Tuesday, 27 May 2014

A "hasty dash to frack"?

On the whole I've given up writing critiques of articles discussing fracking in the media written by journalists. There's not enough hours in the day, and more importantly, sensationalism - selling papers - is what journalism is all about. You might as well criticise a dog for barking.

However, it's a different story when it's academics writing for the media. The extra respect that members of the public afford to academics means that there is an added responsibility to be accurate. Which brings me on to this article in the Birmingham Post, written by Professor Alister Scott of Birmingham City University, described as "thoughtful" by a senior BBC environmental correspondent.

The first few paragraphs discuss the general discord in the government's energy policy, and I would agree that our energy policy is currently a mess. However, the problems begin when Prof Scott argues that "they have rejected any new EU Directive that would look specifically at issues from the fracking process not covered by existing legislation such as cumulative impact, underground risk assessments, chemical mixes and methane emissions".

It is true that the EU decided to release a Recommendation rather than a Directive. It is however incorrect to claim that the Recommendation has no impact on the activities of operators in the EU. This recommendation mandates a range of measures, including a wide range of environmental factors that operators must assess before, during and after their activities. Member states must inform the EU Commission of measures that they have put in place to meet the requirements of the recommendation.

These measures will be reviewed in 18 months, and if the commission deems that the terms of the recommendation are not being met then they reserve the power to impose legally binding rules at the European level (paragraphs 16.1-16.4). This is hardly the lack of regulation implied by Prof Scott. I'll note in passing that disclosure of the "chemical mix" is required by the Environment Agency.

In his next sentence, Prof Scott claims that "They have even gone further to say that some environmental safeguards should be reduced due the complex burden of permissions and licenses". I'd love to know what environmental safeguards Prof Scott thinks have been reduced? There are moves to reduce the amount of time taken to get permits, and to improve coordination between the various agencies involved (DECC, Local Minerals Planning, EA, HSE). There has been absolutely no move to reduce the environmental safeguards expected during drilling and hydraulic stimulation.

Prof Scott argues that "We need evidence-based policy and we have seen a debate that is more akin to a pantomime. The debate becomes stuck in a groundhog day mentality becoming sterile and increasingly polarised". I'd love to know what Prof Scott thinks is more inductive to "pantomime" debate: reports by the Royal Society, by Public Health England, by the Institute of Directors? Or this?

The renewables industry has long offered payments to local communities to persuade them to accept wind and/or solar farms in their area. However, when shale gas companies offer something similar, "The rush to provide incentives to people and communities affected by fracking is troublesome in social and environmental justice terms". That said, I do agree with the thought that the expectation that shale operators make community payments when industrial developments with a far greater impact - coal mining, large facilities etc - do not could be seen as unfair.

The next claim is that "continual government attacks on environmental safeguards as restricting development encircle the fracking debate". Again, I'd love to know what these attacks on safeguards are? Yes, there is the intention to streamline to permitting process and to improve coordination between agencies. The has been no suggestion of any reduction in any existing environmental safeguard that applies to drilling and/or to hydraulic fracturing.

The fact that "government ministers are quick to condemn 'unsightly' solar and wind turbine developments, but seemingly embrace landscapes of fracking infrastructure" may well be because of the very different scales of impact the two industries have, when measured on a per MWh basis. A single multi-lateral well pad, which might look something like this when completed, will produce as much energy as the entire Scout Moor wind farm, which looks like this

I can sympathise that the level of public engagement has perhaps not been what it might be. I'm not sure how mis-informed articles by academics in the media are supposed to improve this. However, there is already abundant "independent scientific evidence", if one cares to look for it, while every kind of measurement possible is being made around putative drilling sites to ensure "effective safeguards for the public and the environment and effective monitoring arrangements". Cuadrilla's Environmental Impact Report for their two new sites in Lancashire will run to over 3,000 pages. Given Prof Scott's concerns, I am sure he will read every page. 

Prof Scott's conclusion is that we're seeing a "hasty dash to frack". The prospects for shale gas in the UK were first realised in the late 2000s, and Cuadrilla drilled and tracked their well in 2011 - still the only onshore well where fracking has been used in shale rocks (as opposed to fracking in conventional reservoirs, which has been done approximately 200 times onshore in the UK). Since then, we've seen about 5 exploration wells drilled, and the first intention to frack a well submitted by Cuadrilla, where stimulation will probably take place in 2015, once the 3,000 environmental assessment has been completed. 

