Infrastructure Bill [HL]

Written evidence submitted by the Public and Commercial Services Union (PCS) (IB 20)

CALL FOR EVIDENCE ON THE INFRASTRUCTURE BILL

1. The Public and Commercial Services Union (PCS) is the largest civil service trade union in the UK, with a quarter of a million members. We are organised throughout the civil and public service s and government agencies, as well as in the commercial sector, in some areas that have been privatised.  We represent members in the Department for Transport, including the Highways Agency and government departments which oversee the regulatory framework of the shale gas and oil industry: DECC, Health and Safety Executive, Defra/Environment Agency and Public Health England.

2. We welcome the opportunity to submit our views on two parts of the Infrastructure Bill :

· Part 1 of the Bill which relates to the Strategic Highways Agency and the intended creation of a new Government Company to take the place of the current Highways A gency which is an executive agency of the Department for T ransport ,

· Part 5 of the Bill which relates to Energy and in particular clauses 38 -42 in the section on petroleum and geothermal energy in deep-level land - specifically "streamlined access to onshore oil and gas reserves" or fracking.

3. The Infrastructure Bill is a portmanteau Bill and therefore as our submission is in relation to both parts 1 and 5, our word count exceeds the guide of 3000 as it covers, in effect, two submissions. Section 1 of this submission, paras 4 – 31 relates to Part 1 of the Bill, section 2, 31-64 relates to section 5 of the Bill.

Section 1- Highways Agency

4. PCS represent s over 8,000 member’s right across the Department for Transport (DfT) . In the Highways Agency (HA) PCS represents staff at all grades below the Senior Civil Service including members in the Traffic Officer Service.

5. PCS is opposed to the intention included in the Infrastructure Bill to change the status of the HA from an executive agency to a government-owned company (GoCo) – Highways England. We therefore propose that the whole of Part 1 of the Infrastructure Bill be deleted.

6. We do not believe that a change in status is required to improve the efficiency of the agency. We fear that the creation of Highways England is the final staging post to privatisation of the strategic road network in England.

7. In the Impact Assessment published with the consultation document (on the proposals now set out in part 1 of the Infrastructure Bill) in October 2013, the option to retain the HA as an executive agency of DfT with funding certainty was not considered. PCS however believes this is the best model for roads reform. Funding certainty was given by Danny Alexander in his speech to the Commons on 27 June 2013, with no mention of it being dependant on the HA’s status change into a GoCo. The five-year Parliamentary cycle would provide much of the sought-after stability and the HA has now in any event, let a £5 billion contract to cover improvement schemes for the next five years.

8. Most of the government’s efficiency savings identified come from securing longer-term funding and removing day to day interference with priorities of the HA. In November the HA let a framework contract with 26 companies (the Collaborative Delivery Framework). This provides a cost effective way for the HA to procure up to £5 billion of investment in England’s motorways and major A roads over the next five years. The successful bidders are required to make year on year savings. The contract will novate to the new company but any savings will not be due to the status of the new company.

9. If Part 1 of the Bill is to be retained, we would propose that Clauses 1 and 2 be removed and all further reference to Strategic Highways Companies revert to the "Highways Agency". This would at least reassure us of the veracity of the Minister’s previous statements that the legislation is not about or with a view to, privatisation of the HA’s functions, or the strategic road network.

10. We believe privatisation would inevitably lead to tolling of major routes which will have a detrimental impact on the environment, road safety and local economies.

11. The amendment of schedule 1, part 2, to remove paragraphs 112-127 or alter them to clearly state that they only refer to existing charging schemes, would give reassurance that road-tolling and road-charging are not features of the Bill. There have been confused messages with ministers recently saying that tolling was not their intention but at the same time stating in certain documents that they will consider tolling (para 79 of the Government’s response to the Transport Committee’s fifteenth report of session 2013 -2014, published 20 October 2014 ). In addition Paragraph 43 of the explanatory notes to the Bill states that paragraphs 124 to 127 of the Bill, "amend the Transport Act 2000 to allow the Secretary of State to apply a road use charge on trunk roads where he has appointed a strategic highways company to be the highway authority, in order to preserve the existing arrangements." (our emphasis)

12. PCS accepts that longer term funding certainty is the key to achieving significant savings against the current costs of managing and maintaining the strategic road network but we do not accept there is a need to change the status of the agency to achieve this. Indeed the change of status itself would incur significant costs with logo changes to patrol vehicles and uniforms for the Traffic Officer Service, the total re-branding of the HA including road signs, websites etc, the need to insure vehicles, buildings and other structures and individuals, and pay Vehicle Excise Duty. The involvement of two oversight bodies would also inevitably lead to more, not less, bureaucracy, along with growing concerns over their expertise on road issues.

