Dear Mr. Tyrie,
My wife and I recently bought a cottage with a meadow and pond in Lynchmere, near Fernhurst in West Sussex, which is in an Area of Outstanding Natural Beauty within the South Downs National Park. The SDNP is defined as an "extensive area of beautiful and relatively wild country in which, for the nation's benefit...the characteristic landscape beauty is strictly preserved". The South Downs National Park was designated in 2011, after an extensive public enquiry and several years of intense public consultation, and it is one of only 10 National Parks in England. A couple of months after completing on our purchase, we were shocked to discover proposals submitted by Celtique Energie to conduct exploratory drilling for oil and shale gas in this area of outstanding natural beauty near the village of Fernhurst. With the location of the proposed drilling inside the National Park, this project runs entirely contrary to the principle of national interest in which the SDNP was set up. This proposal would amount to quite extraordinary vandalism in the National Park; quite apart from being horrified by the very detrimental aesthetic impact on the beautiful landscape of constructing a 40 metre high rig, a rig which would be operating for 24 hours a day and floodlit at night, my wife and I are deeply concerned by the potential for serious air and water pollution and a whole raft of associated long term environmental and health risks, as well as the impact of increased, heavy lorry traffic on the small rural roads and the way of life nearby. I am therefore writing to you to express my grave concerns about the Celtique Energie proposals and to seek your help in preventing this outrageous exploratory project from coming to fruition.
The ill-conceived Celtique Energie drilling proposal has galvanised the local community in protest and, having researched current policy on shale gas exploration, we have discovered that the government has handed out hundreds of exploratory drilling licences to small opportunistic start-up oil and gas drilling companies to explore the potential for shale gas all over England. This has happened despite the protests of 95% of the local communities involved and without any national public consultation, or any published cost : benefit data, or any informed public debate exploring why, for example, our leading oil company BP has analysed the potential economic benefits and decided not to invest in UK shale gas exploration, preferring instead to concentrate on untapped and more commercially viable reserves of gas in the North Sea. The policy has been described by venture capitalists seeking to leverage rapid returns as ‘the shale rush’ and it completely ignores the terrible health and environmental scandals which are now unfolding in the US, Poland and Australia as a result of these activities. This policy is an undemocratic way to treat British voters.
In an attempt to communicate with the local community, Celtique Energie have provided an ‘information document’ relating to this proposal, but, while it purports to inform local residents about details of the site preparation and drilling operation, and the steps taken by the company to address potential areas of concern such as visibility, ecology, noise and landscape impact, it does not, address the key issues of the chemical composition, quantity, transport and storage of drilling ‘mud’ and the storage and removal of waste products from the drilling.
We feel it is essential that the company provides a comprehensive list of the chemical components of the drilling mud and other products that they plan to use in the exploratory drilling site, the quantity and concentration of mud and water used and more information on the process of drilling, as well as the storage and removal of waste products, polluted water and evaporating chemicals from the drilling. It is well known and universally accepted that many chemicals in ubiquitous use for shale gas drilling constitute human health and environmental hazards even where they are extremely diluted.
Irrespective of the chemical additives used for drilling, shale itself contains several toxic substances which can be mobilized and disrupted by exploratory drilling and washed out of the shale in the high pressure water used in the process; this is usually described as flowback fluid. These substances include lead, arsenic, barium, chromium, uranium, radium, radon and benzene, along with high levels of sodium chloride. The constituents of the flowback fluids can be hazardous even at extreme dilutions, where potential exposure effects include tissue poisoning and cancer; this is exacerbated by common shale gas well drilling practices, such as air-lubricated drilling and the use of impoundments (such as open troughs or small ponds) to capture and store flowback fluids.
I have provided a chart at the end of this letter showing the likely chemicals that will be used by Celtique Energie, all of which are dangerous for the workers handling them, for local residents who may inhale droplets through evaporation, and for wildlife if released in even very dilute concentrations into the soil or through seepage into the ground water. Our key concerns relate to the biocides, the corrosion inhibitors, the surfactants and the lubricants that Celtique Energie will be using in the process, as well as transporting to and from the site along very narrow, winding country roads through the National Park.
To give you an idea of the extremely dangerous nature of these chemicals, I have provided some health information about the products commonly used for exploratory drilling. First, there are the Biocides such as Gluteraldehyde, DBNPA and DBAN.
