Complaint to ASA against RAFF (Residents action on Fracking; Fylde) for Gross Errors

 

 

If you travel through villages like Westby and Roseacre on the Fylde in Lancashire, you will see anti-fracking notices claiming that fracking is highly dangerous.  The claims are simply scaremongering and reflect the success of propaganda from anti-fracking groups of which RAFF is the most active on the Fylde.

RAFF-BROCHURE-4-PAGE-NEW.compressed

This is a blog with a difference as it is a copy of a complaint to the ASA (Advertising Standards Association) against the Leaflet Shale Gas, the facts, which has been produced by the leading anti-fracking group on the Fylde in Lancashire. I (Michael) has copies were given out at a public meeting in Elswick on 6th March 2014 and at the Garstang Show on 2nd August 2014. Ken has already complained to the ASA about similar inaccuracies in “factsheets” from Frack Free Somerset.

Neither Ken nor I have any connection with any shale gas exploration company but we are both concerned with the high level of disinformation put out by local anti-fracking groups.

Ken describes himself with this “CV”; After graduating with an Engineering Degree from Manchester University, I worked for Schlumberger Wireline Services as an open and cased hole engineer for 2 years in the mid 70s, in South East Asia, being promoted to ‘Senior Field Engineer’. In the 80s I worked for Halliburton wireline (Welex) as a cased hole wireline engineer. I worked in Libya, Kuwait, the USA, and India, mainly. I was promoted to ‘District Engineer’ in Libya,the most senior technical post. I dealt with customers, sorting out problems with leaking wells, cement bond logs, production logs, perforating etc. I quit the oilfields in 1990, after a total of 12 years, and became a Physics teacher. I have recently retired from teaching. I became interested in the fracking debate as I could not understand why people were protesting about shale gas fracking, in Balcombe. This was about an oil well, drilled in limestone, with no fracking planned. My researches and questioning of anti frackers (before they banned me) made me realise that the whole anti fracking bandwaggon is based upon falsehoods, failure to read UK regulations and procedures, nimbyism, and scaremongering. I am a beleiver in correct science.

As an environmentalist, and scientist, I agree with the IPCC and believe gas to be the sensible low carbon choice to fill in the gaps when renewables do not function, provided it is done properly. My researches convince me it will be, like any other technically advanced science that operates in the highly regulated UK.

 

For myself I graduated in geology, worked for a few years in Africa as an exploration and mining geology dealing with base metals like copper. I then was ordained in the Church of England and have recently retired. I have published much on science and religion and also in the history of geology and have written several academic papers on Darwin’s geological work in Wales and Shropshire, which he carried out in 1831 and 1837 -42. I have presented papers on Darwin’s geological work in the UK, Switzerland and the USA (at their annual conference of the Geological Society of America in 2008 and 2009). Like Ken I am an environmentalist, agree with the IPCC, (and wrote a book chapter on Evangelicals and Climate Change where I was very critical of Christian denialists like Beisner and other creationists) and with Dieter Helm in The Carbon Crunch see gas i.e shale gas as a bridge or transition to get rid of coal before sufficient renewables come on line, which will not happen in my lifetime. I have lived within 10 miles of Cuadrilla’s previous and proposed sites since 2001 so qualify as a local.

Several of my blogs have been on fracking and related issues

ed9/2/15 The irony is the first paragraph of RAFF’s leaflet;

It has become apparent that the UK government and gas and oil drilling companies have not been honest about the risks involved with shale gas development. PR consultants have been employed to disseminate misleading information to strengthen the case to extract shale gas in the UK.

It seems that the ASA did not quite agree with this claim

 

 

Complaint to the Advertising Standards Authority against leaflets distributed by ‘Stop Fylde Fracking’ and ‘RAFF’ (Residents against Fylde Fracking) in summer 2014
Presented by Michael Roberts, and Ken Wilkinson. 19 August 2014

