Tag Archives: health

Ken Wilkinson on Fracking (Harrogate 6/10/16)

On 6th October Ken Wilkinson gave a talk at a debate in Harrogate with Lorraine Allanson was the second speaker.. He was opposed by john Plummer, a local FoE bod (fresh from the exposure of FoE’s porkies in The Times and,Ian Crane, a chemtrails expert, who claims oil experience but confirmed to Ken that he worked in HR, and so has NO experience of drilling. Apparently he was very high in Schlumberger HR. If you enjoy chemtrails read this   . It was part of a debate given mostly to anti-frackers, but here is Kens’s contribution. As the meeting was mostly fractivists he lost the debate but won the argument!! Ken says, “the audience was largely against, they had to look through the evidence. I cant help thinking that will have made some question why they are ‘anti’, in view of the fact that their evidence based on bullshit. The hard liners will never change, but others….I really enjoyed the presentation, and had a smile on my face all the time! Very little has been said on social media about this. That to me speaks volumes.”

 

(apologies for the poor presentation of the pictorial evidence as the PDF used was not being co-operative with me!)

Ken on Fracking 6th October 2016

I have come here today to help dispel the tidal wave of misinformation that surrounds the well established process known as fracking. I have suitable qualifications, and 12 years of oil and gas engineering experience to support my research.  I am not an expert, but know people who are. I have no affiliations with the industry and am totally unpaid for this.

Many may wonder why I spend my time doing this. I campaigned intensely several years ago against a charity that denied access to my favorite paragliding site. I ran a website, lead protest marches that were covered by the TV, and had MPs involved. I believe in  campaigning against something that I feel is wrong or unjust.

Having industry knowledge, I was shocked at the lack of understanding displayed by protesters and I started to research and fight back. In a public meeting I challenged Frack Free Somerset and they were unable to answer my questions. ‘The Truth Behind the Dash for Gas’ had been shown in one of Ian Crane’s propaganda films. It showed sobbing people, and terrible events, but was based on a limited number of facts and was aimed primarily at scaring people.

I brought Advertising Standards complaints against a leaflet distributed by Frack Free Somerset and they had to withdraw and promise not to repeat their claims. I followed that with a complaint against Resident Action on Fylde Fracking, in Lancashire.  Again they had to withdraw, and the same for Frack Free Alliance and Breast Cancer UK.  Frack Free Ryedale also made false claims in an advert, involving claims that fracking would industrialise the countryside. They also withdrew. I am not very popular with them!

Please note that I am merely a retired teacher with a keyboard, and my views are independent. None of these groups wanted to be challenged, yet when they were asked to sustain what they presented to the public, they were unable to provide credible evidence.

That’s the problem with the fracking debate. There is so much dubious information. A few historical incidents from some poorly regulated states in America are presented as systematic problems. The retired Governor of Pennsylvania recently stated, ‘we didn’t regulate well construction and frack water as well as we should have at the time. We cured that in 2010, and we haven’t had any significant incidents since.

Similarly in Australia, there have been concerns about coal seam gas extraction. Shallow coal seam gas is a completely different technique to deep shale gas extraction, but the main point is how well controlled has this been? How well were regulations applied? What were the regulations? In the UK, operators satisfy regulators on numerous aspects of safety. These are the latest regulations and they are extensive. (Hold up regulations)

You could say the same about the aircraft industry. At the start, flying was very risky. Engineers addressed the problems. Now aircraft are incredibly reliable, from an engineering perspective.

Public health England have noted that ‘Where potential risks have been identified in the literature, the reported problems are typically a result of operational failure and a poor regulatory environment’

Many are critical of UK regulation, yet the Institute of Mechanical Engineers concluded recently ‘ONSHORE oil and gas operations have been managed safety and with minimal impact on the UK’s natural and human environment for over 100 years. The current UK “Goal Setting” Regulatory Regime has been found to be robust and effective. The UK Regime is significantly different to that in the US.

