● This is “the thin end of the wedge” in more ways than one
● This will very likely cause considerable disruption, if not damage, to the village and its surroundings for many years to come
● There are significant risks and genuine unknowns regarding public health and our environment
● We must act to stop this now, later is too late
Our Case Against the Proposal
● There is much uncertainty over what may eventually transpire on this site, partly because there are genuine unknowns.
● Whatever you believe about the risks to amenity, public health and the environment – and it's impossible for anyone, no matter how expert, to quantify these accurately – there is a strong chance* that – should this exploratory drilling be allowed – there will be some sort of intensive and disruptive industrial activity here for decades to come.
* Someone's prepared to bet several £m on it!
It's the “thin end of the wedge”
● This is the first application of its type in the SDNP
● Once “exploration” is permitted here, it will be much easier to argue for further development:
– elsewhere in the SNDP
– for production here, via further planning consent
– for other/expanded activities here, simply via 'permitted development' or other rights
– use of hydraulic fracturing does not require planning consent and could happen at any time, subject to other permits e.g. from the Environment Agency (EA)
● The fact that planning consent does not regulate the use of hydraulic fracturing per se reveals why Celtique's repeated statements like “use of hydraulic fracturing is not part of this application” are meaningless and, in our view, deliberately intended to mislead – they wouldn't specifically need planning consent to use this underground technique (they would need permits e.g. from the EA etc. but we have no real say in that process!).
If we don't block this application now, we are lost – Celtique know this very well; which is why they so persistently say “this is only temporary, only exploratory”
It's a very poor choice of site
● Even if you approve of this kind of activity in a National Park – for the record we don't – there are alternative sites which would be less damaging.
● The geology of interest covers thousands of acres, and horizontal drilling can be used for large distances (e.g. up to 11km at Wytch Farm in Dorset) to avoid placing a wellhead in a sensitive area. It follows that, other constraints aside, technically there is considerable flexibility over choice of site – of course horizontal/deviated drilling costs more, which is probably why it's not proposed!
● It is wrong that one key factor in site selection is simply the identification of a “compliant” landowner.
● There are alternative sites (yes, even in the SDNP):
– Which are much more than 1 mile from, and not upwind of (the prevailing wind affects noise, air quality etc.), the most densely populated area for miles – our village;
– Which are directly accessible from an 'A' road, or even a railway, obviating many hundreds of HGV and other traffic movements, over a prolonged period, through the most densely populated part of Fernhurst, down Vann Road;
– Which are further from significant water courses (ours feed Lod and Arun) and from ancient semi-natural woodland;
– Which are not adjacent to Scheduled Ancient Monuments (e.g. Furnace Pond);
– Which are further from homes and tourism-related businesses.
What Celtique Really Wants
● To prove that there are economically viable hydrocarbon reserves here, and then profit by selling on to a company like Centrica, IGas or Shell which would take the site from 'exploration' into 'production'.
● According to Celtique's website, including pages subsequently deleted but archived, there are two possible sources of hydrocarbons either/both being potentially exploitable:
Option 1 - Limestone
● There may be shale oil/gas in Kimmeridge or Oolitic limestones adjacent to Kimmeridge clay/shale at about 8,000 feet (2.4km) true vertical depth. This formation is deemed closely similar to the US Bakken shale in North Dakota – so called 'tight oil'.
● Extraction would involve:
– Multiple horizontal drill runs, closely spaced, extensive use of hydraulic fracturing plus the use of considerable volumes of acid to effectively dissolve the limestone, creating voids into which oil/gas can accumulate. This would be similar to the US Bakken shale extraction processes.
Option 2 - Shale
● There may be shale gas in a relatively thick layer of Liassic shales at about 11,000 feet (3.4km) true vertical
● Extraction would involve:
– Multiple horizontal drill runs closely spaced, high-volume hydraulic fracturing using 'slick water' containing proppants like silica sand. Even more than in option 1 above, this is the classic “fracking” activity which has caused so much concern in Texas and Pennsylvania, for example.
The bottom line...
● It's easy to get bogged down in technical detail of 'conventional' vs. 'unconventional', what actually constitutes “fracking” or not, etc. etc. However:
– Commercial exploitation of either option is the kind of activity which, economic reasons imply, would need to be replicated at other neighbouring wellhead sites (Northchapel? Milland? etc. etc.).
– Commercial exploitation of either option here would be a long-term, intensive and certainly not risk-free industrial activity on our doorstep. Exploitation of both, simultaneously or successively, would be extremely disruptive.
This is an intrinsically risky business
“…it may not be possible fully to restore sites in sensitive areas following well completion or abandonment, particularly in areas of high agricultural, natural or cultural value. Over a wide area, with multiple installations, this could result in significant loss or fragmentation of amenities or recreational facilities, valuable farmland or natural habitats.”
---Aug 2012 – Report by AEA Ricardo consultancy* to the European Commission “Support to the identification of potential risks for the environment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe.”
