The Government's False Promises on Shale Gas and Climate Change
The Response to the Mackay and Stone report -
“In September the Government welcomed the report by Professor David MacKay FRS, DECC Chief Scientific Advisor, and Dr Timothy Stone CBE, the former Senior Advisor to the Secretary of State for Energy and Climate Change, assessing the potential greenhouse gas (GHG) emissions from extraction of shale gas in the UK and the compatibility of such emissions with the UK’s legislated climate change targets.”
“The report by Professor David MacKay FRS and Dr Timothy Stone CBE made 8 recommendations. The Government accepts them all.”
On the 24th April 2014 the government under the DECC logo claims to have accepted all the recommendations of MacKay and Stone’s September 2013 report on GHG emissions. How worthful is that acceptance?
The introduction to the government’s response is not encouraging. It talks the same talk of how the government is doing its best to combat climate change. This is not even worth analysing to expose its deception. But more useful may be to look at the statement and see where this is defective or where it can be used.
“In managing fugitive, vented or flared methane throughout the exploration, preproduction and production of shale gas, operators should adopt the principle of reducing emissions to as low a level as reasonably practicable (ALARP). In particular, “reduced emissions completions” (REC) or “green completions” should be adopted at all stages following exploration. Government should discuss with regulators appropriate mandatory requirements to be applied at each stage to ensure that the best technology is implemented in all cases.
We accept this recommendation in full. We are committed to adopting green completions alongside the development of production facilities.”
This raises two issues - the omission of exploratory phase from the recommendation, and what the government means by “green completions”.
Stepping aside from that, the government’s response says
”For all oil and gas activities, onshore and offshore, DECC requires that venting should be kept to the minimum that is technically possible.”
Er no, this is not true, because then DECC tell us
“Routine venting is never permitted, but it is not possible to prohibit venting entirely, as in particular operational circumstances it may be necessary for safety reasons. However, the preferred alternative, where gas has to be released because there is no economic use for it, is that the gas should be flared to reduce its contribution to global warming emissions. In respect of future appraisal or production activities, DECC’s established policy is that flaring should be reduced to the economic minimum.”
The response goes on to say -
“The Environment Agency’s draft technical guidance for onshore oil and gas exploratory operations makes clear that operators should apply a hierarchy of controls to ensure waste gas is first prevented, then minimised and finally rendered harmless. The guidance goes on to make clear that operators should initially consider installing an engine to burn the gas and recover the energy. If this is not possible then a flare may be used. Operators must be able to show that their activities, including flaring during exploration, do not lead to emissions at levels higher than those set out in their environmental permits.
These controls will remain in place during exploration stage, where the use of green completions techniques is often not technically or economically feasible. But as MacKay-Stone makes clear, there are significant gains to be made using green completions in production.”
This is double-speak. It says the controls will be in place, but during exploration adherence may not be economically possible.
There we have the nub of the problem. Operators will always be let off the hook at any stage, because they can claim adherence to best available technique is simply too expensive.
However, the next few paragraphs of the response talk about replacing ALARP (As Low As Reasonably Practical) by use of BAT (Best Available Techinques) instead, A conflict with what they said above, welcome as that is.
The danger sign is that the response says that the government through the Environment Agency will work to influence at European level the definition of BAT. If they are likely to be as effective in lobbying as they were against EU environmental impact regulation of shale gas this is not encouraging.
To judge how this response will work in poractice we can consider two current examples although these are not for shale gas it is indicative of how the current regulation fails to achieve any GHG reducing ambition.
At Balcombe 29th April West Sussex passed an application (previously with waste method approval from the EA) for flaring the methane gas from exploration and testing, supposedly for oil rather than gas, although clearly it was expected to find gas. No consideration was given as to why energy capture was not used.
At Markham, Doncaster Council gave Regent permission, and a waste plan is currently (end April 2014) under consideration by the EA for exploration and production of coal mine methane. In this case there is no intention of using energy storage EVEN DURING exploration, although an energy plant WILL be installed for production. NOR is there any intention to flare during exploration and testing. The gas will simply be vented. This is totally inconsistent with the government’s statement.
Recommendation b) and c)
“b) Shale gas exploration and production in the UK should be accompanied by careful monitoring and inspection of GHG emissions relating to all aspects of exploration, pre-production and production, at least until any particular production technique is well understood and documented in the context of UK usage (see Research, below).
c) Thereafter operators should monitor their sites to: (1) ensure early warning of unexpected leakages; and (2) obtain emissions estimates for regulators and government.