Meanwhile, in the USA thousands of wells will have been drilled and fracked. Meanwhile, other countries with shale potential are making solid progress, and drilling and fracking multiple wells. Argentina, China and Poland spring to mind. If 5 wells drilled and one fracked in 4 years represents "a hasty dash to frack" to Prof Scott, I'd hate to see what slow progress looks like.  


  1. The "hasty dash to frack" aka the so-called "dash for gas" is more of a gentle stroll IMHO! The amount of regulator scrutiny to which shale gas is being subjected coupled with the sheer number of studies (RA/RAE, PHE, HoL etc) must surely demonstrate that it's being done in our inimitable, thoughtful and very British way. In many ways, it's a lot like new nuclear which also seems to be languishing in the long grass somewhere - despite the CO2 reductions this could deliver in electricity generation. It sure is a muddle, but it ain't a dash.

  2. Thank you for your comments. I actually do value the points you make. 
    My focus was on tne way government was constructing its fracking policy and that process made me feel very uncomfortable. That was my motivation for the blog. Your scientific expertise is welcome and I have no ability nor  desire to question that aspect of your arguments. However I am pleased to respond to your critique taking each of your points in turn. 

    1 The  EU recommendation vs directive. You are correct in the way  the recommendation works but the uk government made clear it's opposition to an EU directive. It stated that existing legislation was satisfactory. I dispute this line of argument and favour a directive on fracking as supported by many other states. 

    2 the relaxing of environmental safeguards is a common theme in many government pronouncements. For example the motivation for a government review of NATURA2000 was based on the presumption that such designations restrict economic growth. Thus my comments were predicated on the way the government have  stated that the environment is the enemy of enterprise and this leads to a culture of trying to fast track existing regulations as they, in theory, can be trumped by the national interest where relevant.  

    3 You are quite correct in the positive assessment of some scientific reports such as the Royal Society. Point taken. However recent reports from the  US EIA confirm the huge hype of the estimated reserves of gas present. The main Californian field has had estimates revised down by 96% which suggests that we must question seriously how estimates are made. What worries me is that our government have moved before we have accurate assessments of capacity and, crucially a coherent energy policy which means we lurch from one energy source to the other at the whim of political opportunism. This is not the way to make policy. 

    4 The pantomime I refer to is based on the  way government claim that any opposition to fracking is irrational or even Trotskyist. Here the argument becomes reduced to the view that you are mad to oppose fracking. My point is that people do have legitimate concerns and these demand respect not ridicule. So as you have started let the arguments win the day; not ridicule or incentives to keep opposition muted. Of particular relevance here are the points I make about cumulative impact, underground risk assessments and methane release which are not covered satisfactorily by current legislation. 

  3. 5 My point on solar vs wind farms was based on the ad hoc statements ministers were making on impacts of wind farms and solar farms. There were clear differences of opinion given but based on no objective landscape assessment methodologies which I do have some experience with. Furthermore cumulative impact assessment is relevant as where significant reserves exist wells and fracking infrastructure will be in close proximity. The Texas landscape shows this in extremis http://commonsensecanadian.ca/birds-eye-view-texas-fracking-causes-rumble/

    6 The  issue of public involvement is a topic close to my heart. Here quantity of consultation document does not equal quality; how can anyone realistically including me carefully read a 3000 page report. Here the quantity serves to do nothing more than obfuscate the evidence and actually restrict the public debate. We need to have a proper debate over fracking and as required by the Aarhus Convention to enable the public to be able to express a voice. This means we do need better more publicly accessible information. This goes back to how the government consults. It's starting point that any opposition to fracking is irrational to me is not really the way to have any meaningful debate. Furthermore,  to have a Lords Committee produce an independent report with members involved standing to benefit from successful exploitation of shale gas/oil, is not helping their cause. 

    7 The point I make about haste  in the dash to frack was more on how this government moved from one energy source to another. My perception was based on seeing its impact in America and wanting a piece of that action. The policy making  model in my view is broken. see our recent work here www.eatme-tree.org.uk. 

