Letters JV-CIEH #1

8/11/2019 Letters JV-CIEH #1

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School of Earth Sciences,

University of Bristol,Wills Memorial Building,

Queens Road,Bristol, BS8 1R

ames!"erdon#$ristol!ac!u%

&'()*(&)1+

o the $oard of the -hartered .nstitute for Environmental /ealth,

. am 0riting in resonse to your recent reort, 2Shale 3as and 4rac%ing5

E6amining the Evidence7 u$lished in tandem 0ith Scientists for 3lo$alResonsi$ility S3R9! his reort claims to rovide an 2imartial7 and 2evidence:

$ased7 revie0 of the issues surrounding shale gas e6traction in the U;! heauthorshi $y rofessional $odies lends 0eight to this 2evidence:$ased7

imression! /o0ever, $y any standard of scholarshi this reort falls 0ell short!

4actual errors, cherry ic%ing of scientiarty has camaigned vigourously against

shale gas develoment in the U;, . feel that this reresents a con


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clustering of 0ells is common in onshore conventional reese /all events! .naddressing 0hether seismicity oses a ris% to 0ell$ore integrity, the authors

might have $een $etter e6ercised $y considering 0hether these regularoccurrences have osed 0ell$ore integrity issues for the &,))) onshore, and over

1),))) offshore, 0ells that have drilled in the U;!

2.2. Water and ground contamination

S3R(-.E/ cherry:ic% the study $y ac%son et al! &)1'9 in their discussion of

ground0ater contamination! Such cherry:ic%ing gives the misleadingimression that this is the only study erformed in the region, 0hen it is in fact

only one of many! Moreover, S3R(-.E/ neglect to discuss the myriad issuesraised over this aer, for e6amle the limited num$er of 0ater 0ells samled

1+)9, the non:randomness of the samling rocess, and the lac% of a $aseline forcomarison! here have in fact $een numerous studies of ground0ater in the

>ennsylvania region and further a


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G study of &') 0ater 0ells made $y the -entre for Rural >ennslyvania,

0hich found no imacts from shale drilling!

G $aseline study made $y the US3Sin undrilled arts of Sullivan -ounty,

>G, 0hich recorded similar levels of naturally occurring methane to those

found $y ac%son et al! &)1'9! G second $aseline study made $y the US3Sacross the >ennsylvania:Fe0

Jor% $order, 0hich again recorded similar levels of naturally occurring

methane to those found $y ac%son et al! &)1'9!

he study erformed $y Warner et al! &)1'9: the same Ku%e University

team as ac%son et al! &)1'9 I over the 4ayetteville shale, Gr%ansas,0hich found no imact from drilling!

he fact that all of these studies have $een neglected reresents a serious

omission from the reort!

Similarly, the failure $y S3R(-.E/ to e6amine in any detail the ra0 statistics of>G KE> infringements leads them to ma%e misleading statements regarding 0ell

integrity! -onsidine et al! &)1&9did so, and found that of over ',)) shale gas0ells drilled in >ennsylvania, only & had caused stray gas migration into shallo0

ground0ater, 0hich reresents a failure rate of )!)LH! .n $oth cases, reairs0ere made to the offending 0ell, and 0ater @uality remediated! hese rotection -ouncil &)119, 0ho studiedtens of thousands of 0ells in ?hio and e6as,


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roduction, nuclear o0er roduction and electricity generated through $urning

coal!7

2.4. Local air quality

.n the section on air @uality, S3R(-.E/ resent no data ertaining to air @ualityduring shale develoment, and are only a$le to ma%e unsu$stantiated assertions!/o0ever, such data is availa$le5 for e6amle Bunch et al! &)1+9 e6amined

e6tensive air @uality measurements made over the Barnett Shale, and did notennsylvania made $y the >G KE> &)1)9did not identify concentrations of anycomound that 0ould li%ely trigger air:related health issues associated 0ith

Marcellus Shale drilling activities, and overall emissions inventories sho0 areduction in air ollution as o0er generation has s0itched from coal to shale

gas >G KE> air emissions inventory, &)119!3iven that such data is availa$le, .-- state that 2 in mitigation

scenarios reaching a$out +) m -?&e@ concentrations $y &1)), natural gaso0er generation 0ithout --S acts as a $ridge technology, 0ith deloyment

increasing $efore ea%ing and falling to $elo0 current levels $y &)) anddeclining further in the second half of the century7! he .>-- have made it clear

that they see natural gas e6tracted from shale as a %ey comonent of greenhousegas mitigation strategies from no0 until &))!

.n their assessment of the imact of shale develoment on rene0a$leinvestment, S3R(-.E/ neglect the otential ositive imacts of a$undant natural

gas on deloyment of rene0a$les! G reort $y the Brattle 3rou &)1'9found astrong comlementary relationshi $et0een rene0a$les and natural gas,

$ecause the


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Economics &)1'9 has sho0n that, the &))D recession aside, tourism in

>ennsylvania has increased su$stantially in recent years, a the same time as theMarcellus shale has $een under develoment!

!. Can we manage without shale gas"

.n this section, S3R(-.E/ neglect the many different uses 0e have for naturalgas! Seci


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My concerns have their rincial $asis in the accurate ortrayal of a delicate and

sensitive toic! /o0ever, . feel . should also oint out the imact of the -.E/sendorsement of this reort, $oth on the institution as a 0hole and on the ran%:

and:rofessional -ode of -onduct laces great imortance uon

maintaining the standing and credi$ility of the organisation aragrahs &!& and&!'9! More seciresuma$ly, the -.E/ as an institution 0ishes to add its voice to the de$ate over

U; shale develoment, and more seci


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Jours sincerely,

Kr! ames "erdon, >h!K!, M!Sci, MG-anta$9,FER- Research 4ello0,

School of Earth Sciences,University or Bristol!

Letters JV-CIEH #1

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