The Government accepts these recommendations in full. The Government agrees that while shale gas is developing there is justification for careful monitoring and inspection of GHG emissions. The report is a significant step forward in establishing the range of emissions we might expect in the UK’s regulatory context. Since the release of the MacKay-Stone report, the University of Texas at Austin produced a detailed study involving the monitoring methane emissions from various stages of shale production. It found that emissions from fracking are lower than previously thought. However we will not be able to conclude firmly that shale gas operations will not lead to damaging levels of GHG emissions without inspection and monitoring.”
Firstly this response admits that current regulation does not cover the issues involved. But then we are given a clear sign that the government, by quoting a report to suit its views, rather than later reports which have shown that methane emissions are FAR GREATER than were previously thought, encourages us to believe the government’s view of science is biased.
“The Government will therefore be pursuing a programme of research that will monitor methane emissions (methane accounts for the vast majority of produced gas) from all exploratory sites in the next two years relating to exploration, pre-production and production of shale oil and gas. More detail on the research programme is covered in the response to recommendations g and h below.
These recommendations have been welcomed by industry who have already committed to monitoring work being undertaken on their sites and have conducted their own monitoring of existing sites. The UK Onshore Operators Group charter states that; ‘Fugitive emissions levels will be constantly monitored at all stages of development and the data made available in line with best practice and regulatory reporting requirements’.”
Adherence to these principles will be difficult. But at all stages, including planning applications, close attention must be paid to these promises to ensure they are adhered to. Omitted here, though, is any commitment to baseline monitoring BEFORE any exploration starts.
Further on, (see later) the government commits to a research programme. Surely, though, this programme should ALSO be completed before any shale gas exploration starts.
Recommendation d) and e)
“d) Shale gas production in the UK should be accompanied by research into development of more effective extraction techniques, such as improved REC and self-healing cements, which minimise wider environmental impacts including whole-life-cycle GHG emissions.
e) Government and industry should actively pursue new techniques to minimise GHG emissions associated with exploration, pre-production and production of shale gas and also reduce the impact on local environment and infrastructure.
The Government accepts these recommendations in full. “
The explanatory notes, however, talk about investing £2 million in a competition for in innovative technology for safe and responsible exploitation of shale gas. They mention ideas such as self-healing cement. criteria for the competition will also include projects aimed at reducing GHG emissions.
We can only conclude from this nonsense that the government ACCEPTS that CURRENT technology is unsafe, or not as safe as we should demand.
“The shale gas industry should research methods to minimise water demand and vehicle movements, so as to reduce greenhouse gas emissions and the impact on local infrastructure.
The Government accepts this recommendation in full.”
An interesting note is that the REFINE group is currently researching impact of increased traffic.
But INSTEAD of demanding new techniques to reduce water demand, the government talks about using piped water rather than trucks to reduce vehicle movements.
More water pipes also means more local disruption.
Again the recommendation calls for research. An appropriate response would really be NO FRACKING EXPLORATION until the research is completed. We all know that today’s exploration sites will be tomorrow’s production sites if the government and the frackers have their way.
Recommendation g) and h)
“g) There should be a detailed scientific research programme of methane measurement, aimed at better understanding and characterising sources and quantities of methane emissions associated with shale gas operations.
h) This research programme should be independent and managed jointly between government and industry. The research should aim, for example, to reduce uncertainty associated with estimates of local methane emissions from shale gas operations and also to guide the optimisation of regulatory monitoring. The research could also provide information on the effectiveness of operators ’actions to minimise methane emissions.
Government accepts this recommendation in full. We will establish a programme board for the programme of research that includes industry, academics, environmental groups and regulators. The programme board would be responsible for improving the evidence base with the aim of reducing uncertainty associated with estimates of local methane emissions from shale gas operations and to input into regulatory monitoring, in a transparent manner. In the meantime, the pilot study will be managed by the Environment Agency and DECC will collaborate with the pilot.”
Another research programme. Time and time again we have the evidence that the government accepts the need for research but STILL insists on full-steam-ahead for fracking.
Here they suggest a pilot study - at a conventional oil site. Number one, this is NOT a gas site, and secondly it demonstrates how LITTLE we are protected by the potential effects, and how little is known about the, from existing onshore oil and gas developments.
The second implication for shale gas is that the research programme will take place AFTER development of the industry. Again the government is confirming it will plough ahead without any knowledge of the dangers. Why is the research programme not taking a look at the US experience?
Given the government (in the form of Michael Fallon and DECC) have this week given their endorsement to a report which talks about some 33 BILLION pounds being needed to be injected into the UK shale gas industry, here we have a government offering a few pathetic crumbs to fund research. Research that will come too late for those communities already adversely affected by shale gas development that the government is pushing for regardless.
Apart from funding research, the Government’s promises at a detail level are worthless, in the light of existing experience, and conflict between the government’s statements on best available techniue and economic necessity.