• Gluteraldehyde is a potent respiratory toxin effective at parts-per-billion concentrations and has induced occupational asthma and/or contact dermatitis as well as being a known mutagen; it is readily inhaled or absorbed through the skin. Algae, zooplankton and trout have been found to be dramatically harmed by this chemical at very low concentrations.
• DBNPA is a sensitizer, respiratory and skin toxin, and is especially corrosive to the eyes. In the environment, it is very toxic to a wide variety of freshwater, estuarine and marine organisms, where it induces developmental defects throughout the life cycle. In particular, it is lethal to water fleas, trout and shrimp at low concentrations.
• DBAN has similar toxicity as DBNPA and it is also carcinogenic. DBNPA and DBAN work synergistically; in combination, the doses at which these biocides become toxic are significantly lower than when they are used separately. In other words, it takes much less of these chemicals to exert toxic effects when they are used together.
The drilling process also requires the use of a corrosion inhibitor such as Propargyl Alcohol, a surfactant used to lower the tension of the liquids, usually an ether such as 2BE or EGBE, and a lubricant such as Heavy Naptha.
• Propargyl alcohol causes burns to tissues in skin, eyes, nose, mouth, oesophagus, stomach and it is toxic to the liver and kidneys. It is also harmful to a variety of aquatic organisms.
• 2-BE or EGBE is easily absorbed through the skin, and is toxic to red blood cells; it causes them to rupture, leading to haemorrhaging.
• Heavy Naphtha is hazardous to a host of microbes, plants and animals. Several of the mixture’s components are known to cause or promote cancer. If released to soil or groundwater, several components are toxic to terrestrial and aquatic organisms, especially amphibians, in which it impedes air transport through the skin.
I could continue, but hope that I have made the point that this chemical information and its concentration in ppm must be provided in the company’s proposal before any kind of valid assessment of the risks and impact of the drilling can be made at all. Celtique Energie has claimed in its information booklet that it will use a freshwater drilling mud with non-toxic additives; we need to know what these proposed additives are and at what concentrations. Are they claiming, for example, that otherwise lethal chemicals are now non-toxic because they are going to be diluted by gallons of water? The evidence would indicate the contrary.
We have also not been adequately informed about burn-off of gases released during the exploratory phase of this proposed project. What atmospheric pollution may be caused? What guarantees will be given that no smoke or malodorous or toxic fumes will be released and what legal compensation agreements will be in place to pay for any damage to the environment or human health as a result of particulate or chemical pollution in the air, or the water or the soil? If this wholly unacceptable drilling project is allowed to go ahead, I will be conducting comprehensive water tests and a specialist soil survey at my property to benchmark the quality and constituents of the groundwater and soil before the drilling begins; I will not hesitate to sue Celtique Energie for any pollution that they cause during the drilling, or damage that is subsequently caused to the environment as a result of the exploration even after the drilling has ceased, including any mobilisation of naturally occurring toxins brought to the surface from the disruption of the shale layers. I will be recommending this benchmark testing as a course of action to all my immediate neighbours and all members of the local community in our National Park.
Finally, the question of traffic is also critical in assessing potential damage to and destruction of the rural environment. This site lies just off the ‘very rural’ Vann Road and this road and the approaches through Fernhurst, Lynchmere and Milland are not at all appropriate for use by heavy lorries or any increased flow of traffic. Celtique Energie themselves estimate that traffic will increase by 35 vehicles a day, including 22 HGVs on average over each 24hour period; this represents an almost 21% increase on the A286 during the PM peak. Since HGVs are virtually unknown on Vann Road currently, the impact on Vann Road and the residents of Fernhurst would be colossal and utterly unacceptable. The company proposes to use a temporary access road with a left turn in and a right turn out only routing; it makes the outrageous claim that this routing will ensure that HGVs utilise the larger “A roads” (A286) rather than the smaller rural roads of the surrounding villages. What is Vann Road other than precisely one of the ‘smaller rural roads of the surrounding villages’ they are pretending to be taking pains to avoid? The distance from the A286 to the entrance to the site is 1.2miles along Vann Road, a very picturesque, narrow, winding rural road, which passes through the very centre of Fernhurst. Given the rate of HGV traffic, it is also inevitable that there will be occasions when these HGVs will be passing each other on Vann Road; this is currently impossible.
All in all, I and many hundreds of other residents in the surrounding area, are truly and justifiably alarmed by the proposals for shale-gas and oil exploration at the Fernhurst site and we are actively seeking assurances that you will do your utmost to prevent this project from seeing the light of day.
With many thanks for your kind consideration.
We look forward to receiving your response to our concerns as soon as possible.