Letters JV-CIEH #2

8/11/2019 Letters JV-CIEH #2

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Chadwick Court 15 Hatfields London SE1 8DJTelephone020 7928 6006Fax020 7827 5862www.cieh.org

President

Janet Russell OBE CFCIEHChartered Environmental Health PractitionerChief Executive

Graham Jukes OBE CFCIEHChartered Environmental Health Practitioner

The CIEH is a registered charity

incorporated by Royal Charter(No 290350)

7 August 2014

Dr. James Verdon, Ph.D., M.Sci, MA (Cantab),

NERC Research FellowSchool of Earth SciencesUniversity of BristolWills Memorial BuildingQueen's RoadBristol BS8 1RJ

Dear Dr Verdon

Shale Gas and fracking: examining the evidenceThank you for your recent letter in response to the publication of the joint CIEH and SGRreport. Your extensive comments can be broken down to 4 generic criticisms/allegationsrelating to this work:

1: That the work is not impartial (which you state the report claims - which it doesnot) specifically because of Gwen Harrisons association/involvement with theGreen Party and full engagement with civil society which you assert is a conflict ofinterest.

2: You accuse the authors of cherry picking evidence.

3: You suggest the publication would not meet peer review standards and youconsider the work representsa shocking lack of scholarship.

4: That (because of the above criticisms /assertions) the work negatively impacts onthe standing of CIEH and its members.

I comment on those general points below and specifically in the tabulated appendix(attached) on each point. To aid clarity I have placed your letter alongside the responsein the appendix and followed the structure and headings of your letter.

Point 1: Impartiality

There is no claim anywhere in the report that it is impartial. However, it is in line with theCIEHs declaration of following a precautionary approach to ensure public protection. Wefully agree with the point you have made in your letter i.e. that activities within anindividuals personal life should not preclude a contribution from that individual toprofessional work (where that individual has experience and/or expertise to contribute).In that context Gwen Harrisonsinvolvement in this work is entirely appropriate. In thesame vein your comments can not be regarded as impartial eitherdue to your publiclyavailable opinions available on social media sites - but your expertise is acknowledgednonetheless.


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Point 2: Cherry-picking Evidence

Your comment is rejected as it is not based on fact. Whilst perhaps the briefing shouldhave not only had a references section but also a bibliography, (although this is NOTintended to be an academic publication), there is a distinction between what was read by

the authors in the preparation of this work and what was cited. In your comments, asidentified in the attached appendix you stand guilty of the very criticism you are levelling.

Point 3: Standard of Work and Peer Review

It has not been claimed, nor was this intended to be, an academicpaper written for peerreview. If you are intending your comments to be regarded as a peer review we wouldregard that as inadequate, as solitary reviewers run the risk of making comments that arein fact opinion. This work however was a collaborative project with more than one authorand moreover, others had opportunity to comment on the draft text including the CIEHProfessional Standards and Policy Committee.

Point 4: Impact on CIEH Reputation

The CIEH having considered in detail your letter and the response of the authors of thejoint report, rejects your conclusions. The CIEH stands by publication of this documentand considers it is a valuable addition to the debate surrounding this subject area. Thereport is proving to be extremely helpful to those who are charged with regulating andadvising on fracking proposals.

There is no evidence that you have presented to me to substantiate a claim of breach ofthe CIEH code of conduct and I regard your expressed concerns as unfounded.

Prior to publication the report was circulated internally for comment and those commentswere taken on board by the authors as indicated above. Final copy was submitted to me

and published under my authority as a document worthy of carrying the quality mark ofthe CIEH.

While I reject your conclusions I am nevertheless appreciative of the time and effort youhave taken in expressing your view to us and for the opportunity afforded by thiscorrespondence to clarify your misinterpretations.

