are very dangerous in many aspects and once the water supply is contaminated, it cannot be un-contaminated. Water’s natural ability to permeate rock means the contaminated waters will eventually find clean/natural/ground waters and thus, contaminate them ... and put at risk the environment around it."
This ignores the Environment Agency requirement that only non-hazardous chemicals are used in the fracking fluid. It ignores the evidence provided by Prof. Kendall and myself that fracking fluids are extremely unlikely to "permeate rock" to contaminate groundwater. This comment shows zero understanding of geology/hydrology, and is made by a group that has precious little expertise in this regard, yet the EAC see fit to quote it prominently and uncritically.

5. The EAC appear to rely on Friends of the Earth for data on well integrity:
"Friends of the Earth directed us to evidence from the United States that 'found failure rates in newly-drilled shale gas wells in Pennsylvania to be between 6.9% and 8.9%'"
Are FoE really the best data source for information on well integrity? Why does the EAC not use instead the paper by Davies et al. on the subject, for example. The EAC statement is in error. Well failure, implying total loss of well control and release of hydrocarbons to the environment, is a very different thing to individual barrier issues (containment maintained and no pollution indicated). Well failure rates occur at rates that are "two to three orders of magnitude lower" than the rates cited by the EAC. For more discussion on this, see my post here.

6. The EAC cites evidence provided by Caroline Raffan:
"her 'greatest worry is that water contamination will get worse over time as wells develop concrete failures, and the methane escapes into the water table and also into the environment.'"
Ms Raffan's full statement is available here. I will leave it to the reader to decide whether this is the sort of robust, well referenced expert evidence that should be quoted prominently in a Select Committee report.

7. Public Health England have concluded that the risks posed by shale gas extraction in the UK are low. However, the EAC counter this conclusion with evidence from a local doctor and "UK Green MEPs". It is worth noting that the PHE report covers and examines in detail almost all of the references cited by Dr Rugman. Public Health England are the national authority on this matter. It is therefore surprising indeed that the EAC would place more weight on the conclusions of a local resident (even if he is a doctor), rather than PHE, given that both appear to have studied the same literature sources!

Staying on this subject, the EAC cites "local surveys" conducted by Philip Mitchell, who appears to be a local resident, with no apparent relevant expertise. His submitted evidence is available here. You will note that the evidence provides no actual data, nor even details of how his "survey" was carried out. This is not exactly science here, just a few anecdotes of people claiming that their asthma has been made worse by Cuadrilla's activities at Preese Hall in 2011. As an aside, I am an asthma sufferer myself, and I know that my symptoms are often varying, sometimes very light, sometimes quite bad. Were I of a more suggestive mindset, I am sure I could find all manner of potential "causes" that might happen to correlate with changes in my symptoms. Yet this is deemed worthy of consideration in a Commons Select Committee report!

My assessment is that the EAC went into this process knowing already what it wanted to find. This is apparent from the very short length of time taken to produce the report (less than 6 working days from the oral evidence session). In order to reach the "desired" conclusion, it ignored evidence submitted by those who would be considered by most to be experts in the relevant fields, and instead relies heavily on evidence provided by anti-fracking activist groups. In my opinion, this is not an impressive piece of work. It would appear that my opinion is shared in a number of other comments on the report (link, linklink). It will be interesting to read the government response to the report.

Update (28.1.2015):
Courtesy of @CSWnews, via my brother, this seems relevant:

Wednesday, 7 January 2015

More misleading leaflets from anti-fracking groups

In the news today, another anti-fracking group, Resident's Action on Fylde Fracking, has been forced to withdraw its literature due to inaccuracies, misleading comments and unsubstantiated statements. This follows a similar ASA ruling last year in Somerset, and from the equivalent body in Australia. This incident has been reported in The Times (£) and Independent.

Full details of the complaint and the ASA's draft judgement are not available. This is because, rather than face a final judgement, RAFF agreed to withdraw the offending leaflet. In such cases, where the advertiser withdraws the material, the ASA will cease it's investigation, since the likely decision would be to force the advertiser to take these actions anyway.

Most amusing is RAFF's attempts to put a positive spin on the decision. They appear to make the claim that the leaflet "was therefore NOT withdrawn as a result of Mr Roberts’ complaint". However, comments from the ASA make clear that that's exactly what has happened: ASA comments are reported as: "The ASA was carefully assessing evidence from both sides. They had not come to any conclusion… They (RAFF) withdrew the leaflet before a final decision was made." Further, it appears that RAFF were required to provide assurance to the ASA that the leaflet would not be repeated or re-distributed.