The leaflet we would like to complain about is available online here http://stopfyldefracking.org.uk/wp-content/uploads/2012/03/RAFF-BROCHURE-4-PAGE-NEW.compressed.pdf and has been distributed as hard copy in numerous meetings in the Fylde area. There are numerous inaccuracies in this document, and in view of the public interest in this, it is important that these inaccuracies are brought to light. Many inaccuracies are based upon reported poor practice in the USA, which are genuine concerns, recognized by the Royal Academy of Engineering report https://royalsociety.org/policy/projects/shale-gas-extraction/report/  in 2012. This led to recommendations https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/49541/7269-government-response-sg-report-.pdf that have been incorporated into recent regulation. There are also many points raised by RAFF that are either irrelevant, incorrect, or bad science. It is wrong for this group to attempt to influence public opinion using false arguments. This is but a selection of what could be many more complaints.
Page 1
Complaint 1  ‘Hydraulic Fracturing, established technique, or new technology?’
The history of this technique is summarized here https://en.wikipedia.org/wiki/Hydraulic_fracturing_in_the_United_Kingdom#History . This paper http://fracfocus.org/sites/default/files/publications/hydraulic_fracturing_101.pdf suggests a 30 plus year history of shale gas fracking. As such this is false.
Complaint 2. ‘ What is the difference? Drilling for unconventional shale gas utilizes horizontal wells and…. ‘
The comparison was made with Wytch Farm https://en.wikipedia.org/wiki/Wytch_Farm#Environment. In fact Wytch Farm has around 100 wells, drilled from 10 well pads, and it uses horizontal drilling as a matter of course. It had the world record of a 10.5 km horizontal well. The reason for this is that to access the oil and gas, it has to be done in a World Heritage site, and AONB, in an area of very high property values. Horizontal drilling was developed in the North Sea, and is a well established technique.
Complaint 3. ‘Drilling would be intensive and on a large scale’ and the photo of the Jonah gas ¬field, Wyoming, USA (on page 3).
Drilling is covered by local planning consents, and the type of development suggested would be unlikely to gain permission. The Jonah gas field is a conventional vertically drilled gas field in the desert 30 years ago, when horizontal drilling was in its infancy. As such there was no reason to use horizontal drilling in this environmentally uninteresting area. Modern technology allows for 10 wells to be placed on a 2 acre site, each well being the source of up to 4 separate ‘laterals’, or steered horizontal wells, a total of 40 wells. That would be able to access gas from a radius of several kilometres, with no surface evidence, except the access road(s). Like Wytch farm, buried pipelines would mean that the public are hardly aware of any infrastructure. As such this information ignores latest technology, and is misleading. It is also subject to local planning consents.

Here is the photo of the Jonah Gas field. M Roberts drove past the field in 2012 passing within 400 yds of wells, but found it no more intrusive than other oil/gas fields

Complaint 4. The image of burning flares on Page 1 and 4.
We are unsure of the provenance of this image but believe that it is flaring of gas produced with oil. Any flaring in the UK would be short term, (up to 30 days typically) and is required by the Environment Agency (EA) to use low noise, low impact burners. ‘Green completions’, where gas is collected and used are highly likely, and are included if possible as this is ‘best practice’http://www.cuadrillaresources.com/about-us/best-practice/ . As such this information ignores latest technology, does not follow UK permitted procedures, and is misleading. This is covered in this publication https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277219/Air.pdf.