    8 The national interest point emerging from government statements and reports also means that the planning case will be taken out of local authority hands to be determined by the planning inspectorate. Now the problem then is that government and the PM have said that case for fracking is clear and any opposition is irrational. Thus any public inquiry is being played with loaded dice. 

    I hope this response alleviates some of your concerns. Thank you for starting a conversation. 

    1. Hi Alister,

      I agree, always good to talk.

      However, I must immediately address a significant concern I have of your reply. You have linked to a picture claiming to show the cumulative landscape impact of shale gas drilling. However, the picture you link to is in fact the Mexia-Groesbeck oil field, first drilled in the 1920s. Modern shale developments look nothing like this. With extended reach lateral wells, pads are spaced 5-6km apart, using horizontal wells to reach the rocks in between.

      So when even respected academics are linking to pictures of things that are. not. shale. gas. developments. in order to decry the visual impact of shale gas development, it's difficult not to conclude that there is an element of irrationality in the debate, even at the higher levels.

      In the spirit of honest conversation I expect you to retract this particular link/claim, and I suggest you find a way to communicate with those who are more familiar with the industry to avoid these errors going forward.

      Of course there are some valid concerns to be addressed for local people around potential developments. I don't think anyone has tried to deny that - even government if you read what they say carefully (hence the realisation that a community benefits package is appropriate). I would draw a line between the average resident new to fracking who is concerned about new development, and some of the groups that have set up that I'm sure you're well aware of.

      A huge part of this opposition, and particularly the most vocal part of it, are making claims that cannot be backed up with evidence or reason, which is how I would define irrationality.

      As mentioned by the previous commenter, when challenged by an ASA complaint, Frack Free Somerset were unable to justify or provide evidence for a single one of their claims.

      We've seen local councillors object to fracking on the grounds that it could trigger a volcano in the Mendips (http://www.wellsjournal.co.uk/sitting-Mendip-volcano-says-Somerset-expert/story-14010082-detail/story.html). We see opponents linking fracking to a conspiracy involving "chemtrails" (some of the people advancing this argument have featured regularly on mainstream media opposing fracking). One of the UK's most prominent anti-fracking activists seems to believe that fracking is part of a conspiracy to wipe out the human race by the "Enlillian mafia".

      I agree that some of the government's rhetoric is as likely to alienate as to encourage. However, a huge amount of what is coming from the opposition side simply is irrational, and deserving of ridicule. If this needed any further confirmation, it's got to the point where knowledgable academics can in all seriousness link to an oilfield drilled in the 1920s to argue about the impacts of shale gas development.

    2. Some other comments:

      1: I would argue that existing UK regulations are sufficient - we've successfully regulated the oil and gas industry on- and offshore in the UK for quite some time. The recommendation is in my mind the correct way to go at this stage - let's see if existing regulation can meet the terms of the recommendation. If not, the option of binding regulation is still on the table for you, so you've not lost anything. I would consider this a measured way to approach the issue, rather than demanding immediate regulation (much of which would (and does in the recommendation) overlap with existing rules.

      2: Maybe the government is relaxing safeguards in other areas. That is not of concern to me - I am interested in shale gas, and your article was specifically about shale gas. Your original post claims that gov is looking to reduce environmental safeguards for shale gas exploration are being reduced. Please detail what safeguards are being reduced, otherwise your comment, which underpinned much of your original post, is baseless.

      3. Yes, the Monterrey shale recoverable resource estimate has been downgraded. That doesn't mean that the oil is not there. There's exactly as many bbls of oil there today as there were yesterday. However, all shales respond to hydraulic stimulation differently, and not all rocks fracture very well (sometimes rocks are too ductile and do not fracture). This appears to be the case for the Monterrey. It's not that the oil isn't there, it's proving harder to get out.

      FWIW, the EIA has underestimated recoverable resource in every other major shale play in the USA.

      I agree that the Bowland estimates have huge uncertainty - these early estimates always do. However, if they're even halfway right these are really significant numbers! And if they're wrong and Cuadrilla et al aren't able to get anything out? We'll never move beyond the exploration phase, so no need to worry about planning issues etc, and the only people to lose are those who have invested in the operating companies (and who really cares about them). It's a win-win situation surely?