The problem with the fracking debate is that it is infected with dubious information. Looking at health, hundreds of supposed scientific papers have been published in the US, claiming to find links between health and fracking. Just recently there was a well publicised paper that claimed to find that living near a well led to an increase in asthma.  Please now look at the Evidence sheet that was on your seat as you came in. Evidence 1 on the sheet shows dots for wells and dark areas for asthma hotspots.  As you can see for yourself, there is no link between asthma and drilling.

asthma

Evidence 1

The most drilled areas have the least asthma (A)
The least drilled areas have the most asthma (B),
(Darker = more asthma, the dots are the new wells)

The Pennsylvania Department of Health conducted their own investigation and discovered that in the same time period, asthma actually decreased by 26%. See Evidence 2 on the Evidence sheet.

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So contrary to what you have been told, the researchers own data showed that the counties in the US with the most drilling, had the least cases of asthma!

In Pennsylvania, that is not surprising as the pollutants from coal production have massively reduced due to the corresponding increase in gas production.  This has led to significant  reductions in lung complaints, and that is down to swopping coal for gas.

There is a load of money available from US anti fossil fuel groups such as the Sierra Club, and Park Foundation to fund anti fracking studies that support their pre-conceived ideas.  This is what we call “bad science “ as it is not capable to withstand scientific scrutiny.  The same researcher and his group have also published about premature babies. Again, expert scrutiny has completely dismissed their claims, but it doesn’t stop the sensation seeking press from running these stories. You have to ask yourself the question. If there are so many health effects, why do Public Health England reject these concerns? Why have there been no health related lawsuits? Where are the wards full of sick people?

The Medact Report has influenced many, and the press release in 2015 indicated that there were clear links to serious health issues. The chemicals they report on are NOT PERMITTED IN THE UK!  While not an apology, Medact did recognise their mistake and issued an updated report in 2016 that now states ‘Based on current evidence it is not possible to conclude that there is a strong association between shale gas related pollution and negative local health effects’.You can see these words in Evidence 3 of your Evidence sheet.

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In other words, out of all of the hundreds of published papers that were reviewed, they are now unable to find a single one that finds a conclusive link between fracking and health! That’s a shocking finding that the public need to be made aware of.

 

They then state that one health issue could be ‘stress, anxiety and other psycho-social effects’.  Scaremongering can become a self fulfilling prophecy.  If people are constantly being told that fracking will be bad for their health, of course, it will cause an increase in stress!

Public Health England are a statutory consultee in fracking applications. That means that they have to keep up with new developments. In the Lancashire Planning committee report, they dismissed the Medact report and other oft cited papers as bad science. Science is based on evidence, and there is nothing conclusive, even from the US. This has been confirmed by dozens of expert bodies that have investigated the process who have all confirmed that it can be done safely if done properly.  I refer you to these expert bodies in Evidence 4 on your Evidence sheet.

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The Royal Society, The Royal Academy of Engineering, the British Geological survey and so on. These are the top brains of UK science. In truth this is just a small sample of the expert groups that say that well regulated fracking is low risk. That is engineers speak for safe.

Friends of the Earth have been central in providing support for many anti fracking groups that have sprung up everywhere. They recently distributed a leaflet that made many questionable claims, in that ‘toxic and carcinogenic, materials would be used in fracking. (See Evidence 5).

FoE’s dodgy leaflet

foeadvert

Most people think that Friends of the Earth are a well meaning charity, but in fact there are two Friends of the Earths, one that acts as a charity that can legitimately raise money and the other that acts like a PR machine, scaring people to raise money for their charity company. This has been set up to avoid Charity Commission attention. The main fundraiser for Friends of the Earth limited is fracking. They have suffered drops in income in recent years so fracking is the new cash cow. To rally the troops they are begging for money using scaremongering claims. In law, the Environmental Permitting regulations 2010, schedule 22, paragraph 4 states that carcinogenic and toxic materials are classed as ‘hazardous’ and the Environment Agency will not permit them to be used under any circumstances. Please see evidence 6 with the exact wording in law.

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As you may expect, I brought a complaint to the Advertising Standards Authority. The inability of Friends of the Earth to sustain their false claims was highlighted on the front page of the Times recently. Please refer to Evidence 7 on your Evidence sheet.

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After 9 months of delaying tactics, Friends of the Earth have been unable to provide credible evidence for their leaflet. The judgement was a draft but someone (not me) leaked it to the press. It is damning in its criticism of Friends of the Earth. All four complaints were provisionally upheld.