Friday, 21 November 2014

Statement from the European Academies Science Advisory Council

This week the European Academies Science Advisory Council released a statement on shale gas in Europe. EASAC is formed from the national science academies of EU member states. You can read the full statement here, and an executive summary here

A spokesman for EASAC stated:
"While there is no scientific or technical reason to ban hydraulic fracturing, there are clear rules to be followed: Companies must work harder to obtain societal approval to operate, by engaging stakeholders in constructive dialogue and working towards agreed outcomes. Trust is critically important for public acceptance; requiring openness, a credible regulatory system and effective monitoring. Data on additives used and the results of monitoring to detect any water contamination or leakages of gas before, during and after shale gas operations should be submitted to the appropriate regulator and be accessible for the affected communities. The same openness to discuss on the basis of factual evidence must, however, also be expected from the other stakeholders." 
Key passages in the statement include the following:

  • This EASAC analysis provides no basis for a ban on shale gas exploration or extraction using hydraulic fracturing on scientific and technical grounds, although EASAC supports calls for effective regulations in the health, safety and environment fields highlighted by other science and engineering academies and in this statement. In particular, EASAC notes that many of the conflicts with communities and land use encountered in earlier drilling and hydraulic fracturing operations based on many single-hole wells have been substantially reduced by more modern technologies based on multiple well pads, which can drain up to 10 km2 or more of gas-bearing shale from a single pad. Other best practices, such as recycling of flow-back fluid and replacement of potentially harmful additives, have greatly reduced the environmental footprint of ‘fracking’. Europe’s regulatory systems and experience of conventional gas extraction already provide an appropriate framework for minimising disturbance and impacts on health, safety and the environment.
  • Overall, in Europe more than 1000 horizontal wells and several thousand hydraulic fracturing jobs have been executed in recent decades. None of these operations are known to have resulted in safety or environmental problems.
  • Regulations intended to ensure safe and environmentally sensitive drilling activities are already in force in those European countries with their own oil and gas industry.
  • The reservoir volume accessed from a single site has increased substantially through such multi-well pads and longer horizontal laterals, offering a potential extraction area of 10 km2 or more from one pad and reducing surface land use area accordingly. Unconventional gas fields thus no longer have significantly higher well pad densities than conventional fields. Technically, horizontal wells with a reach of up to 12 km are possible (although such wells would at present be uneconomic), but even with clusters of only 3 km radius, it becomes viable
  • to produce unconventional gas in heavily populated areas.
  • A recent meta-analysis (Heath et al. 2014) of the scientific publications on this issue [shale gas and CO2 emissions] came to two conclusions: (1) that emissions from shale gas extraction are similar to those from conventional gas extraction and (2) that both when used in power generation would probably emit less than half the CO2 emissions of coal.
  • Regarding potential sources of emissions from shale gas extraction, flaring and venting in conventional exploitation in Europe ceased during the 1990s (with the exception of initial flow tests in successful exploratory drilling); industry therefore possesses the necessary expertise to avoid this problem. ‘Green’ completion technologies are also widely used to capture and then sell (rather than vent or flare) methane and other gases emitted from flow-back water (they can be recovered at low cost by taking out the gas within a confined separator). This will be mandatory for hydraulic fracturing of all gas wells in the USA from 2015 onwards. Ensuring ‘green completion’ is fully applied in Europe is thus an essential prerequisite for maximising benefits from shale gas to climate change policies.
  • General industry practice in conventional wells (which typically have higher pressures and gas flow rates and longer lifetimes than shale gas wells) has solved the problems of gas migration. By pressure testing, the tightness of the well can be verified. Hydraulic fracturing also uses external casing packers to separate individual fracked zones from each other, creating mechanical barriers in the lowermost part of the well against gas migration outside of the casing.
Finally, I can only conclude that the EASAC are avid readers of Frackland, as they illustrate how lateral well drilling allows a substantial reduction of the surface footprint, as I have done numerous times on this blog. 
Figure 2 Innovation in well design and operation (source: Range Resources Ltd.). Left: old single well spacing (Texas); right: modern multi-well cluster configuration accessing gas from an area of up to 10 km2 (Pennsylvania).

Saturday, 1 November 2014

Image of the Day: Reclaimed Well Pads

A question I am often asked is what does a shale gas well pad look like. The answer can depend, because a pad will change over time. During operations, there will be lots of equipment on the pad, and it won't look particularly nice. However, well construction typically takes a few months, and once complete most of the infrastructure can be removed. Once this is done, much of the pad can be reclaimed and restored.

Of course, the pad in full action is the most dramatic, so this is what the media likes to show. This leaves people with the impression that a shale gas pad will always look that way, not that it's like this for a few months before being restored. 