    3. 5. I do agree that some of the statements made by ministers regarding renewables are perhaps less than helpful. Especially because what is being said and what is actually happening don't necessarily match. We still have subsidies for renewable energy, even if parts of our government don't seem to like it very much. In terms of cumulative impact, I think you are putting the cart before the horse. At present the operators want to drill a small number of wells around the country to see whether the gas will flow, and where any "sweet spots" might be. Once that has been ascertained, they will begin to plan what they might wish to do in terms of full-scale production. Only at that point, when we know exactly what is planned, can we begin to look seriously at potential cumulative impacts. This is exactly why we do not have a "dash to frack" - you do the exploration phase first, then you plan for the production phase afterwards.

      6. I agree that public involvement could be better, especially from the government side of things. That said, current proposals for changes to the trespass law are currently out for consultation. I think the operators initially did a poor job of this as well, but have now realised the importance and are raising their game. The 3,000 page report isn't meant for public consumption as such, but it shows that operators are taking their responsibilities to the environment seriously. I guess the question is where the responsibility lies wrt public consultation, government or the operators?

      7&8. I know that certain gov ministers have had the occasional outburst about shale, I'm not sure what major policy changes have really been made that represents "moving from one energy source to another". The tax break is the same applied to any other "challenging" hydrocarbon field at an early stage of development. DECC imposed a moratorium for 2 years, and then imposed more rigorous seismic monitoring requirements. The EU introduced a Recommendation. The change to trespass laws is the first major development that could really be described as "pro-shale". That said, I am obviously less familiar than you in terms of the intricacies of planning law, so if there have been significant changes in this regard (or if the various government utterances have an impact here) then I'd be happy for you to expand on this.

      I'd be very interested to hear your thought's on Dart Energy's planning inquiry in Falkirk, for example? Is that inquiry being played with loaded dice?

    4. For the record I quickly linked to a photo of fracking from a web source. A mistake and I did not check that link. Lazy and careless so you are spot on there. I appreciate as an academic I need to be more careful in using such information.

  4. I started to become informed on the fracking debate when I saw protests about shale gas fracking centred around an oil well in a limestone formation that had no plans for fracking. (Balcombe). On point 4, the opposition movement is at times ridiculous. That is why I sent a series of complaints to the ASA about anti frack literature. Here are some of the 'legitimate' concerns of the public.
    Use of 'toxic' hydrochloric acid. Used for decades and is sold as patio cleaner, but it will pollute the land for generations....
    Use of sealed radioactive logging sources. Standard oilfield practice. Very controlled, licensed, and believed to 'poison' wells.
    Fear of earthquakes that has no basis in science.
    Fear that chemicals would enter aquifers, when there is no science to support that.
    Deliberate misrepresentation of well leak concerns, when this is a very minor and fixable problem.
    Water shortage scares that do not exist for the vast bulk of the country.
    Imported fears that secrecy will cover up problems when everything has to be declared, and only non hazardous usage of chemicals is permitted.

    The map for planning applications is amazingly complicated and JV's comments say it all. There is plenty of research, regulation, and involvement with the public, and this is a well established science. I can understand the frustration of the Govt when there is so little movement and the opposition is based upon milking of non existent fears by those against the development of this available 24/7 energy source. Wind of course is not available and we cannot store large amounts of energy.

  5. My entry into fracking was like KW, based on the silly hype over the mammoth earthquakes in the Fylde in 2011 (1.5 and 2.3), inaccurate dealing with fracking by Greenpeace, FoE, Green Party (e.g. a Green Party leaflet in Lancaster in 2012 referring to danger of quakes) and local fractivists. I also went to meetings by Frackoff and local groups. The more I delved the more dissimulation by fractivists I found. I have yet to find a reasoned and evidenced opposition to fracking. However the fractivists have been effective in kidding people