Yours Sincerely

Graham M Jukes OBE CFCIEHChief Executive


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Appendix 1

CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report

Shale Gas and fracking: examining the evidence July 2014

Letter from Dr James Verdon

To the board of the Chartered Institute forEnvironmental Health, I am writing inresponse to your recent report, Shale Gasand Fracking: Examining the Evidencepublished in tandem with Scientists forGlobal Responsibility (SGR). This reportclaims to provide an impartial andevidencebasedreview of the issuessurrounding shale gas extraction in the UK.

The authorship by professional bodies lendsweight to this evidence-basedimpression.However, by any standard of scholarshipthis report falls well short. Factual errors,cherry picking of scientific literature,omissions of key facts and scientific papersabound throughout the report. The purposeof this letter is to draw your attention tothese errors, and to raise my concernsabout the implications of CIEHsendorsement of this report. I will begin byaddressing some of the major issues foundin the report. I will do so in a manneranalogous to that with which I am mostfamiliar, namely that of scholarly peer-review.

Authorship

I note in passing that the lead author of thereport recently stood for election for theGreen Party. Given that Green Party hascampaigned vigourously against shale gasdevelopment in the UK, I feel that thisrepresents a conflict of interest. Moreover,judging by her own comments on twitter,the lead author appears to have joinedprotest marches against shale developmentat Barton Moss. Of course, personally-heldviews do not necessarily preclude a

professional author from penning animpartial report on a subject on which they

Response by the CIEH and SGR on thepoints raised by Dr James Verdon

The covering letter to which this appendixis attached rejects the assertions made byDr Verdon in his opening remarks.

What follows is a dissection of the pointsthat he has made to ensure that readers ofthe report are in no doubt as to ourassertion as to its quality and validity.

In comment on the background to the

production of the report. The report aroseout of a concern that the UK governmentwas championing a new fossil-fueltechnology based on narrow economicconsiderations without adequate attentionto environmental and social/ healthconcerns. Claims were being made bygovernment and industry that seemed tohave very limited evidence to support them.A key aim of the report therefore was tocritically assess such claims, with referenceto the available peer-reviewed literature, aswell as wider sources. In addition itspublication in partnership with theChartered Institute of Environmental Healthprovided the opportunity to merge the workthat CIEH had done to support theknowledge base of the profession and theCIEH members on the ground who will becalled upon to advise the local governmentplanning process.

Authorship

There is no claim anywhere in the reportthat it is impartial. We accept that activitieswithin an individuals personal life shouldnot preclude a contribution from thatindividual to professional work (where thatindividual has experience and/or expertiseto contribute).

Impartial reporting on any area of policy-relevant science and technology is difficultto achieve. While we have made no such

claim for the impartiality of this report andyou are misquoting us on this point, we do


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are wholly partial, or indeed have a conflictof interest. However, given the issuesraised below, one is left with the feelingthat the SGR/CIEHs stated aim of

producing an impartial, evidence-basedreport was doomed from the beginningbased on the choice of lead authorship.

maintain that the report is robust and is inline with the CIEHs consideration of theprecautionary principle to ensure publicprotection, which is extremely relevant

when assessing the impacts of proposeddevelopment.

In an area such as shale gas and fracking inthe UK, there are large uncertainties in keyareas and significant gaps in the evidencebase, so the scope for differentinterpretations is large. It is unsurprisingtherefore that an academic working onprojects associated with the oil and gasindustry would have a different

interpretation to ours.

Regulatory regimeWe note that there are no criticisms of thesection of the report, Regulatory regime.Concerns about the robustness of theregulatory regime in the UK are a centraltheme of this report, which we haveemphasised. Within our report, we havehighlighted numerous concerns andrecommendations made by a range of

stakeholders, including the Royal Society,the European Commission, and from withinthe Environment Agency. Further and directhigh level discussions between the CIEHand the Environment Agency postpublication of this report, in particulararound the comments in paragraph 2.5reveal an acknowledgement of the issue ofscarce resources. We have however beenadvised that reprioritisation of resources toeffectively deal with the permittingrequirements of fracking proposals isaddressing this issue, in that agency.