To address this balance, here are a couple of images of well pads during construction, and then what they look like when finished. 

Firstly, this under-over image shows a pad with a single well being flow-tested, with the gas being flared, and then the same well once the pad has been reclaimed and restored. 

This next image shows a multi-well pad with a drilling rig on site. You can also see open flowback ponds storing water. It's not clear whether this is fresh water yet to be used, or waste flowback water. In the UK flowback water cannot be stored like this.

Underneath shows the same site once it has been completed. Most of the pad is grassed over, with only a small amount of infrastructure left on the pad.

Friday, 24 October 2014

Sigmas and Sharpshooters

Today's paper is a recent report published in the journal "Earth's Future" looking at methane emissions from shale gas operations in the USA. As you'd expect from a paper that is critical about shale gas exploration, it has received extensive media coverage.

However, the paper falls short in a couple of really important ways, which I'll discuss below. Sadly, it provides a few handy lessons about how not to go about doing science. The first issue is falling foul of the Texas Sharpshooter Fallacy, the second is failing to use the proper measures to ensure the result is statistically significant.

Firstly, the Texas Sharpshooter Fallacy. The parable is of a hopeless Texan gunman looking to prove to the world his martial prowess. So he takes aim with his pistol at the side of a barn, and blasts away. Once he has done shooting, he notices that by chance some of his shots happen to have hit close together. He then paints on a target with its bullseye at that point, before inviting the neighbours over to admire the results of his sharpshooting skills.

More technically, this fallacy describes a situation where certain clusters of data are cherry picked from a larger population because they happen to fit your hypothesis, ignoring all the cases that would disprove the hypothesis.

So how does this fallacy apply to the paper in question? The image below shows the methane measurements for 2006-2008 (the "before" case) and 2009-2011 (the "after" case) presented in the paper:

It's clear that methane has gone up substantially all across the USA in this period. There are many sources of methane emissions, both naturally occurring (bogs, swamps etc) and man made (farms, coal mines, conventional gas wells, and shale wells). What is noticeable is that while there are places where there is shale gas activity and high methane concentrations, there are plenty of places with no oil and gas activity that have seen methane levels rise, while in other places there is shale gas activity but methane levels that are not particularly relevant.

For example, Nebraska saw substantial increases in methane, yet in 2010 there were only 2 drilling rigs in the entire state. It's a similar story in, for example, Iowa (0 drilling rigs), Illinois (2 drilling rigs) and Indiana (3 drilling rigs). In contrast, Arkansas, home of the Fayetteville shale with 39 active rigs in 2010, and Northwestern Louisiana, home of the Haynesville shale with 135 active rigs in 2010, have noticeably low methane concentrations.

There are many different shale gas/oil plays across the USA. It is apparent that methane concentrations also vary across the USA. It is therefore inevitable that, just by chance, some areas of high methane will correlate with areas of shale production. Our sharpshooters have drawn their targets around 3 such areas (the black boxes in the above image) and declared themselves to be expert marksmen. Not good science.

We can see the same effect within the individual study areas as well. The following image shows the change in methane levels for Texas from 2006-2008 to 2009-2011:

During this time, there was active drilling and unconventional hydrocarbon production from the West Texas Permian Basin, the Haynesville Shale and the Eagle Ford Shale. Neither the Permian nor the Haynesville show anything out of the ordinary, while there are other areas with no active drilling that have seen substantial methane increases. It's a similar story for the Marcellus in Pennslyvania, shown below: there are places with drilling that have high methane levels, but also places with drilling that have low measurements, and places with high measurements that do not have drilling.

The second issue is one of error bars and confidence intervals. With any scientific measurement, there is an error bar marking the interval over which we can be confident the result is accurate. Typically, confidence limits of 95% are used - if it is said that a measurement is 5 ± 1.5 at a 95% level, then we can be 95% confident that the true value lies somewhere between 3.5 and 6.5.

The authors of this paper complete their analysis for the Bakken and Eagle Ford shales, concluding that methane emissions have increased by 990 ± 650 ktCH4/yr and 530 ± 330 ktCH4/yr in each case.

What is unusual, however, is the limits they have chosen for their error bars. These are set to the 1-σ level, or one standard deviation. This corresponds to a confidence interval of only 68%, meaning there is a 1-in-3 chance that the computed value was arrived at by chance.

Scientists generally use the 2-sigma level as an error bound - corresponding to a 95% confidence level in the result (which still means that the measured observations could have occurred by pure chance 1 time in 20). For really important experiments, scientists will require even higher confidence bounds, like the 5-sigma bound for the Higgs Boson discovery, which means a 1 in 3,500,000 chance of a spurious result.