  6. 1. Are Regulations Sufficient
    I approach this issue from a precautionary principle. Thus from the existing suite of regulations affecting oil and gas industry there has been identified a series of shortcomings as I stated in my first post: underground risk assessments, methane emissions, cumulative impact. My source for this is the 2012 report to the European Commission DG Environment http://ec.europa.eu/environment/integration/energy/pdf/fracking%20study.pdf
    In my mind it makes sense to look at the environment and health issues that fracking raises and have regulatory interventions/procedures that deal collectively with this. Hence a directive fulfils that role as as seen by the Water Framework Directive subsidiarity, partnership working and collaboration can be essential parts of that. It was significant that the UK lobbied to have the favoured EU Directive rejected in favour of a reduced and weakened Recommendation which is not legally binding for member states. Yes there is a prospect of further interventions but that equally plays out on a political stage. Why start with a compromise that weakens the regulatory environment within which fracking decisions take place?
    The further dimension to this is that many of the environmental safeguards as secured through EIA procedures have been seriously critiqued in terms of their efficacy and objectivity given that EIAs are undertaken by consultants under the employ of the developers themselves. Barker and Jones 2013 highlight the varying performance of 35 Environmental Statements across the oil and gas sector. This builds on the conclusions of Glasson et al 2005 p340 who identify the following weaknesses in process.
    “ • has a non-existent or weak follow-up process, lacking surveillance and enforcement of
    terms and conditions, effects monitoring, etc.;
    • does not consider cumulative effects or social, health and risk factors;
    • makes little or no reference to the public, or consultation is perfunctory, substandard
    and takes no account of the specific requirements of affected groups;
    • results in EA reports that are voluminous, poorly organized and descriptive technical
    • provides information that is unhelpful or irrelevant to decision-making;
    • is inefficient, time consuming and costly in relation to the benefits delivered; and
    • understates and insufficiently mitigates environmental impacts and loses credibility”
    More contemporary critiques highlight the same problems; see my Scott et al 2013 p42 assessment http://www.sciencedirect.com/science/article/pii/S0305900613000214

    1. 2. Is Government reducing environmental safeguards
      My post was on the way government energy policy is being developed. The first point was that it was not coherent in any way and there was an energy policy vacuum which enabled lurches (not dashes actually; ironically not even my own title to the piece) from one favoured energy source without any clear strategy.
      The government are not reducing the environmental safeguards per se but they are diluting the voices who are in charge of defending those safeguards. By raising the status of economic growth. They are openly resisting calls for more integrated regulation that deals with fracking process per se. Their reluctance to embrace a more integrated EU Directive in my view is counterproductive as it might actually help overcome many public concerns. Like you I agree that we have two extreme camps; those who see fracking as the end of the earth and those who see it as the saviour of our energy gap. Like you I agree this is a pantomime debate and it is no good at all to have a debate on those terms.
      The wider narrative within which all policy is being developed is, in my view, relevant to shale gas as much as you want to focus on that alone. Sorry you can’t look at it in isolation. The government priority is clear; economic growth is seen as the number one priority and given that it can trump environmental and social interests in planning decisions when matters are of national interest that matters. Currently social and environmental matters are poorly accounted for in planning decisions. Our current work for government as part of the National Ecosystem Assessment follow on project illuminates this problem (www.eatme-tree.org.uk).
      It is therefore important that government and decision makers see the environment not just as a constraint but as an opportunity space with benefits. To do this we need to change the way we use tools and assess the environment in the decision making process itself. As I discussed previously, the current tools are not fully fit for purpose eg EIAs.
      Economic growth is embedded into the NPPF (National Planning Policy Framework) and has been a clear driver for the way all government agencies operate in practice. This drives a culture of short termism in response to economic austerity, but in so doing, impacts upon the work of its environment agencies such as Natural England and the Environment Agency. Much of my arguments are here http://blogs.birminghampost.co.uk/news/2012/10/the-castration-of-the-quangos.html highlighting the way government ministers and departments impact on the delivery and voice of such agencies.
      The other issue here is the government rhetoric of localism which clearly espouses the value of locally-driven planning decision making and a removal of central government interventions. In cases like fracking there is a very clear disregard of that idea begging the question of whether localism is anything more than a government soundbite and only to be promoted when it is the kind of localism they want to see. This is actually relevant here as opposition to shale gas is widespread. They cant have their localism cake and sweep it under the carpet when they don’t agree with it.
      In my previous post I referred to the EU NATURA 2000 review. This is important as the government commissioned it on the basis that they were convinced that such designations (Special Areas of Conservation) were harming economic development. The findings challenged this assertion. For example Natural England receives around 26,500 land use consultations annually; of these, they ‘object’ to less than 0.5% of these on Habitats Regulations grounds (par 28). https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69513/pb13724-habitats-review-report.pdf