In truth, Friends of the Earth limited have always known that their claims were false and when Tony Bosworth was questioned about carcinogenic materials on BBCs North West tonight, he said that the carcinogenic material they were concerned about was sand. Yes, you did hear that correctly, the same sand that your kids play with on the beach. The next day the Times headline was ‘Fracking opponents ridiculed for claiming sand is a cancer risk’.  

They also claim that polyacrylamide causes cancer, and is used in frack fluid.

(Drink water now)

This is polyacrylamide. I bought this as a ‘non toxic childrens toy’.

To be fair, it is hazardous, as it’s a choke hazard for children under 3. Its also a soil conditioner, and is used in lip fillers and nappies!

Hopefully this complaint against Friends of the Earth will come to a judgement shortly. As I said earlier, Friends of the Earth use a limited company to avoid the attentions of the Charity Commission. They scare you with one hand called Friends of the Earth which is a limited company, and they receive money with the other hand, also called Friends of the Earth, which is a charity. The Charity Commission will not allow charities to tell lies as they class that as ‘political activity’.

In 2012, during the Moratorium on fracking, the Royal Society and the Royal Academy of Engineering published a report about shale gas. They identified 10 recommendations. The process for implementation was set in place in 2012. Many may have heard claims that ‘only one of these has been put in place’. That is demonstrably false. I have been advised that 6 are in place and the rest are ongoing.

The Health and Safety Executive are responsible for well design and safety. They have regulated the North Sea for decades and our regulations are world class. The sealing of wells is paramount. The HSE require two lines of defence both internally and externally and on top of that, the Environment Agency require an extra layer of casing both above and below the aquifer.  This is to ensure wells do not leak and have virtually no chance of contaminating an aquifer.  In a poorly regulated state or country, it is possible to have incidents and I can refer you to Evidence 8 in your Evidence sheet.

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You can see that the drilling company has left parts of the well unsealed, but even a well like this can be repaired to make it safe using modern technology and engineering practices. No case of deep fraccing fluids entering shallow aquifers has ever been documented, as noted in the Royal Academy report.

Many are worried about old wells leaking. Often claims are made that ‘60%’ of wells will leak in time. This data refers to ‘Sustained Casing Pressure’ which is an internal leak where the gas does not get into the environment.  Real leaks to the environment are very rare indeed with gas detectors at surface that would pick up a leak very quickly.  and alert the company so that the well can be shut in using a remotely operated surface valve.

Corrosion is another worry, and I worked on this in the 1980s, and so have some direct experience. If a well is properly sealed then fluids cannot move. That means no corrosion can take place. Is anyone worried about New York’s Empire State building falling over? That is made of cement and steel buried underground in a salty environment, just like a gas well. It has survived for nearly 100 years!

In terms of seismic risk, there is a vanishingly small risk that a tiny tremor, like the one in Blackpool could occur which measured 2.3 on the Richter scale.  Again, seismic specialists have researched this extensively and have regulated the process with a traffic light system to mitigate the risk of this ever happening again.

Earthquakes in the US that have been attributed to fracking are in fact from disposal wells. Disposal of fracking fluids in this manner is not permitted in the UK under any circumstances by the Environment Agency.

Pollution incidents from the US which are not permissible in the UK include:

  • Leaking fluids from open storage pits. These are not permitted in the UK due to risk of flooding and splitting. See evidence 9
  • kw9
  • spills from unlined well-pads. Impermeable membranes to mitigate any chemical spill are required in the UK. See evidence 10

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Truck accidents are another worry.  Do we stop the delivery of food to supermarkets or petrol to petrol stations due to accident risk? Or do we get experienced drivers on well maintained trucks to mitigate the hazard?

Many are concerned about water pollution, yet drilling is not even allowed in water extraction areas. In the UK all the chemicals that are used by drilling companies have to be disclosed and provided to the EA for testing and approval.  No chemicals that are hazardous to aquifers or groundwater are allowed under any circumstance. Strong EU environmental Directives like the Water Framework Directive have taken away Friends of the Earth’s campaign rationale. Beaches, rivers, and water must be  clean, pollution must be controlled, industries must be licenced and any breaches of law can and do result in warnings which if not acted upon will be followed by prosecution.