I've not often seen a confidence level of 1-sigma being used in peer reviewed science, given the implication of a 1-in-3 chance of being a spurious result. Instead, let us double their confidence levels to the 2-sigma limit (95%) more normally expected as a minimum for scientific findings. We then find the results have become 990 ± 1300 ktCH4/yr and 530 ± 660 ktCH4/yr. In both cases the error bars have become larger than the values themselves. We cannot even be sure whether rates of methane emissions have increased or decreased, since the lower error bars at the 95% level fall below zero.

In short, even with the Texas-Sharpshooting described above, the authors have not managed to produce statistically robust evidence to back up their claims. However, it's given me a chance to discuss both the Texas Sharpshooter Fallacy (which is also a common problem in attempts to forecast earthquakes) and the importance of error bars, which I am sure both scientific and non-scientific readers alike will have enjoyed.

Wednesday, 22 October 2014

Europe's Geological Surveys Make Joint Statement on Shale Gas

After a meeting in Copenhagen, the North Atlantic Group of the European Geological Surveys released a statement on shale gas and fracking. More info is available here.

This group is made up of the Geological Surveys of the UK, Germany, Ireland, Holland, Norway, Iceland and Denmark, so it represents most of Europe's geological expertise. Make no mistake, these guys are experts.

Below are a choice selection of quotes both from their Copenhagen statement, as well as comments from the President of Germany's Federal Institute for Geosciences (the BGR) in a press release. The press release is in German, so I have used google to translate as best I can. Apologies to any German speakers who spot any mis-translations, but the general gist of the statements should be clear to all.

Firstly from the Copenhagen Statement:

"The Survey Directors are concerned that frequent misleading media messages regarding exploration and exploitation of raw materials and geo-energy have the potential to obscure scientific results and conclusions, and may ultimately lead to poor decisions for Society."
"The Survey Directors emphasise that their Surveys hold the majority of key sub-surface data for their Nations. They are thus best placed to objectively and independently inform decision makers, on shale and other georesource estimation exercises, and on some of the potential environmental risks of the operations."

"Particular concern was expressed that the role of the national Geological Survey may be bypassed, resulting in the submission of poorly formulated geoscientific advice to governments."
The press release from the BGR was even more explicit:
"The European Geological Surveys of the North Atlantic area, which include the Federal Institute for Geosciences and Natural Resources (BGR), fear in the face of misleading reports in the media about the exploration and extraction of raw materials negative socio-political consequences."
"Often dangers are evoked where there are none. When fracking for production of natural gas there are widespread fears in the population, most of which are unfounded from geoscientific perspective."
"Since the early 1960s, more than 320 fracking measures in conventional natural gas production have been carried out in Lower Saxony. The technique used here is similar to the method for the development of shale gas resources. In these past operations by fracking there has not been a single incident in which the environment has been damaged. When critics speak in connection with fracking as an uncontrollable high-risk technology, this is just wrong under scientific criteria." (my emphasis)
I think these comments will be worth remembering as the shale gas debate rumbles on over the coming months.

Tuesday, 14 October 2014

Does the infrastructure bill give carte blanche to inject any substance an operator chooses?

Today's fuss is over the infrastructure bill currently going through parliament. The purpose of this bill is to reduce the amount of time spent in court arguing over subsurface access rights and trespass issues.

However, anti-fracking activists have today tried to claim that the bill is an attempt to subvert existing regulation, allowing operators to inject whatever fluid they want without any safeguards. The Guardian has some typically scaremongering coverage here.

Greenpeace are claiming that
"Ministers are effectively trying to absolve fracking firms from responsibility for whatever mess they’ll end up leaving underground"
while Friends of the Earth claim that
"The government appears to be trying to sneak through an amendment which would allow fracking firms to reinject their waste under people’s homes and businesses" 
Are they right? Of course not.

Saturday, 11 October 2014

Advertising Complaints in Australia

A few months ago I blogged about Frack Free Somerset (FFS)'s decision not to challenge a complaint about their promotional material made to the Advertising Standards Agency (ASA). Their leaflet contained numerous errors and misleading statements. Because FFS agreed to remove their material and cease using it, rather than to attempt to offer a rebuttal, the ASA never carried out an investigation.

There are obvious parallels to the complaint made to the ASA over Cuadrilla's publicity material, and over an advert placed by the self-styled "Frack-Master" Chris Faulkner.

We in the UK are not the only country to provide an advertising regulator, and in this post I will report on a decision reached by the Publishing Advertisers Bureau in Australia.