    2. 3. The loaded government dice for planning decisions.
      This culture ties in with the ‘loaded dice’ point I made in my response to you. If the government publicly state that case for something is unassailable and it is in the national interest that we go ahead that sends a very strong signal to a planning inspector and developers. Armstrong in 1985 did an excellent anatomy of the public inquiry process for Sizewell B where a 2.5 year inquiry was ‘hijacked’ when, just before it started, the government stated then the case for nuclear power was unassailable. Many of the arguments that were being advanced were based on dangers and health risks etc but the government pronouncement made in my view the inquiry decision a forgone conclusion.
      We have a similar position now which puts planning inspectors in a difficult position particularly when the secretary of state has the final say. I would argue that the fracking issue will go to inquiry due to developers wanting to circumvent local authority decision making under the provisions of the growth and infrastructure act allowing government to decide.

      1. The government has no overall coherent energy policy which enables lurches from one energy source to another based on political whims and opportunism.
      2. There is government resistance to an improved regulatory environment which actually might help overcome public concern.
      3. There is a government rhetoric of localism which suggests local people might be able to influence what happens in their area but it only works if they follow government policy.
      4. There are academics who have expressed similar concerns over fracking policy to me who are far more eminent and distinguished in their field of energy than me. Prof Paul Ekins http://blogs.ucl.ac.uk/sustainable-resources/2013/08/07/ukerc-blog-the-fracking-battle-no-way-to-conduct-energy-policy/ also has written a blog post. Furthermore an emerging academic concern is the ways estimates of reserves are distorting the energy debate. Eg Glade et al 2013 http://www.sciencedirect.com/science/article/pii/S0360544213004416
      5. I actually want to be convinced that shale gas/oil is the way forward. That is still my position.

    3. Hi again Alister, and thanks for your continued comments,

      I'll begin by pointing out that you've felt compelled to pen about 2,000 words in justification of the original article of only 1,000 words or so. I would suggest that this alone is tacit realisation that the original article was somewhat careless. Sadly, it is the original article that remains for mass consumption on the website of the Birmingham Post. Much as I might try to promote thus blog, I doubt that the more nuanced position you now outline will have anything like the same number of readers or public impact.

      As an academic myself, I can well understand the difficulties of discussing complex issues at a level that can be easily understood by the general public, and in a style that keeps the reader interested, especially when editors impose word limits (or cut you off after 30 seconds, as I've experienced when giving radio interviews).

      However, there is such a thing as dumbing down too much, and I think that a member of public reading your original article would take away a substantially different message to what they'd take away from reading you extended comments here.

      Case in point - in the original article you repeatedly make the argument that the government is attacking and removing safeguards, yet in your comments you accept that they are not doing so, but that you are concerned that government rhetoric may affect the decisions made by regulatory and planning bodies. I would argue that these are very different statements to make.

      The following statement is slightly "wordier" than your original piece, which erroneously claims that government are reducing environmental safeguards, but would surely represent a more accurate description of the present situation. Perhaps I am overly optimistic of the public's level of comprehension, but I think the man on the street could understand the following:

      "The government has not removed any environmental safeguards. In fact, DECC have already increased environmental monitoring requirements in comparison to conventional oil and gas wells, including requirements to monitor air quality and fugitive emissions, to monitor induced seismic activity, and to use microseismic methods to map the hydraulic fractures as they are generated during fracking. However, I have my concerns that government rhetoric is placing economic benefits ahead of environmental risks, putting undue pressure on the independent actions of the relevant regulatory bodies."

      Similar case in point - in your original article, you repeatedly refer to "dashes" for various things - now we have lurches instead. Maybe "dash" was not your title, but it definitely comes across as one of the "take-home" messages of your piece. I'm not completely sure of the difference, perhaps a dash actually achieves something effective, while a lurch is something done less coherently and effectively, and perhaps the unintended result of circumstance rather than a desired move.