13. The purpose and justification for Part 1 of the Infrastructure Bill is set out in Transforming our Strategic Roads – A Summary, published by DfT in October 2014. This states that the executive agency status of the HA gives rise to institutional inefficiencies such as less flexibility over day to day operations, procurement and contract management compared to other infrastructure providers. A single source document (European Cost Comparison – cost differences between English and Dutch Highway Construction, EC Harris and TRL December 2009) is used to illustrate that "international comparisons show that operators in other countries can run their roads more efficiently at arms-length". That report did find from an initial comparison that HA motorway construction costs, per lane km, were higher but concluded that once the factors behind the higher costs were normalised "there is very little difference in costs between the respective lane km costs".

14. The additional costs identified for the Highways Agency were due to the provision of services such as

· CCTV, speed enforcements and vehicle recovery which do not form part of Dutch construction costs but are funded separately,

· higher technical standards to pavements and structures,

· higher aggregate and soil disposal costs due to the effect of taxes and additional transportation costs,

· simpler drainage provisions on Dutch projects,

· more complex ground conditions and consequent design solutions on HA projects, and

· the impact of exchange rates.

Most of these are features that would be associated with a "world-leading road operator".

15. A more recent EC Harris report from 2012 on international construction cost comparisons, found that the UK compares favourably to most developed countries. It is thus simply not true to claim that the HA is less efficient than comparable organisations.

16. We believe any institutional inefficiencies that do exist are not related to the status of the agency, but to the stop/start funding arrangements that have prevailed ever since the agency was created. This was recognised as long ago as 2002 when HM Treasury published "Better Government Services – Executive Agencies in the 21st Century". It recommended that greater efficiency could be realised if "agencies have three-year funding agreements and full end year flexibility" over this funding period.  Creating a new company is not necessary to make this happen.

17. As well as improved efficiency, the other claimed benefits for a new company include improved customer service, clearly defined aims and objectives and robust governance through independent monitoring of performance. These are exactly the same reasons as to why the HA was created as an executive agency. There is nothing included in the recently published Strategic Business Plan for Highways England that could not be achieved or delivered by the HA in its current form.

18. Despite repeated parliamentary questions on the subject, there has still been no definitive answer as to whether Highways England would be subject to VAT, currently running at around £450 million a year which the HA as a government agency is currently exempt from. It is expressly not mentioned amongst the tax exemptions in the Bill. If not exempt, far from saving £2.6 billion as claimed, the change would cost £4.5 billion even at today’s expenditure levels, which are set to double or more.

19. The HA supply chain claim that visibility of the future project pipeline will give them the confidence to invest in training, equipment, plant and research. It is not the status of the agency that gives visibility to future projects, but the roads investment strategy. Similarly the status of the HA does not, and cannot, guarantee that any future government will have different investment plans or priorities.

20. It is also claimed that a change of status will allow the new company to change its procurement practices. There is no evidence that this would be the case. The Public Procurement Directives will still apply and as the new company will be spending public money the normal government rules on managing public money will apply. A common complaint is that suppliers have too little time to respond to invitations to tender, but this is due mainly to a Cabinet Office target of 120 days from OJEU notice to tender award. If this target is a problem, then changing it would be far simpler than changing the status of the Agency.

The Roads Investment Strategy

21. The original framework document for the HA stipulated that the agency would be responsible for managing and maintaining the trunk road and motorway network as well as managing and delivering agreed programmes of new and improved schemes, aimed at removing bottlenecks. That same framework concluded that ministers would remain responsible for overall policy on trunk roads in England and by extension, the size and shape of work programmes set for the agency. Part 1 of the Infrastructure Bill formalises this through the requirement to publish a Roads Investment Strategy (RIS).