Shale gas production could be spectacular. It has been calculated that a single drilling rig, drilling at the same rate as in the US, could supply London, in 3 years! Advances in fracking techniques mean that well production rates decline much slower than before and shale wells in the US currently produce more than double the total output of traditional gas wells. A single well-pad could have 40 wells, producing for 20 years, all hidden behind trees, This will lead to tax revenues, and local jobs. Drilling would be slower in the UK, due to the high level of regulation, BUT the point is that the scare stories are just that. Scare stories. Nobody is proposing the types of drilling and industrialisation shown in evidence 11 on your Evidence sheet.

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Using modern directional drilling techniques, well pads can be spaced miles apart, not hundreds of yards. The actual plans are for well hidden well-pads with multiple wells as shown in evidence 12.

km8-site

 

Who knows where the 10 wellpads are in the Vale of Pickering area? So why do groups like Frack Free Ryedale and Friends of the Earth deliberately try to deceive the public?

Others worry that the water used in fracking that is not removed from the well will magically rise against the force of gravity and the thousands of feet of rock above it to pollute the water supplies above. In fact, the Royal Academy of Engineering report noted that this will not happen in the UK. Even if it did the chemicals are non hazardous.

Like you, Lorraine and I are concerned about climate change. We would love renewables to work but solar and wind currently produce a tiny percentage of our energy usage.

There is currently no practical storage for large amounts of electricity in the UK. Many talk about electricity as ‘energy’  but that is only 1/5th of our use. What about heating, transport, and industry. They are almost entirely fossil fuel based.

The US has reduced its carbon output massively as it has switched from coal to gas. As I mentioned before there is a massive health benefit in doing this as coal pollutants are no longer released. All projections show that we are going to be using gas for decades to come.

The only question is where it comes from.  We are currently importing over half of our gas usage. This is predicted to rise to around 80% in a few years.

The clear evidence of the 2013 Mackay Stone report on greenhouse gas impacts from using gas show that locally produced shale gas is the best option. Gas from Russia comes through long pipelines. Liquified Gas from Qatar needs lots of energy to cool it, and to transport it and gasify it again. The gas with the least hydrocarbon footprint comes from under our feet.

There are no significant leak pathways in drilling and fracking so what is the problem? If the HSE tolerated leaks we would have many more explosions in our houses, our kitchens, industries and the pipelines under our roads.  In the UK flaring is not allowed other than for a short period to test the wells.  As Kirby Misperton flaring will not be required as the pipelines are already in place.  In Lancashire, they will use shrouded flares, for exploration, which are required to be quiet and efficient. Once a pipeline is installed then green completions would mean that no gas would be vented at all. Again, when looked at, these are minor concerns.

We are surrounded by incredible technology. Planes, phones, medicine, and space technology have all have seen amazing advances using UK scientists.

Recently, Crossrail meant that a 7m wide tunnel was drilled under the most expensive property in the world. Did anyone say it would not be safe.  Of course not. We expect these things to be done with educated and experienced people, who know what they are doing. Why is the shale drilling industry held to a different level of accountability?

After several years of investigating this, I still am at a loss to understand what is so concerning about fracking. Is it purely the use of the F word and all the connotations that can be derived from it. Is it the fact that minority groups need another cause to get behind just like they did in the past with fox hunting, apartheid, and anti abortionism.  Or is it the case the there are some countries who do not want to see the UK become self reliant on energy again.  I don’t know, but what I do know is that the public are being grossly misled by organisations like FoE and other protest groups.  Fracking ladies and gentlemen can be done safely, it can be done safely environmentally , it does not increase health risks, it can bring many benefits to both the region and the UK and with all these factors in mind, I urge you to repel the motion in front of you.

 

 

 

Medact’s madact on Fracking

Update on Medact; On Thursday 18th June there will be a presentation of the Medact report on Health and Fracking at the Minster in Preston, where they will push the supposed heath risks of fracking, It is regrettable that Medact did not revise their paper to bring it into line with Public Health England. From what we saw at the launch in London we expect the same ill-founded concerns.