    4. On regulations -

      The underlying theme of your post is that shale gas extraction is something completely new and therefore requiring a completely new set of regulations. In fact much of what is done is exactly the same as that required for conventional gas extraction. Lets examine the processes in detail, and the associated risks for the key stages.

      1. Construction of a well pad: exactly the same for conventional and shale gas.

      2. Drilling, logging, casing and cementing a well. Potential risks include the handling of drilling mud fluids at the surface. Process and risks the same for conventional and shale gas wells - including visual impact, noise and exhaust of diesel generators, HGV traffic transporting equipment and fluids.

      3. Well-bore integrity. Lack of well integrity is caused by poor cementing/casing. The result of a bad casing job is that there is the potential for fugitive methane to contaminate shallow aquifers or to be released to the atmosphere. As per #2, this is the same issue for conventional or shale gas wells. In fact, I would contend that the risk is greater for a conventional well, given the increased propensity for high pressure free-phase gas in a permeable reservoir to cause a blow-out (c.f. Macondo/Deepwater Horizon).

      4. Hydraulic fracturing itself. Firstly, keep in mind that this is a small part of the overall process, taking all of a few hours to complete. Hydraulic fracturing is a common processes in conventional wells, although the volumes of water used are typically less than used for shale, especially the onshore fracked wells in the UK, which were mainly done in the 1980s. However, we're already seeing larger stimulations being performed offshore in the North Sea chalk reservoirs (see here for eg. Principal risks of hydraulic fracturing include inducing seismic activity - it's rare but it can happen, hence the new traffic-light-scheme rules; sourcing and transporting water to the site (implying many trucks, unless water is piped to the site); and handling the various fluids at the surface (making sure to avoid spillage).

      5. Dealing with produced water. After fracking, some of the fluids flow back, which must be treated and disposed of adequately. If a typical well uses 6,000 - 13,000 bbls of fluid, and 50% flows back, that's 3 - 15,000 bbls to be disposed of. The principal risk is mishandling of the fluid at the surface, leading to spillage, or the use of disposal facilities that are not rated to handle the chemistry of the produced fluid in question. The existing onshore industry currently deals with over 70 million bbls of produced water, which has to be processed and disposed of. That's the equivalent of over 4,500 fracked wells per year. The offshore industry deals with many times more than that (although the disposal is easier at sea). So it's not as new a problem as some would have you believe.

    5. 6. Production. Gas well-heads are pretty similar whether for conventional or shale gas. The principal concern would be the leakage of methane through faulty valves etc. Shale wells will require air quality monitoring to ensure that methane emissions are low, which AFAIK is not a requirement for conventional wells. If we are being consistent, perhaps it should be.

      7. Intensive onshore drilling. There are parts of the UK that have been pretty intensively drilled. See the area around Gainsborough, for instance, where residents report few issues or complaints (you can download well database here. Shale gas development would see an increase in this kind of infrastructure, but in fact a reduced number of individual well pads in comparison to the Gainsborough example, but spread across a wider area.

      Consider the above, and bear in mind we have one of the largest centres for oil and gas excellence outside of Houston and the middle east in Aberdeen, a good track record of drilling safety, in an environment (offshore North Sea) which is far more challenging than the onshore shale drilling proposed, and regulations that are regarded around the world as some of the most effective in the industry. I don't think wholesale re-organisation of regulations via an EU Directive would be a productive use of time.

      The key changes that have been made are rules to cover induced seismicity; the requirements to identify how waste fluids will be stored, transported and processed; and the requirement to monitor methane emissions to ensure that the use of shale gas is consistent with climate change commitments (i.e. that methane emissions don't reduce the climate benefits of replacing coal with gas).

      I would accept, however, that other EU nations might not have such comprehensive regulations already in existence, if they do not have a mature hydrocarbon industry already. A Directive might have been of more use in such circumstances, but that does not apply to the UK.

    6. With regards to wider government energy policy, I'm not sure whether either lurches or dashes are the appropriate verbs when it comes to actual action, notwithstanding the rhetoric. What I see is stagnation, resulting an expected "capacity crunch" with capacity margin only 2% above demand by 2015, leading the the potential for supply disruption. Disruption of this kind has severe economic, social and health implications, so I don't think it inappropriate to consider this through the perspective of national interest (I'm not saying that shale gas development alone can solve the capacity crunch, but I am considering the wider narrative here).