22. What is lacking in the Bill is a requirement for the Secretary of State to consult all stakeholders and interested parties in drawing up or varying the RIS. Similarly there is no legal duty to protect the climate, air quality or the natural environment. Roads policy should not be treated in isolation from policies on demand management, land-use planning, public transport and future technologies.

23. More deaths are caused by transport-related air pollution than by road traffic accidents The most recent report of the Environmental Audit Committee – Action on Air Quality recommended (para 61) that the strategic Highways Company should have a legal duty to protect air quality and that the Infrastructure Bill should contain a specific clause to that effect.

Tolling

24. PCS believes that the real intention behind changing the status of the agency is to make it easier to privatise it in future. The ex-Chairman of the HA, and author of "A Fresh Start for the Strategic Road Network" Alan Cook, admitted this in an interview with the Daily Mail in 2013. Minister Stephen Williams even confirmed, when closing the Bill’s second reading, that any government promise of no privatisation was only good for the duration of the current parliament (i.e. the next five months).

25. Privatisation will only be possible if a revenue stream can be created. The most obvious means to achieve this is to levy tolls. In its response to the Transport Select Committee’s fifteenth report of session 2013-2014, the government stated (paragraph 79)

"The Government will consider tolling as a means of funding new road capacity on the strategic road network. New capacity would include entirely new roads and existing roads where they are transformed by an improvement scheme".

The published RIS and the associated Strategic Business Plan both make reference to transforming the network through improvements, and a new type of road – Expressways – are to be created. Given the draft clauses in the Bill to permit the new company to levy tolls and install tolling equipment, it seems unlikely that there is no intention to introduce tolls in the near future. The provision in the Bill that permits the new company to be fined if it fails to meet its performance specification only makes sense if the company is not publicly funded. Bringing in tolling experience at Board level only reinforces this view.

26. Tolls are not popular in the UK and all the evidence is that they do not work. Part of the problem is the availability of diversionary routes. The road network in England is well connected and built to a high density. A report issued by consultants Atkins in November 2012 found that tolls on the A14 could result in up to 35 per cent of traffic using the existing road, being diverted onto other local roads. Most traffic congestion occurs on local roads rather than the strategic network so this sort of shift will see severe environmental impacts. Furthermore the additional wear and tear on already under-funded local roads coupled with the increase in what would normally be motorway traffic users on potentially long journeys would lead to a significantly increased likelihood of road traffic accidents and, unfortunately, a corresponding increase in fatalities.

Staff Views

27. Despite nearly four years of being told a change in status will be a good thing, over half of HA staff who responded to the most recent management survey remain opposed or strongly opposed to the change. Operational staff are the most negative about the change.

28. Staff working in the HA remain unconvinced that the changes are required. Both unions, PCS and Prospect, in the HA have balloted their members on the question "do you agree that the Highways Agency should remain part of the civil service rather than becoming a government owned company?". The results have been remarkably consistent. 92% of PCS members and 93% of members of our sister union Prospect agreed.

29. HA management most recent survey results revealed that although the majority of staff understand what the roads reform agenda is about, the majority remain unconvinced that it is necessary. These surveys have in fact shown that staff have become increasingly unconvinced over the course of the last twelve months, even as managers and directors have made ever more desperate attempts to sell the supposed benefits of these changes to them. In fact just 1.25% of staff strongly agree with the management statement that they feel positive about the new company.

30. HA staff are dedicated, professional civil servants; an unusually large proportion of them with many years of experience in their roles, who quietly and unobtrusively get on with serving the public under whatever circumstances are thrown at them, so such a vote of no confidence from them is a significantly damning indictment of the serious shortfalls apparent in these proposals and Part 1 of this Bill.

31. In short, PCS believes that this is an orchestrated attempt to use public money over the next five years to bring the Strategic Roads Network up to a standard attractive to the private sector and introduce tolls across the network. The next step might then be to invite bids for regional franchises modelled on the rail and water industries, with tolling as the primary income stream backed by yet more public money should tolling prove insufficient to placate shareholders and maintain expected profit-margins.

Section 2 – Part 5 Infrastructure Bill - Energy Section

32. PCS opposes shale gas extraction or fracking and, by consequence, opposes the inclusion of provisions 38 to 42 in the Infrastructure Bill to accelerate the shale gas industry.