Shale Gas Task Force is very critical of Medact Report https://darkroom.taskforceonshalegas.uk/original/e4d05cb29b0269c2a394685dad7516e6:c48ffe7884e9b668b8d4b7799a027874/task-force-on-shale-gas-assessing-the-impact-of-shale-gas-on-the-local-environment-and-health.pdf

See page 29

added 15/7/15

I would still like to know what evidence there is of increased illness in the vicinity of onshore wells in Britain.

Perhaps we should ask if there has been a spike in cancers in Elswick where there has been gas well for over 20 years.

 

medact

On Monday 30th March 2015 Medact launched their report on the health effects of fracking http://www.medact.org/wp-content/uploads/2015/03/medact_fracking-report_WEB3.pdf . Its conclusions are very different to that of Public Health England (PHE) last year https://www.gov.uk/government/publications/shale-gas-extraction-review-of-the-potential-public-health-impacts-of-exposures-to-chemical-and-radioactive-pollutants

Reaction to the Medact report has been swift. It has been welcomed by anti-fracking groups, but has received criticism;  http://oesg.org.uk/news/medact-fracking-report-criticised-by-sme-trade-body/     : and  http://frackland.blogspot.co.uk/2015/03/medact-vs-british-columbia.html where Dr Verdon compares it unfavourably to a recent Canadian Report.

and also the critical response from UKOOG, published in April; .http://www.ukoog.org.uk/about-ukoog/press-releases/146-shale-gas-industry-says-medact-report-fails-to-understand-uk-regulatory-system-and-lacks-credibility

But here is an open letter to Medact from Ken Wilkinson highlighting the flaws of the paper.

Open letter to Medact, calling for the withdrawal of the recently issued Health and Fracking publication.

The reason I am writing this that I am concerned about fundamental flaws in the publication mentioned above. Each one of these is in itself a cause for withdrawal, and the totality means that the only ethical course for Medact is to withdraw the publication for review. As seasoned academics, you will of course accept that clear evidence of fundamental flaws would damn any research that your students might undertake, and lead to its rejection.

I have to state that I am totally independent in my views, and would describe myself as pro fact, rather than pro fracking. I have no financial interests at all, and I value that status. Like many, I give my time up for free for a cause that I believe in (the truth). I am recently retired and this gives me the time to research, when I am not doing my many sporting activities, and volunteering in a tough inner city school.

I have 12 years of experience working as a wireline engineer, finishing up as the most senior engineer in my company, in Libya. I dealt with customer liaison, problem wells, and jobs, and so had to know my stuff. I left in 1990 to become a Physics teacher.

It was made clear in all of the evening discussions, that Medact wanted to bring clarity to the debate. Dr Mccoy discussed this with me at the end of the evening. I am afraid this report brings false data and yet more confusion. It is little more than a propaganda piece for ‘anti’ frackers, not surprising when one of the report’s authors is an anti frack campaigner.

The Medact board is clearly a group of highly qualified academics that have great concerns concerning Climate Change, Global Warming, environmental pollution and health matters. These are issues that I (a humble BSC in Engineering) have great sympathy with. The planet could be on a path to destruction and there needs to be change. The problem would seem to be that simply publicising climate change issues would probably not have the desired effect of forcing a stop to fracking.

It is however unacceptable to present false science to ‘win the argument’ to stop fracking, by scaremongering and citing risks that do not exist in the UK regulatory environment.

Fundamental Flaw No 1

It would seem that Medact is publicising issues of health and safety that will not exist in the UK context. The fact is that there are many differences between practice in the US and the UK. These have not been considered. I would hope that this is due to misinformation only from Mike Hill, rather than the rest of the panel. He does not seem to have a grasp of many basic drilling concepts and has no relevant qualifications. I do not believe he has any experience of fracking, and not much, if any, of drilling. The fact that he so frequently refers to himself as an ‘expert’ is in itself odd. How many doctors would do that? Please see

http://www.thetimes.co.uk/tto/environment/article4397734.ece?shareToken=2ec2db188503e903f28d010eee37c321

http://order-order.com/people/mike-hill/

The clear evidence is that one of the main authors of your report is an anti-frack campaigner. This means that any credibility for Medact immediately vanishes. The Times article states that Dr McCoy was unaware that Mr Hill was standing as an MP on the single issue of opposition to fracking.

http://votehill.org/wp-content/uploads/2015/02/PR08-the-big-risk-press-release-Web.pdf

Fundamental Flaw No 2

At the launch of the report it quickly became apparent that the board had no idea that the use of chemicals in drilling is controlled by laws from the EU and the Environment Agency, the regulatory body concerning risks to groundwater. In particular the JAGDAG list of proscribed chemicals is not mentioned anywhere in the report. As benzene is mentioned in the report it is worth mentioning that this is on List 1 (Hazardous pollutant), along with many other nasty chemicals.