Page 2
Complaint 5 ‘Regulation’. ‘No regulation specific to the onshore unconventional shale gas industry exists’ and ‘The EA’s hands off¬ approach relies on the drilling company to self regulate’
This is simply untrue. The various regulatory agencies have all prepared and reviewed their practices to accommodate shale gas exploration. This series of publications  https://www.gov.uk/government/publications/about-shale-gas-and-hydraulic-fracturing-fracking present this information to the public, and shale specific regulations  https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/283834/Regulation_v3.pdf are in place from the HSE http://www.hse.gov.uk/shale-gas/assets/docs/shale-gas.pdf , Environment Agency, DECC, UKOOG. (see this link https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265988/Onshore_UK_oil_and_gas_exploration_England_Dec13_contents.pdf as well). In addition, OUOG https://www.gov.uk/government/groups/office-of-unconventional-gas-and-oil-ougo  has been set up specifically to deal with these issues. As every action is covered by a licence http://www.ukoog.org.uk/knowledge-base/regulation/what-is-the-process , it is false to claim that there is no regulation. Much regulation is pertinent to the process of drilling and this is no different from conventional oil/gas wells. In addition BAT, (Best Available Technique)  https://www.gov.uk/government/publications/regulatory-roadmap-onshore-oil-and-gas-exploration-in-the-uk-regulation-and-best-practice is required which means that rather than following a prescriptive regulatory standard, the agencies can require improvements as technology improves.
Complaint 6 ‘In 2012, Steve Walker of the Health and Safety Executive (HSE), a key shale gas regulator, admitted they had failed to inspect Cuadrillas‘ wells in Lancashire.’
This is totally at odds with this link which reports 10 visitshttp://www.cuadrillaresources.com/protecting-our-environment/how-are-we-regulated/  . The EA and HSE have agreed to jointly inspect operations.
Complaint 7 ‘Chemicals’ ‘a chemical spill of Calcium Di Hydroxide at iGas’ Barton Moss site’
This does not indicate a lack of regulation, but a minor accident. Regulation, enforced by the EA, requires that the well pads must be chemical-proof http://www.cuadrillaresources.com/protecting-our-environment/water/ , and assessed against flooding risk to mitigate mishaps such as this which can occur in any industry. In any event, Calcium Dihydroxide is not hazardous. http://www.icca-chem.org/Portal/SafetySummarySheets/634578159377315274_PSS%20Ca%28OH%292_V01.pdf
Complaint 8 Chemicals used in the extraction process …. as well as BTEX volatile organic compounds; Benzene, Toluene, Ethylbenzene and Xylene, which return to surface with the gas….. in the USA people living near shale gas wells have found drilling chemicals in their blood and organs,….
None of these chemicals have been licenced by the EA. The EA require that in the UK, operators must show the Environment Agency that all such chemicals are non-hazardous in their intended application. (See page 4 of this link https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265972/Developing_Onshore_Shale_Gas_and_Oil__Facts_about_Fracking_131213.pdf ) In view of the carcinogenic properties of these chemicals there is no evidence to suggest that these would ever be permitted. The nature of chemicals must also be made public. The implication is that this would be included in the current plans, which is false. This also ignores the fundamental differences in regulation of fugitive emissions, controlled by the EA https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277219/Air.pdf . It also ignores the judgement of scientists at the Health Protection Agency (HPA) http://www.hpa.org.uk/webc/HPAwebFile/HPAweb_C/1317141391233 .
The assertion that drilling chemicals have been found in the blood and organs of people in the USA is highly contentious and would not happen here due to the regulation required. We believe it to be yet more scaremongering as all drilling chemicals need to be licenced by the EA. This link http://www.dartenergyscotland.co.uk/images/documents/Dart_Closing_Submissions-Mr_Steele_QC.pdf  (Pages 34 to 39) shows that claims such as these have been made before, and have no basis in fact. All additives are individually assessed and required to be non hazardous.
Complaint 9 ‘Well leaks… 6% of wells leak immediately, with 50% leaking within 15 years… Well integrity is a chronic problem that the oil and gas industry do not know how to fix.’
This is a common misconception and it is false. This is based on a paper from Schlumberger http://www2.gnb.ca/content/dam/gnb/Departments/en/pdf/Publications/MudCement2003.pdf , in 2003. In this, the problem of ‘sustained casing pressure’ is tackled, and the company helpfully provides a solution! Wells have a number of barriers to leaking gas, and a single leak is not good, but it does not necessarily mean a leak of fluids to the environment. It is also fixable by ‘squeezing’ cement, so the idea that ‘the industry does not know how to fix ‘ is false. The technique is described here http://petrowiki.spe.org/Remedial_cementing  . Leaks in the USA that have been heavily publicized have all been repaired. Further details are available on this link  . https://en.wikipedia.org/wiki/Hydraulic_fracturing_in_the_United_Kingdom#Well_leak_concerns There are currently no wells leaking in the UK https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/268623/13_1664.pdf , with over 2000 land wells, and 6500 offshore wells. There were some historical prblems but these have been fixed. This paper http://www.spe.org/atce/2013/pages/schedule/tech_program/documents/spe166142-page1.pdf  indicates ‘true well integrity failure rates are two to three orders of magnitude lower than single barrier failure rates’ This is inaccurate, misleading and scaremongering.
Page 3
Complaint 10 ‘Where does the waste go’….. ‘vast quantities of hazardous wastewater also called flowback. It contains water, toxic chemicals, heavy metals, radioactive materials including Uranium, Thorium, Radium, Lead and Radon….. radioactive drill cuttings, however, a radioactive waste permit is not required.’
The treatment of flow back water and drill cuttings is covered by licencing from the EA https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265988/Onshore_UK_oil_and_gas_exploration_England_Dec13_contents.pdf  , (Page 23 on) under ‘Environmental Permitting Regulations’ as it is a ‘type 2 NORM industrial activity’ similar to many mining and extractive industries. It is open to public consultation as can be seen here https://consult.environment-agency.gov.uk/portal/npsapp/dartenergy/dart_energy_west_england_limited  . The levels of radioactivity are monitored. Radioactivity and microscopic amounts of many materials are present in food, building materials, soil, the human body and yes, drill cuttings. The question is at what concentration? The main ‘toxic’ chemical is salt. This BBC report  http://www.bbc.co.uk/news/uk-england-25902272 covers the main issues, indicating that the EA have tightened regulations, and that treatment methods http://www.resource.uk.com/article/Comment/water039s_fine-3365#.U_Oiuf1wapq  mean that the fluid can be disposed of safely. As such this is both false, and is scaremongering.
Complaint 11 ‘toxic chemicals that rise to the surface with the gas are also discharged into the atmosphere. This results in poisonous air pollution’
Covered in this publication   https://consult.environment-agency.gov.uk/portal/npsapp/dartenergy/dart_energy_west_england_limited . Use of the words ‘toxic’, and ‘poisonous’ is false and scaremongering. The gas that would be produced is mainly methane, and that would be collected, or burned, leaving no toxic products. Like much of the output from protestors, this is based on the open storage of flowback fluids. The EA and EU require enclosed steel tanks.
Complaint 12 The use of the image of the overflow pipe, ‘draining into the river Ribble’.
This pipe has been installed under licence from the EA, and is part of the drainage and storage of rain runoff. It is not a ‘secret’ chemical disposal point. As such this is scaremongering by people who have not bothered to enquire as to what this was for. Cuadrilla’s website http://www.cuadrillaresources.com/protecting-our-environment/water/  shows the construction of this and clearly a chemical proof pad will need to be drained after rain, after checking that there is no chemical contamination.