Before I do so, however, I want to comment on the situation we now find ourselves in, where advertising standards agencies are finding themselves having to make judgements on what are, in some cases, quite complicated and technical issues, with very little understanding of the subject matter. I very much doubt that anyone at the ASA has any familiarity with oil and gas operations and/or regulation.

While I am sure that the ASA are used to dealing with complaints in subject areas they are not familiar with, I would suggest that this debate is very different to determining whether or not a new brand of shampoo really makes your hair feel 10 times silkier. Yet as an authoritative body it is inevitable that their pronouncements are taken very seriously indeed, when the more I think about it, the less reason I see to do so. Frack-Master Chris Faulkner summed the situation up: "the ASA has been both judge and jury in this case. They appear to have become unqualified experts in fracking and interpreting the complex issues surrounding fracking in the UK".

However, today's blog is about a decision in Australia. The opposition group Frack Free Geraldton (FFG), with support of the Conservation Council of Western Australia (CCWA), published an advert in the local rag, the Geraldton Guardian. The Australian Petroleum Production and Exploration Association (APPEA) submitted a compliant regarding the advert, which appears to have been upheld. In each case, the statements made by FFG and CCWA were found to be misleading and deceptive.

The statements, and the reasons for the findings, are discussed below.

"Shale fracking, the process of extracting gas by using toxic chemicals to crack deep rocks, can turn our water into a dangerous chemical cocktail"

It was found that this statement gives a misleading impression of the fracturing process, because it gives the impression that most of the fracking fluid is composed of toxic chemicals. It was found that "The statement that 'toxic chemicals' are used to crack deep rocks creates the impression that toxic chemicals 'alone', certainly not in such small percentage quantities are used to frack", which is not the case: frack fluid is 99% water, with only a small amount of additive, most or all of which is not toxic.

The statement finds that "to an ordinary reasonable reader the words of the advertisement and the accompanying illustration together create the impression that the amount of 'toxic chemical' used is a much greater concentration that is in fact the case", which is a misleading and deceptive exaggeration.

With regards to turning water into "a dangerous chemical cocktail", it was found that while there are risks posed by hydraulic fracturing, "the consensus of scientific data suggests that there have been no cases internationally of hydraulic shale gas fracturing inadvertently breaching a water source and thereby causing contamination", and that "a combination of research from around the world shows us that the risks are low".

Moreover, in their response to the complaint, CCWA "have not produced any evidence that hydraulic fracking fluid has in the course of any hydraulic shale gas fracking process permeated a fresh water aquifer. Its contentions are against the scientific literature".

"Research in the US has found that 6% of fracking wells leak into ground water in the first year"

Anyone who is familiar with this blog will already know why this statement is misleading. It is a topic I have discussed extensively. The 6% statistics refer to the number of wells that have some kind of casing or cement issue in one of the casing strings. However, wells have several casing strings to separate the production zone from any sensitive groundwater supplies. This means that a well with an issue in one casing string will not be spewing hydrocarbons into the environment. It's a belt-and-braces type approach.

A paper by King and King in 2013 (SPE) is instructive in this regard:
For US wells, while individual barrier failures (containment maintained and no pollution indicated) in a specific well group may range from very low to several percent (depending on geographical area, operator, era, well type and maintenance quality), actual well integrity failures are very rare. Well integrity failure is where all barriers fail and a leak is possible. True well integrity failure rates are two to three orders of magnitude lower than single barrier failure rates.
In their response, the CCWA admit that their statement "is not materially correct", and it is therefore found to be "misleading and deceptive".

This is a point I've been making for some time, so it's good to see that even environmental bodies know that it is not correct to say that 6% (or 30% or 50% or whatever) of wells are leaking, even if they do still insist on claiming this in their promotional material.

"Once our water is contaminated, it will be forever" 

This statement ignores the abundant evidence that while any contamination incident is bad, the damage is rarely permanent: wells that do leak can be repaired, spills can be remediated. For example, Considine et al. (2013) examine the environmental impacts from drilling in Pennsylvania, and find 25 incidents that they deem to be "serious". However, they find that in all but 6 cases the impacts had already been remediated satisfactorily. The APPEA provided similar examples of remediation in their supporting evidence for their complaint.

In contrast, "the contentions put forward by CCWA in support of this statement in its submission dated 22 August 2014 are without any independent scientific support. They are unsupported assertions." 

As a result, it was found that "the statement that once contaminated water will forever be contaminated is not supported by contemporary scientific views and is misleading and deceptive." 

For anyone interested in the original complaint, the CCWA rebuttal and the final decision, the documents are available below.

The original APPEA complaint is here.
The CCWA response is here.
Further APPEA comments are here.
The final decision is here.