In Balcombe, Cuadrilla wanted to use antimony trioxide in drilling mud. This is a common chemical but permission was denied. Human studies are inconclusive regarding antimony trioxide exposure and cancer, and it is not classed as a carcinogen, but animal studies have indicated it may possibly be a risk. This indicates that the EA regulatory system works.

The European wide Groundwater Directive is European legislation that states. In order to protect the environment as a whole, and human health in particular, detrimental concentrations of harmful pollutants in groundwater must be avoided, prevented or reduced

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0118

The Environment Agency is also covered by statutory instrument.

The pollutants the Environment Agency are concerned with for groundwater are

    • Hazardous substances, which are substances or groups of substances that are toxic, persistent and liable to bioaccumulate, and other substances or groups of substances that give rise to an equivalent level of concern.
  • Any non-hazardous pollutants, which is ‘any pollutant other than a hazardous substance.http://www.legislation.gov.uk/ukdsi/2010/9780111491423/schedule/22http://www.wfduk.org/sites/default/files/Media/Substances%20transferred%20from%20List%20I%20%26%20II%20to%20hazardous%20or%20non%20hazardous.pdfThis list is under revision to accommodate fracking, and chemicals likely to be requested are being classified.Benzene occurs naturally at very low concentrations in shale gas (parts per billion) and the levels of benzene are similar to domestic gas. Benzene is also found in high concentrations in petrol stations, and near roads.So much of this report relies on the idea that chemical usage is unrestricted. As a point of information, the many toxic chemicals that have been used in the US is largely historic, as the properties needed can be achieved by using food additive based materials. Only 3 materials have been permitted so far. (Polyacrylomide, Glutaraldehyde, and Hydrochloric acid.) In addition the US is moving to compulsory declaration of chemicals.Fundamental Flaw No 3. Failure to understand crucial differences in fluid handling, US/UKhttps://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277211/Water.pdfOther fluid protection requirements are listed on pages 3 and 4, and these should satisfy most that this has been looked at (by the Royal Academy of Engineering, in 2012) and that these requirements have been put in place, to avoid the small number of issues from the US experience.https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/277219/Air.pdfAgain this means that the 400+ studies can be ignored, as they are mainly US based.I am not aware of any protests concerning a 7m wide tunnel drilled under London recently (Crossrail). We all assume that the engineers will do their jobs properly and self-regulate. Why should fracking any different? Tying in with the links above, a whole series of information papers has been made available for over a year to inform the public that their genuine concerns are being addressed. It is strange that Mr Hill has been unaware of these, as we (Rev Michael Roberts and myself) referred to some of these in our Advertising Standards Authority complaints against RAFF (Resident Action on Fylde Fracking). I understand Mike is RAFF’s technical ‘go to’ person. RAFF were unable to sustain their false claims and they withdrew the article to avoid the public humiliation of having judgements go against them. (The majority of our complaints were provisionally upheld BTW.) http://www.ukoog.org.uk/images/ukoog/pdfs/UKOOG_progress_in_meeting_Royal_Society_recommendations_March_2015.pdfThere are many other issues that I could raise, that I tried to discuss last night. I understand your desire to limit my speaking (I did speak a lot) but these points include.