      I agree that government attitudes seem hypocritical with respect to localism when it comes to renewable energy vs shale gas. There is presumably a balance to be struck between local impacts and national interests when it comes to these decisions. While it might nominally be thought that the local impacts are similar (though I would dispute that), they are very different in terms of national interest. For the same amount of energy produced, the choice is not one shale pad or one wind turbine, but a single, football-pitch-sized shale pad or an entire mountainside covered with wind turbines. The first generating tax revenue both locally and nationally, the other requiring subsidy added to bills. The first providing a power source that is flexible, the second that is highly intermittent, and therefore of little use when considering the issue of "capacity crunch". Hence, while the local impact side of the scales might be similar, the national interest side of the scales is very different.

      There is inevitably a balance to be found between environmental impact and social/economic benefits when it comes to new projects/infrastructure. And also a balance between national interest vs local impacts. The question is who gets to decide? Ultimately, I would have thought that it is the prerogative of the democratically elected government of the day to decide where this balance lies?

    7. Finally, I think you might benefit from one of the many conferences that are taking place on the issue of UK shale. The next one is later this month in London: http://www.shale-uk-2014.com. There's usually a wide range of representative speaking, including government (and Labour opposition), industry, regulators, planners, environmental NGOs, and academics. The picture you get from these is usually quite different to that generally reported in the media.

      In particular, I've listened to representatives from the EA, and from local MPAs, and spoken to them off the record over beers etc at the end of these meetings. Perhaps they have different feelings privately, but none has expressed any concern about government rhetoric forcing their hand in terms permits and permissions in a manner with which they were uncomfortable.

  7. My final response
    Apologies for the delay in responding but exam boards and marking have got in the way.
    Thanks for your detailed response and, in particular, your insight into the risk assessment procedures for fracking processes. Whist you might feel we are poles apart I do not see such a difference. We are approaching fracking from two different lenses and its unconventional in that it is not for or against. Anyway here is my final response.
    1. Introduction
    I feel there is one very important theme here across all your postings which I haven’t raised explicitly with you before concerning the way science is not politically neutral. It is socially and politically constructed through the funding and political processes by which results and reports are released and its wider uptake and application in policy and decision making. In many cases these are cherry picked ( see Scott et al 2013 http://www.sciencedirect.com/science/article/pii/S0305900613000214 page 3 and Figure 1) with other evidence not factored or allowed into the process.
    I often find myself and, indeed am, presently in positions where my research results are not allowed to contain certain words or inflammatory statements criticising government policy when the research is funded by government. I find this challenging to deal with but equally ensure through other outlets that my concerns are made public arenas. So the separation of science from society is dangerous. You recently highlighted side by side the signed letters for fracking (eminent scientists) and against fracking (mainly environmental and pressure groups). The implication is that the eminent scientists are to be believed in favour of wider publics and social scientists. So this begs the question of whether, in your view, the views of a scientist have any more weight than the concerns of a member of the public or pressure group such as Friends of the Earth who have not been supplied/convinced with necessary information to allay their fears,. Who is at fault here?. Is it the scientists who can’t communicate their findings perhaps? Or is it that these publics should trust scientists inherently even if they are funded or depend in the future on grants by the very agencies who want a positive outcome?
    In your response you alerted me to the massive scientific evidence presented to support environmental assessments. But I struggled to read and understand the 50,000 pages of the environment statement for HS2 even though it matters professionally to me and I do not consider myself uninformed. Furthermore, many of the public would struggle to find the time to read the 164 page non-technical summary. Notwithstanding the fact that these massive pieces of work are funded by the developer themselves making it a rather cosy arrangement, the bombardment of information to publics in the name of ‘consultation’ is a fallacy; it is not consultation it is deliberate manipulation as so few people or agencies have the time and resources to respond effectively. This is rarely commented on and needs urgent action in my view.
    I do not see much value in playing a blame game but I just feel natural and social scientists need to work together better to address these key issues and fracking is a classic case that shows me it is not working and indeed is merely polarising opinion. That is one reason why I am so keen to engage with you over this issue.
    The other points in your last response are now addressed.

    1. Hi Alister, thanks for your responses. As always, it's good to talk.