Page 4
Complaint 13 ‘Water contamination…etc ‘
There is ‘no medical evidence’ to support the Hollowitch case described, as can be seen herehttp://energyindepth.org/wp-content/uploads/marcellus/2013/03/Affidavit.pdf  . In addition, no pollution that could be ascribed to drilling was found by the authorities http://energyindepth.org/wp-content/uploads/2010/09/DEP-Response-Letter-to-Hallowich-08-12-2009-3.pdf  . As such the claim of a gagging order seems rather bizarre.
There have been many claims about methane contamination of water wells due to shale gas fracking, and it has been difficult to prove this as no base line measures were made in many cases (such as the one above). The British Geological Survey have recently completed a baseline survey http://www.bgs.ac.uk/research/groundwater/shaleGas/methaneBaseline/results.html  to inform any claims. In addition the Royal Academy of Engineering report https://royalsociety.org/~/media/Royal_Society_Content/policy/projects/shale-gas/2012-06-28-Shale-gas.pdf  recognized this as a problem area and best practice in well design are required by the HSE.
The RAE report https://royalsociety.org/~/media/Royal_Society_Content/policy/projects/shale-gas/2012-06-28-Shale-gas.pdf  also indicated that there has never been a case of fracking fluids entering aquifers in the USA, (see page 12, para 1.4.1) although this was an area of concern, regarding well design, and the separation of aquifers and shale formations. The reported AAP article appears to be this one  https://royalsociety.org/~/media/Royal_Society_Content/policy/projects/shale-gas/2012-06-28-Shale-gas.pdf , and the only contaminant mentioned is methane, which is non toxic.

Unfortunately the ASA has provided support for RAFF in the past. This is frequently referred to by those who are against this technology. Many of the ASA sustained complaints http://www.asa.org.uk/Rulings/Adjudications/2013/4/Cuadrilla-Resources-Ltd/SHP_ADJ_203806.aspx#.U_Okx_1wapp  seem tenuous, but one, that hydrochloric acid is ‘toxic’ is simply incorrect. The stated reference, the HPA, does NOT classify this chemical as ‘toxic’, merely as ‘irritant’, and in high concentrations, as ‘corrosive’ as can be seen here, on Page 13 http://www.asa.org.uk/Rulings/Adjudications/2013/4/Cuadrilla-Resources-Ltd/SHP_ADJ_203806.aspx#.U_Okx_1wapp  . (The designations of ‘toxic’ refer to hydrogen chloride, not hydrochloric acid.)
We feel it is a matter of public interest have full judgments made. There are court cases arising from legal, well researched drilling plans being opposed on false grounds. In addition, policing of ill-informed protest is costly for the UK as a whole, yet the ‘anti fracking’ movement seems able to present these false arguments with no comment.

Regards, Michael Roberts, and Ken Wilkinson