33. The grounds for our opposition are based on: climate change and the environmental impacts; weak regulation; jobs; health and safety; energy security; ownership; human rights. We believe that at a time when the global call is to divest ourselves of fossil fuel dependency, investment in fracking is reckless in the least and will delay serious investment in alternative sustainable energy sources.

34. PCS calls for:

a) adoption of the precautionary principle when analysing the health and safety and environmental risk factors;

b) a moratorium on fracking;

c) investment in renewable and sustainable technologies.

Climate Change and Environmental Impacts

35. Shale gas is a fossil fuel and which we see as a form of ‘extreme energy’. Here we use the definition elaborated by the Extreme Energy Initiative [1] which goes beyond categorisation alone but refers to the entire extractive process. Therefore, while we oppose extraction of all fossil fuels, it is the adoption of processes to access ever harder to reach unconventional fossil fuel reserves that makes fracking, and others form of extreme energy, of increasing concern.

36. Since the industrial revolution, fossil fuels have underwritten the development model of "industrialised" nations. In the nineteenth century the catastrophic price we would pay for this development by unleashing harmful greenhouse gas emissions into the atmosphere was not known. However in the 21st Century we have the benefit of history, science, and technology to learn and change our future energy course. And there is no more pivotal point than now.

37. The authoritative UN Intergovernmental Panel on Climate Change (IPCC) has stated that it is unequivocal that "warming of the climate system" is happening and that "recent anthropogenic emissions of greenhouse gases are the highest in history ." [2] Therefore the princip al cause of global warming is burning of fossil fuels. It is also well stated and recognised that if we stay on our current path, the impacts on people and ecosystems will be irreversible and likely lead to more extreme weather of the type experienced with the floods of last winter.

38. As the report: Unburnable Carbon 2013: Wasted capital and stranded assets [3] notes, if we are to at least hope to stay within the widely accepted 2oC global warming temperature limit on pre-industrial levels – and others argue this should be lower – then "a precautionary approach means only 20% of total fossil fuel reserves can be burnt by 2050".

39. It is argued – see DECC report UK Shale: Climate change report (2014) [4] - that shale gas would have a significantly lower carbon footprint (including CO2 and methane) than coal when used for electricity. However this claim is not supported by other evidence widely available and notably from the US. The risk from fugitive methane emissions as a result of leaks is extremely high and of growing concern given its greater global warming potential. In the US, recent peer reviewed research by Cornell University, building on work previously done in 2011, concludes that "both shale gas and conventional natural gas have larger GHG than do coal or oil, for any possible use of natural gas and particularly for the primary uses of residential and commercial heating." [5]

40. Whether one has more or less however is mere semantics of ‘carbon trading’ and akin to a dieter choosing sugar free sweets rather than addressing what may be a more fundamental question about how to meet daily calorific intake in line with human energy burnt in daily activity. All are fossil fuels and all contribute to climate change processes.

41. On an environmental level, impacts of fracking include noise and air pollution due to heavy traffic around well sites, water usage and potential for chemical leakages not least for groundwater contamination. This brings other additional environmental costs as infrastructure needs to be built to service the fracking wells e.g. new roads. Fracking is also water intensive and could create water stress in certain areas and certainly there will be problems of disposal.

42. The clauses in the Infrastructure Bill add further measures to restrict objections to the exploration and exploitation of shale gas. In January 2014, without Parliamentary scrutiny, the government removed the right of individual landowners to be informed of planning applications and weakened the process of notifying property owners of such applications. These attempts to accelerate the fracking industry runs counter to what all the science, research and daily experience of people impacted by climate change is telling us we should be doing – keeping fossil fuels in the ground.

Weak Regulation / Jobs

43. A lot of the assumptions made about the environmental, climate change and health and safety risks of shale gas are based on an assertion that it won’t happen here because our regulation will be better. Even if we thought that shale gas was a viable energy source, the regulatory framework currently in place does not provide the guarantees Government’s own funded research calls for. For example, the Royal Society (2012) [6] says the environmental and health and safety risks can be mitigated if best practice is observed and a strong regulatory framework is put in place.

44. Currently the regulatory framework for shale gas has large gaps and despite this being a new technology in the UK, little regulation is dedicated specifically to shale gas exploration, development, and extraction. As the report by Friends of the Earth (FoE) "All that glitters" [7] points out, an immediate failing of the current regulation is the "failure to follow a precautionary" approach established as part of the Rio Declaration on Environment and Development in 1992, to which the UK is a signatory.

