Session 2014-15
Infrastructure Bill [HL]
Written evidence submitted by Ms Helen Cuppleditch (IB 35)
I am a resident in West Sussex, business owner and home owner who has been researching ‘unconventional’ extraction of hydrocarbons including the process known as fracking.
There has been an incorrect assumption (partly from media and partly from MPs) that those of us opposed to the process are basing our views on emotion not fact. There is also an incorrect assumption that we are incapable of educated, independent research. This assumption does not reflect the reality of why so many UK citizens, from many walks of life, are deeply opposed to the process and why we are desperately worried about the impact the Infrastructure Bill will have on all of us in relation to the extraction of hydrocarbons.
1. Climate Change Act 2008 vs Infrastructure Bill.
The Climate Change Act 2008 ensures the UK Government (and successive governments) has a legal obligation to minimise our greenhouse gas emissions. The secretary of state for energy and climate change will have to report on a regular basis how this is being implemented and achieved.
The Infrastructure Bill however, will make it a legal requirement for the government to ensure ‘maximising the economic recovery of UK petroleum’. The secretary of state for energy and climate change will also have to report on a regular basis how this is being implemented and achieved.
It is impossible for both to be implemented and achieved.
2. Economics of the industry.
The recent drop in the price of oil has further exposed the fragile economics of the American industry, with it being reported that the industry has run up $550 billion of debt [1].
Much of the North American shale production requires high capital expenditure just to keep production at the same rate due to quick depletion rates of the wells.
With interest rates being so low, many investors had been looking for ‘high yield’ returns and had invested in the unconventional hydrocarbon extraction industry through high risk ‘junk bonds’.
Until now, many investors had considered the investment risk was worth the gamble despite many experienced investors warning that the industry is likely to be an ‘inflated shale bubble’. With such fragile economics now being exposed I question if financial systems could withstand any ‘stranded assets’ that may soon be exposed in this industry, and therefore I believe this is an economically unsustainable industry. With many investors, both large and small, now recognising there is an increased risk attached to all fossil fuel investments, I believe the path being considered by introducing measures in the Infrastructure Bill to maximise the economic recovery of UK petroleum is an unstable, rickety, economically flawed bridge to nowhere, and not the bridge to ‘energy independence’ that the industry and government has been promoting to the public.
3. Environment Impacts and Homeowner / Landowner Rights
Nowhere else in the world has high pressure, high volume hydraulic fracturing taken place in such highly faulted geological formations. Therefore, the UK will be a guinea pig for this industry.
I note that the Environment Agency has produced ‘ Generic risk assessment for SR2014 no 4: accumulation and disposal of radioactive waste from the NORM industrial activity of the production of oil and gas ’ spreadsheet [2]. Within this risk assessment it states that, when it comes to ground and groundwater, NORM (Naturally Occurring Radioactive Material) from flowback or produced water re-injected to the underground oil and gas bearing strata will be ‘low risk’ because it considers the only pathway into the aquifers will be through the drilled well.
The document states: ‘This is NORM present in the oil and gas brought to the surface and then re-injected back into the original rock, or NORM present in residual well stimulation fluids left in the rock strata. There is no pathway for this NORM to the wider environment, other than any created by drilling and the well. The Environment Agency "Environmental Risk Assessment for shale gas exploratory operations" considers the risk of fracture propagation beyond the target zone to be low.’
Therefore the report states there is no risk management by the Environment Agency in relation to any possible contamination through pathways other than the drilled borehole (which falls under the Health and Safety Executive to oversee).
Low risk is not the same as safe. I question if the EA or HSE can 100% guarantee that no flowback fluid / produced water / contamination will enter the aquifers and ground through additional pathways other than the drilled borehole (ie existing known faults, unknown faults, fractures created through the hydraulic fracturing process) particularly as this process is a complete unknown within the geological formations in the UK and especially in relation to the chalk aquifers here in the Weald.
Will any monitoring of contamination take place or even be fit for purpose, particularly as the EA is unwilling to accept the possibility of contamination happening through additional pathways outside the drilled borehole?
As pollution can be carried several miles through chalk aquifers in a short space of time, how will landowners in affected areas be aware that any contamination has occurred?
I believe we, as landowners and homeowners, should have the right to deny underground access by the industry because there is a risk to us, our families and the food chain from contamination of our aquifers and ground, but this risk is being played down (and even ignored) by both the industry and government bodies.
I note that Halliburton, one of the world’s largest providers and services to the energy industry and ‘global leader’ of fracking has submitted written evidence [3] for the Commons Select Committee ‘Environmental risks of fracking inquiry’ [4].
Halliburton have stated at note 3.3 ‘There has never been a confirmed instance of drinking water contamination due to HF [hydraulic fracturing] throughout its long history.’
This appears to contradict the findings in August 2014 of the Pennsylvania Department of Environmental Protection [5] which released letters confirming 248 cases of private well water contamination (with further cases still under investigation).
The industry appears to state the same as Halliburton, however, I believe this may be a way of limiting the i nformation by claiming the precise ‘ hydraulic fracturing process ’ may not have caused contamination, without then disclosing information about the WHOLE engineering process and the impact that this whole process has throughout the lifetime of the well, including post hydraulic fracturing / extraction / abandonment . 014.