* a spinoff from the former UK Atomic Energy Authority
Lower Gas Prices?"Fracking [shale gas] has real potential to drive energy bills down" - David Cameron, Prime Minister
"We can't expect UK shale production alone to have any effect [on UK gas prices]" - Ed Davey, Energy Secretary
"Fundamental economics [shows gas bills are unlikely to fall]" - David Kennedy, Head of Committee on Climate Change [official government advisor]
"Baseless [Cameron's claims of lower gas bills]" - Lord Stern
These figures represent approx. 95% (domestic) and 65% (commercial) of total consumers
“It will not be a game changer [in the UK] as it has been in the US ... and there would be enormous environmental consequences.” - Sir David King, former Chief Scientific Adviser to HM Government
● It would be extremely unwise to try and predict the future for prices in the US, let alone the UK, which is very different in many ways, from the above graphs. There has been a large shift in the balance of supply (increasing fast) and demand (increasing more slowly) over the last decade or so, and the balance will continue to change.
● However, even ignoring inflation, and what might be the situation without shale gas, it's hard to argue that US natural gas prices have “plummeted” as has been said by politicians and repeated by news media.
Our Wider Concerns - Risk
● This is a very complex issue and there are many genuine unknowns;
● There is much misinformation and disinformation - who stands to gain from this?
This is all about risk:
● Money, technology, people, environment;
● Risks cannot be entirely eliminated – there is an Oil & Gas industry mantra on risk “As Low as Reasonably Practical” (ALARP) – or, less charitably, “As little as we can realistically get away with at the lowest acceptable cost”.
● However careful we are, accidents can and do happen: Macondo, Buncefield, Piper Alpha, Preese Hall etc.
● Risks to people and the environment tend to be cumulative, and to be persistent over many decades into the future.
● Politicians say “we will only frack when it's safe” - how 'safe' do they mean exactly?
● Regulation is supposed to be what makes the UK different from the USA in this case;
● We have multiple agencies involved in regulation, including: Department of Energy and Climate Change, Environment Agency, Health & Safety Executive, SDNPA
● In December 2012, Lancashire County Council said:
“…there are no specific onshore exploration or extraction regulations for natural gas, and the offshore regulations developed in the 1990s are not sufficient to address all the issues that arise from moving the process onshore especially in populated areas of Lancashire.”
A Regulatory Patchwork?
● Nine months later, we still do not have anything like a publicly available, coherent and complete set of science-based rules, governing 'state-of-the-art' onshore shale gas exploration/production operations, although some work, of variable quality, has been done recently by government agencies and others.
● 'Patchwork rules' enforced by 'patchwork regulation' leads to (and we have already seen examples of each with Cuadrilla):
– Genuine misunderstandings;
● Regarding the individuals who work within these agencies to keep us safe:
– We can expect a rapid proliferation of onshore shale gas activity – workloads will increase;
– Everyone is on a learning curve (even the drillers);
– DECC budget cuts of 8% were announced in spring – will resources be made available as we might wish?
– Many of the most skilled and experienced people from the UK offshore industry are approaching retirement
– “…increased competition for skilled and experienced people…”* will affect both ‘poachers’ and ‘gamekeepers’ - worldwide – in attempts to recruit and retain suitable staff; *Ernst & Young Study 2011
Do you feel lucky?
● The regulatory track record so far is not encouraging, with the EA accused of being “…asleep on the job…” at Balcombe
● Recent indications are that much regulation will in fact be “self-regulation”, a phrase we have heard rather too much of in the finance industry.
● Given that the tiny Celtique arguably has no discernible corporate culture and, like so much of the oil industry, relies on groups of subcontractors – a travelling circus if you will – these subcontractors are likely to bring with them their own ideas of how to conduct themselves. Certainly initially, many of the skilled staff employed at the sharp end by the oil companies will be brought in from the US, where custom and practice are different.
"...for me, evidence of [organisational] culture is how people behave when no-one is watching." - Bob Diamond, ex-Chief Executive, Barclays
● Celtique has stated that, in this exploration phase only, traffic on the A286 will increase overall by 1% - although HGV traffic on the A286 will increase by 18%. It is a given that these are not overestimates!
● Celtique has not stated the equivalent figures for Vann Road – unsurprisingly. We estimate a 2-300% increase in traffic here – just during “exploration”.
● We must remember that construction and other traffic related to St. Cuthmans, Syngenta, KEVII developments may co-incide with all this.
Heavy industry – the impacts?
We have tried below to give a flavour of the scale and nature of activities which may be involved on this site in future, and to indicate the associated risks/concerns. This is necessarily imprecise at this stage in the game, being based on information from Cuadrilla, Celtique and other sources.