 

  • UKOOG guidance on the progress of the 10 recommendations. (March 2015)
  • There are 10 publications, and they can be seen on https://www.gov.uk/government/publications/about-shale-gas-and-hydraulic-fracturing-fracking (Early 2014 mostly)
  • Fundamental Flaw No 4 Failure to take account of Govt issued information and other freely available literature.
  • Unlike several statements in your paper, there is NO evidence that fracking is an inherently risky activity, and pollution incidents have NEVER been the cause of aquifer pollution. It has always been leaking wells, illegal dumping, truck accidents and open pits etc. (There is one possible exception to that in Pavillion,Wyoming, where a frack job was done at very shallow depth, but even that is inconclusive)
  • Incidentally, examination of the above document also shows how the EA regulatory system works. They require the operator to supply plans to meet the concerns of the EA, using best practice, latest techniques etc. As technology moves on, best practice will always be required. It’s pretty well how every high tech industry works. ‘Regulation’ of doctors is by the Hippocratic oath, codes of conduct, professional standards, and communicating about the latest techniques. Doctors do not bleed patients like in the 18th century, and progress has been made without the use of statutory instruments.
  • In the UK, all oil and gas operators must minimise the release of gases as a condition of their licence from the Department of Energy and Climate Change (DECC). Natural gas may only be vented for safety reasons.
  • Another concern is the emission of VOCs (which is ONLY an issue with shale oil wells, and traditional oil wells). There are requirements that no gases are to be released except in an emergency. Please see page 2 of the following link.
  • make appropriate plans for storing fluid safely and not in open pits
  • On page 15, there is a statement that 33% of pollution incidents in the US have been due to ‘overflowing pits and failures of pit linings’. These are not permitted in the UK as can be seen here, on guidance for operators, page 4.
  • One fundamental misunderstanding is that emission of VOCs and benzene is ONLY a concern in shale oil wells. Shale gas has no evidence of these type of emissions, even in the US.
  • Many of the papers that refer to HF risks will have BTEX as the main causes of concern.
  • Benzene for instance is classed as List 1 ‘Hazardous’ and as such it is not permitted. The EA insist that all frack fluids must follow groundwater rules, even in areas where the water is not potable.
  • Classification of chemicals is covered by the JAGDAG list here
  • This can be seen on this link, in schedule 22, paras 4 and 5,
  • Failure of Mike Hill to accept that flaring will be done in enclosed burners, and that these have low emissions that have been investigated by the EA.
  • Failure to understand that a 30 stage injection frack job is like 30 separate frack jobs and is no big thing.
  • Failure of Mike Hill to understand that the PH1 well does NOT have an integrity failure. (Integrity means leaking to the environment, and the minor deformation of 0.1 inch ovality over 140 ft is below the regional seal. You need to understand wells to get this, and all of the evidence is that Mike Hill does not have that understanding)
  • References to ‘earthquake’ when this is not a significant risk and has been looked into with great detail, and academic research.
  • Failure to understand the limitations of bond logs in large casings (I used to run training sessions for oil company engineers on this and other matters many years ago. The technology has changed but the principles are the same)
  • Failure to understand that surface casing leaks with modern cementing are rare, and these would involve only methane, which is non toxic.
  • Scaremongering by suggesting a 60 multiwell pad would be an issue, when the surface impact would be not much more than a single well.
  • Ignoring the AMEC Environmental Impact Assessment and its conclusions. All of the concerns have been addressed, and mitigated, leading to low impact conclusions.
  • http://cuadrillaresources.com/wp-content/uploads/2014/06/RW_ERA.pdf
  • Ignoring the recent acceptance of fracking technology by Lancs CC and the EA in the case of the Cuadrilla wells. This indicates that the EA are happy with the environmental issues.
  • Suggesting that the HPE report is faulty as it should have considered issues of climate change when the HPE are not competent in that area.
  • Suggesting that the HPE report is faulty as it should consider noise/light issues when these are planning matters.
  • Inaccurate and misleading figures for truck movements due to piping of water and reinjection of flowback fluid.
  • Failure to highlight the one definitive paper that is undisputed, and peer reviewed by appropriately qualified people, (NOT anti-frack campaigners) and that shows undisputed HEALTH effects. The ones usually cited as exemplars are McKenzie 2012 (heavily criticised for poor science), and McKenzie 2014( rejected as bad science by the Colorado Chief Health officer) , and Elaine Hill (unpublished, criticised, but still cited in the New York ban)
  • http://energyindepth.org/national/the-dubious-scientific-foundation-for-new-yorks-fracking-ban/