45. Leakages from horizontal or vertical well casings remain disputed, but again recent studies in the US have shown leakages through poor wellbore integrity. Importantly Davies, R.J, et al, (2014) [8] note that the lack both in the UK and other jurisdictions of systematic monitoring of abandoned wells for example, may mean "that well integrity failure may be more widespread" than presently known. These raise important "legacy" issues which we know the current regulatory framework is not established to deal with. And certainly the news [9] that the only fracked site to date in the UK at Preese Hall in Lancashire has suffered a loss of wellbore integrity, gives further cause for alarm.

46. Each of the departments involved in the regulatory process (DECC; HSE; Defra/EA; PHE) has suffered severe staffing and budget cuts since the coalition government came to office. The Office for Budget Responsibility has also forecast that based on government spending assumptions set out in the autumn statement, we can expect to see a "20 per cent fall in government employment over the forecast period" [10] . It is clear to PCS, the number of job cuts in departments that are to service the regulatory framework expose the weakness in the assertions made that it will all just be better in the UK. Further, arguments that jobs aren’t there because the industry is in its infancy do not stack up in the face of the projected staffing cuts proposed.

47. For a union, this may be the obvious point at which we argue for more civil service jobs to support the regulatory framework. However we do not see the fracking industry to be a job creator. Estimates around the number of jobs involved in fracking vary widely ranging from the Cuadrilla backed Institute of Directors report [11] of 74,000 jobs to the AMEC report [12] of 32,000 (direct, indirect and induced) jobs at peak. Again, evidence suggests that these are wildly overestimated and dependent on what elements are included in the supply chain. Conversely we argue for the creation of a National Climate Service [13] that invests in workers who contribute to reducing greenhouse gas emissions.

48. The additional right to keep potentially harmful chemicals in the ground and to leave "in a different condition from the condition it was in before an exercise of right of access (including by leaving any infrastructure or substance in the land)" is reckless in the least and particularly in light of the lack of any legacy monitoring and potential to be used for disposal of harmful waste fracking fluids. This will leave responsibility of monitoring to citizens and to raise them...where? What rights will there be for landowners, including public land, to claim against companies for the vandalism of the earth beneath them? What standard of proof will be required, who will legislate, and who will ‘clean up’?

49. Every measure to date in relation to shale gas has been about deregulation. As oft quoted, David Cameron is "all out for shale" and is clearly intent on doing all possible to accelerate the industry at the expense of regulation. Successful attempts in Brussels to block binding regulation [14] and the clauses in the Infrastructure Bill go further to support this.

Health & Safety

50. As we learn more from the experience of shale gas in the US, so we learn more about the dangerous and harmful effects of fracking on communities and workers. The risks inherent in the fracking process cannot be overstated. Research has drawn a causal link between the chemicals used in fracking and health effects on local residents. These include reproductive health, miscarriage, and developmental problems. By adopting a precautionary approach now allowing more research to be conducted into the chemicals used in fracking, and their impact on local residents and workers, we can ensure against creating a longer term problem further down the line.

51. Workers routinely face occupational health and safety issues particularly in hazardous industries among which fracking should be counted. The fracking process uses silica sand as a main component of the process. Inhalation of silica dust can lead to silicosis, lung cancer, or other fatal diseases. However with secrecy around the chemicals used, there is sufficient reason to believe that workers in the industry will suffer a high level threat to their health and safety. As Hazards magazine elaborates, the "Occupational risks related to fracking overlooked by the UK regulator [HSE] include exposures to a range of toxic and carcinogenic substances, as well as more typical hazards found in the extractive industries." [15]

Energy Security, Ownership, and Human Rights

52. It is accepted that in the last decade the UK has become increasingly dependent on imported gas as the contribution from North Sea gas declines. However the allure of shale gas extraction appears nothing more than a modern day Klondike to bolster the profits of energy companies rather than a real solution to energy security. It is now widely accepted that shale gas will not be a "game changer" [16] in the UK in the same way as it has been in the US, notably in bringing down fuel costs.