Phase 1a - Site Development, Drilling Preparation and Drilling Activities (roughly 3 to 12 months initially):
● Bulldozing the site and placing 5,600+ tons of crushed stone to create the well ‘pad’ – say 250 trucks in then out again;
● There would be up to ten wells on the site in production, only one in the first instance;
● About 3,000 horsepower of heavy diesel engines running full time (roughly equivalent to two InterCity 125 locomotives) for several weeks per well. Emissions from diesels bigger than about 500 hp are believed to be unregulated by the EU. The two proposed PZ9 mud pumps are 1,000 hp;
● About 10km of steel casing tube per well, plus about 1,400 tonnes of cement slurry (dry weight) – say 150 trucks in then out again;
● About 300 tonnes of drill cuttings – say 15 trucks in and out again - per well
● About 3,000 m3 of drilling mud per well (may be trucked in if using ‘recycled’ mud) – maybe 100 trucks in then out or perhaps fewer, with water consumed on site using dry ingredients instead
● Rig and ancillary tanks, mud pumps and other equipment – say 50 trucks in then out again (some requiring police escort); plus thousands of gallons of diesel fuel.
Phase 1b - Well “Stimulation” (‘Frac Job’ and/or ‘Acid Job’), testing and completion (about a month per well initially):
● About 40,000 hp of heavy diesel engines powering each frac for a given well;
● About 2 million gallons, or 6 acre feet, or 40,000 bathsfull, plus about four truckloads of frac sand – per well - forced into the well at about 25 atmospheres of pressure. Assume water would come from main in Vann Road. Plus handling of additives e.g. Biocide, Hydrochloric Acid
● Somewhere between about 250,000 to 2.2 million gallons of “returned waters” – per well - probably contaminated from underground sources as well as drilling mud – stored in tanks and then removed by road. Cuadrilla notes this aspect as the main spillage risk – the return flow rate and volume are unpredictable (like burping a big toxic baby).
● Phase 2 - Well Operation & Production (several years – possibly several decades):
● Details partly depend on on the mix and quantities of oil vs. gas and whether in limestone or shale;
● May involve construction of pipeline and/or processing and compression equipment, possibly also an electric power generation station, so-called “gas to wire”;
● Likely to require removal of oil/water/condensate fluids by road;
● May require re-work [i.e. re-frac’ing or other stimulation] within 3 to 5 years based on USA experience;
● Other Activities: Re-work, Abandonment
Types of Impact
● Traffic - Ironically, the sensitivity of the site probably increases requirements to truck everything in and out (nothing can be ‘dumped’, we trust, and there is little scope for re-processing on-site). HGV/LGV Traffic would most likely go up the A286 through Camelsdale to the A3.
● Air Pollution – Flaring/Incineration of waste gas (during drilling, stimulation and completion, possibly even during production if oil is found); Truck and other diesel engine emissions; “fugitive” emissions of methane and other noxious gases from onsite storage and processing of oil/gas/returned fluids; Unknown (maybe ‘low’, maybe not) levels of radioactive radon gas put into the air; clouds of fine silica dust from fracking process.
● Light Pollution – from onsite lighting, flaring/incineration, traffic;
● Noise Pollution - from traffic; from drilling, frac’ing and ancillary machinery (cranes, pumps, compressors, coolers etc.) and manual operations plus flare/incinerator noise (which may also possibly continue during production).
● Groundwater – probably low risk of major contamination from frac’ed shale directly into the geological ‘zones’ above. Significant risk of contamination over the lifetime of the well from the section of the well at or near the wellhead, due to well casing degradation and failure of ‘zonal isolation’. Probably small risk of major spillage during storage/handling/disposal of: Drilling mud, Frac’ing Additives, Flowback fluids, diesel fuel.
● Earth Tremors – probably low risk of major impact, but minor pre-stressed faults are almost certainly unmapped, may be hard to spot, and may yet cause “seismic events”. It may not be possible, certainly at a realistic cost, to insure against the risk of damage to property caused by manmade seismic events in the vale of Fernhurst. Even if an induced seismic event is small, it may damage existing well casings – this has already happened at the UK's first onshore shale gas frack at Preese Hall in Lancahsire in 2011.
● The wellhead, besides being the focus of heavy industrial activity at the surface, is also the most likely focus of air and/or groundwater pollution for many decades to come. Ignoring spillages, the weakest link is the steel and cement “well casing” - imagine a steel drainpipe a mile or two long in a harsh underground environment
● If the well is not gas-tight, gases/liquids may migrate from one level to another – lack of “zonal isolation” in the jargon – probably creating pollution
– “Since the earliest gas wells, uncontrolled migration of hydrocarbons to the surface has challenged the oil & gas industry”
– “In the Gulf of Mexico…43% of 15,500 …wells have reported SCP [Sustained Casing Pressure i.e. fluid leakage] on at least one casing annulus [i.e. well casing layer]”
– “The presence of SCP appears to be related to age…By the time a well is 15 years old there is a 50% probability that it will have measurable SCP… However SCP may be present in wells of any age”
Source: Oilfield Review Autumn 2003, Schlumberger article “From mud to cement – building gas wells”
● In production, we may have ten or more wells on this site; after after 15 years, five could have lost “zonal isolation” do you feel lucky?
Summary of Risk Areas
● This table shows a “traffic light” representation of our estimate of the risks involved at different stages, it is a subjective process, taking into account both likelihood of a problem arising and its possible level of impact