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.