53. The level of shale gas reserves is also highly questionable and accused of being widely ‘hyped’ up to suit the political fracking agenda. The House of Lords report: The Economic Impact on UK Energy Policy of Shale Gas and Oil states "...there are no well-grounded assessments of economically recoverable reserves of shale gas". [17] However their conclusion egged on by the industry is to "get on with it" with respect to exploratory drilling. This is supported from more recent evidence from the UK Energy Resource Council. They are not opposed to shale gas but are unconvinced of the level of recoverable reserves and the contribution shale gas can make to energy security, not least when faced with meeting climate change targets. [18]

54. We know that in order to meet climate change targets coal will level off by the 2020’s by which time it is forecast that shale gas, if exploitable, will be on stream. However this is replacing one fossil fuel for another and we do not believe shale gas is a bridging fuel to a low carbon energy mix. Investment will detract from serious support for renewables and leave us in the next decade exactly where we are now – debating how we move from fossil fuel dependency and ensure energy security.

55. In this context, the dash for gas and going all out for shale is nonsensical. Whilst there are no easy routes to end our love affair with fossil fuels, there are sustainable alternatives which with the political will to break the fossil fuel habit (and no doubt lose a few corporate friendships along the way) could change our future path.

56. No one disputes that there is an easy answer to transition our dependency from fossil fuels to renewables; for workers in the energy sector, consumers, or energy intensive industries. However it is utterly astonishing that in the face of the science, the UN climate summits and platitudes given to climate change commitments we are set to entrench our fossil fuel dependency.

57. It was notable in the Commons debate on 8 December [19] that Mr Peter Lilley (an admitted climate change sceptic or "lukewarmist" [20] ) remarked that:

"Rightly or wrongly, mineral resources in this country were nationalised before the war and, unlike in the USA, landowners do not have the right to extract them. I do not see why landowners should have the right to prevent the extraction of a national resource that is collectively owned by us all."

If we have collective – nationalised – rights to the mineral resources beneath our homes and public property, do we not have the collective right of ownership and therefore decision making over what happens with mineral resources? Putting arguments aside of the merits or otherwise of shale gas, the profiteers will not be landowners and local communities through derisory pay-offs offered under clause 40 of the Bill. Whilst noted in other interventions in the Commons debate, a Bill is not the place to set a fixed figure, but we know from the public consultation on underground access in the summer where intentions lie. The ‘voluntary’ nature of the payments undermines any regulatory commitment, and is further weakened by the phrase "the Secretary of State must consult such persons as the Secretary of State considers appropriate." How is "appropriate" defined and the engagement of local communities ensured within that?

58. The DECC Public Attitudes Tracker Wave 10 [21] noted in August 2014 that public support for fracking was declining and is now at 24%, whereas support for renewables remains strong with over 79% of UK adults. By logical conclusion, given that the majority of the UK public opposes fracking, as "owners" of the minerals our consent to fracking is the overriding factor and any profits resulting exploitation of these minerals remain under public ownership.

59. Our final point in relation to our specific objections to fracking and one much overlooked in the debate, is the human rights implications of fracking.

60. The report A Human Rights Assessment of Hydraulic Fracturing [22] produced for the Bianca Jagger Human Rights Foundation sets out the compelling case for a moratorium on fracking. The United Nations Environment Programme [23] stresses the fundamental link between the environment and enjoyment of human rights and the UN broadly recognises it is becoming a growing theme in the context of climate change. Important in this dialogue is "access to information, participation in decision-making, and access to justice in environmental matters, as essential to good environmental decision-making (implying that human rights must be implemented in order to ensure environmental protection)". In the summer consultation on underground drilling access, the majority of respondents - 99% - rejected the government’s plans to change trespass laws as set out in this bill. The provisions in the Bill to enable automatic right of access ignores the overwhelming rejection of this measure, further diminishing faith in such consultation processes and which has left the conclusion that the only rights of interest to those forcing through fracking is the vested interests of corporations, not just lobbying in the wings but sitting in the heart of government. [24]

61. The creation of a independent shale gas task force cannot be given any credibility when its funders are the likes of Cuadrilla and Centrica. And further no small irony that the public will be funding a "new £5 million fund to provide independent evidence directly to the public about the robustness of the existing regulatory regime." The outcome of the Lancashire County Council decision on Roseacre and Little Plumpton will be watched very closely.

