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Frack Free Notts – July 2016
Shale gas in Nottinghamshire – how
will they regulate fracking?
Regulatory system
• DECC (as was) – promoting oil & gas and explaining
why this won’t cause climate change
• OGA – licensing, hydraulic fracture plan, seismicity
• MPA – planning: development and use of land
• EA – environmental permitting
• HSE – drilling plan
• PHE – advice on threats to health
Oil & Gas Authority (OGA)
• Petroleum Exploration & Development Licences (PEDLs)
– oil & gas, conventional and unconventional
• Hydraulic Fracture Plan (required for any hydraulic fracturing)
• Seismicity
– micro earthquakes expected (<0.5)
– traffic light system will stop fracking if >0.5
• Notts – 270 conventional wells since WW2
• Firm proposals to drill in Notts licences:
– IGas (1), Ineos (3), Egdon (1), Hutton (2 conventional)
Minerals Planning Authority(Notts County Council)
• Controls over development and use of land
• Assumes other regulators will operate effectively
• Planning framework
– National Planning Policy Framework (esp paras 142-149)
– Planning Practice Guidance (Ref ID: 27-091-20140306 ff)
– Minerals Local Plan, Local Plans, Neighbourhood Plans
• Planning applications
– EIA, Scoping, Validation, Consultation
Typical Planning Issues
• Highways
• Ecology
• Water
• Air Quality
• Visual/Landscape
• Noise & Vibration
• Geology
• Land
• Cultural Heritage
• Social
• Cumulative Impacts
• Public health
Environment Agencyenvironmental permitting
• Mining waste
• Radioactive substances
• Groundwater
• Flaring/venting gases (>10t/day)
• maybe Abstraction Licence (to use groundwater)
• Discharge Consent
• Flood Risk Assessment
• Crude oil storage
Environment Agency - fracking
• Infrastructure Act definition of hydraulic fracturing (>1,000m3 or >10,000m3 total)– not within SPZ1 (within 50m of water abstraction borehole)
– groundwater monitoring 12 months before
– monitor methane to air and publish results
– chemicals to be approved
• Will want to know where frac fluid is left underground (as it is mining waste disposal)
• Waste Management Plan
• Five facilities in England can take return frac fluid with radioactivity
Environment Agency -
consultation
• Public consultation if hydraulic fracturing
• No consultation for standard processes:
– drilling with water-based mud
– drilling with oil-based mud
– NORM (naturally occurring radioactive material) –accumulation and disposal
– leak-off tests [test frack] and acid wash (HCl)
– crude oil storage and handling
Health & Safety Executive• Operators responsible for health & safety
– with independent well examiner providing quality control
– notifies HSE – drill rig, safety equipment, geology, design of well, etc
– weekly reports to HSE
• HSE approves and audits well examination scheme
• Aim to prevent unplanned releases of fluids (liquid or gas)
OGA/HSE/EA cooperation• Permitting
• Consent to drill
• Hydraulic Fracturing Consent
• Extended Well Testing Consent
• COMAH (Control of Major Accident Hazards)
Department of Energy & Climate Change(now Dept of Business, Energy & Industrial Strategy)
Office of Unconventional Gas and Oil
Sources quoted
• Royal Society/Royal Academy of Engineering– Shale Gas Extraction in the UK, June 2012
• Prof David MacKay & Dr Tim Stone– Potential greenhouse gas emissions …, September 2013
• Institute of Directors– Getting Shale Gas Working, May 2013
• Ernst & Young– Getting ready for UK shale gas …, April 2014
• Public Health England– Review of potential public health impacts …, June 2014
“Hydraulic fracturing is safe and environmentally sound – if operational best practice is enforced”
Can the regulators cope?
• Regulators claim they can manage individual exploratory and appraisal wells
• But – admit they don’t yet have capacity to regulate large scale gasfield production
• Cuts in public expenditure – LA planning cut 46% 2010/11 to 2014/15
– EA cut 25% in real terms 2009/10 to 2013/14
– HSE staff cut nearly 50% in last 10 years
(from Medact 2016: Notes from the literature, paras 347-352)
• No UK experience of high volume hydraulic fracturing
• Experience of hydrogeology limited to a few hundred metres down
Nottinghamshire
Shale gas areas and Licences
British Geological Survey – 2013
www.gov.uk/government/publications/bowland-shale-gas-study
Petroleum Exploration Development Licences:
www.gov.uk/oil-and-gas-onshore-maps-and-gis-shapefiles
�interactive map
http://drillordrop.com/east-midlands-and-south-yorkshire-licences
IOD 2013:4,000 horizontal wells
by 2032 to provide 1/3 UK gas
Could be 100 to 400 wells per
10km x 10km square (6 miles
x 6 miles), i.e. 10 to 30 well
pads with 10-12 horizontal
wells from each pad.
Conventional and
Unconventionalscale of activity,
geographical intensity,
land take and spread
are hugely different
Not easily compatible with other land uses
Not easily compatible with other land uses –agricultural, leisure, nature reserves, residential.
Reductions in the quality of life get reflected in falling house prices. (By 7% according to a heavily redacted report of DEFRA that the government tried to suppress). As an area becomes less desirable people are prepared to pay less to live there.
Insurance premiums are likely to rise.
New York State bans fracking
In June 2015, the State of New York banned
high volume hydraulic fracturing. A thorough
review concluded that regulation could not make
fracking safe, with particular concerns about:
• Wastewater disposal
• Seismic uncertainty (likely to be unknown fault lines)
• Impact on wildlife habitats
• Increased ozone levels
• Cumulative impact on communities
(These are residual concerns after considering measures to
reduce adverse environmental and public health impacts)
Defra report on rural impacts
A draft review by Defra of ‘Shale Gas Rural Economy Impacts’ dated March 2014 (released in July 2015) suggested:
• Increased congestion on roads
• Potential human health consequences
• Industrialisation of quiet regions
• Fall in house prices
• Increase in noise
Health Compendium
An updated compendium of health effects was published in October 2015:
• Regulations not capable of preventing harm
• Fracking threatens drinking water
• Toxic air pollution – e.g. BTEX and ozone
• Public health problems, including occupational health
• Earthquakes caused by wastewater re-injection
• Serious exposure risks from compressor stations & dust
• Naturally occurring radioactive materials
• Economic uncertainties exacerbate public health risks (Concerned Health Professionals of New York, October 2015)
Frack Free Notts
• http://frackfreenotts.org.uk/
• www.facebook.com/groups/frackfreenotts/