Conclusion

62. If the government was intent on a serious debate on shale gas then rather adding these clauses as part of a "portmanteau" bill, we would expect at least a single bill covering all relevant pieces of legislation and a single defining regulatory framework.

63. The overwhelming threat of climate change by pursuing a love affair with fossil fuels is a reckless policy in the least. We assert the adoption of the precautionary approach, but remain opposed to fracking and as with European countries such as France and Bulgaria, call for a moratorium on fracking. We do not believe the development of a shale gas industry in the UK is worth the human and environmental risks, with time and investment better redirected towards renewable energy.

64. On the basis of these factors, we therefore call for the removal of all fracking related clauses from the Infrastructure Bill.

December 2014


[1] See http://extremeenergy.org/2013/07/25/defining-extreme-energy-a-process-not-a-category/ - accessed 17 December 2014.

[2] http://www.ipcc.ch/news_and_events/docs/ar5/ar5_syr_headlines_en.pdf - accessed 17 December 2014.

[3] http://www.lse.ac.uk/GranthamInstitute/wp-content/uploads/2014/02/PB-unburnable-carbon-2013-wasted-capital-stranded-assets.pdf - accessed 17 December 2014

[4] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277220/Climate_Change.pdf - accessed 17 December 2014

[5] http://www.eeb.cornell.edu/howarth/publications/Howarth_2014_ESE_methane_emissions.pdf - accessed 17 December 2014

[6] https://royalsociety.org/~/media/policy/projects/shale-gas-extraction/2012-06-28-shale-gas.pdf - accessed 17 December 2014

[7] http://www.foe.co.uk/sites/default/files/downloads/all-glitters-critique-fracking-regulation-46660.pdf -accessed 22 December 2014

[8] Davies, RJ., et al., Oil and gas wells and their integrity: Implications for shale and unconventional resource exploitation, Marine and Petroleum Geology (2014), http://dx.doi.org/10.1016/j.marpetgeo.2014.03.001 - accessed 18 December 2014

[9] https://news.vice.com/article/the-only-fracking-site-in-the-united-kingdom-suffered-structural-failure - accessed 18 December 2014.

[10] http://cdn.budgetresponsibility.independent.gov.uk/December_2014_Exec_summary-web515.pdf - Accessed 18 December 2014.

[11] http://www.iod.com/connect/economics/articles/why-shale-gas-could-be-good-for-the-economy - accessed 22 December 2014; see IoD website for copy of full report.

[12] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/273997/DECC_SEA_Environmental_Report.pdf - accessed 22 December 2014

[13] See the One Million Climate Jobs pamphlet which advocates the creation of one million climate jobs as a response to the environmental and economic crisis at http://www.climate-change-jobs.org/ accessed 18 December 2014.

[14] http://www.theguardian.com/environment/2014/jan/14/uk-defeats-european-bid-fracking-regulations - accessed 5 December 2014.

[15] http://www.hazards.org/oil/fracking.htm#ref8 Accessed 17 December 2014.

[16] http://www.publications.parliament.uk/pa/cm201012/cmselect/cmenergy/795/795.pdf - accessed 18 December 2014.

[17] http://www.publications.parliament.uk/pa/ld201314/ldselect/ldeconaf/172/17207.htm#a33 Accessed 18 December 2014.

[18] http://www.ukerc.ac.uk/news/gas-can-be-a-bridge-to-a-low-carbon-future.html Accessed 18 December 2014.

[19] http://www.publications.parliament.uk/pa/cm201415/cmhansrd/cm141208/debtext/141208-0002.htm - accessed 18 December 2014

[20] http://www.peterlilley.co.uk/parliamentaryspeeches/1807/ipcc-fifth-assessment-report accessed 19 December 2014

[21] https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/342426/Wave_10_findings_of_DECC_Public_Attitudes_Tracker_FINAL.pdf - accessed 18 December 2014.

[22] http://www.sas.ac.uk/sites/default/files/files/UK%20HRIA%20w%20appdx-hi%20res.pdf – accessed on 6th December 2014

[23] http://www.unep.org/environmentalgovernance/Events/HumanRightsandEnvironment/tabid/2046/language/en-US/Default.aspx

[24] http://www.independent.co.uk/news/uk/politics/revealed-fracking-industry-bosses-at-heart-of-coalition-8707589.html# accessed 19 December 2014.

Prepared 6th January 2015