The CIEH has voiced specific concernsabout the effect cuts in local governmentresources are having in maintainingeffective regulation and the tripartiteregulatory control mechanisms currently inplace will have to be suitably coordinated toensure that regulation is appliedappropriately and effectively, which will bea continuing challenge in todays financial

climate.


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1. IntroductionSGR/CIEH make the following claim todifferentiate shale and conventional gas

extraction: Unlike in conventional wells,fracking in shale requires horizontaldrilling [and] huge numbers of wells. Theimplication is that conventionalhydrocarbon recovery requires neither. Inpoint of fact, lateral well drilling isnow commonplace in conventionalreservoirs. Indeed, the technique waspioneered in the U.K. in the Wytch FarmField in the early 1990s. Equally, tightclustering of wells is common in onshore

conventional fields, especially those ofan older vintage. 5-spot drilling patterns ona 10, 20 or 40 acre spacing iscommon in North American conventionalreservoirs, and is easily as dense as thenumber of wells used to extract shale.

IntroductionIn response to Dr Verdons comments onthe first section of the introduction, the

overall point made is that the process ofextracting shale gas is very different fromconventional gas, because fluids are unableto flow as freely as they might in moreporous rocks such as sandstone. TheAdvertising Standards Agency upheld acomplaint against Cuadrilla for suggestingotherwise, as we highlight in our report.Our point is supported by, among manyothers, the International Energy Agency inits World Energy Outlook, which states that

unconventional gas sources are difficult toextract because they are trapped in verytight or low permeability rock that impedestheir flow [and thus] the scale of theindustrial operation required is muchlarger than for conventional production.This means that drilling and productionactivities can be considerably moreinvasive, involving a generally largerenvironmental footprint1.

The report goes on to suggest that Onefeature of the greater scale of operationsrequired to extract unconventional gas[compared with conventional gas] is theneed for more wells. Whereas onshoreconventional fields might require less thanone well per ten square kilometres,unconventional fields might need more thanone well per square kilometre. This reportdoes qualify this statement by saying thatIt should be noted that conventional gasfields in mature areas, such as onshoreUnited States or Canada, often have welldensities comparable to those ofunconventional gas. However, burgeoningunconventional gas production today tendsto replace production that would have comefrom offshore locations or countries rich inconventional gas, such as Russia or Qatar,in which the well densities are muchsmaller. So while there are undoubtedlycases in which conventional gas fields can

1p18:

http://www.worldenergyoutlook.org/media/weowebsite/2012/goldenrules/weo2012_goldenrulesreport.pdf


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2.1. SeismicitySGR/CIEH make the unsubstantiatedassertion that UK geology is substantiallymore faulted than that of North America. Inreality, the geology across multiple shaleplays across the North American continentis highly variable. Some shale plays areindeed relatively undisturbed. However,others are not. Moreover, even plays thatappear flat can contain substantial faulting.

Microseismic data reveals potential faultsstructures in approximately 30% ofdatasets recovered in the USAfaults arefar from rare. However, only a small subsetof faultsthose near to their critical failurestressmight be re-activated if they areimpinged upon by a hydraulic fracturingoperation.The SGR/CIEH comments on CuadrillasPreese Hall well imply that the inducedseismic activity may have impinged on

wellbore integrity. The reality is thatcasing deformation was limited to the lowerpart of the production casing stringthe part of the wellbore in which holeshave already been punched to allow gasto flow. It is irrelevant to talk of wellintegrity in a part of the well casing that isintentionally left open to produce gas.Shallow groundwater sources areprotected by different, shallower casingstrings. There has been no suggestionthat these strings were damaged byseismicity, nor that wellbore integrity hasbeen compromised.More generally, the Preese Hall seismicevents, at magnitude 2.3 and 1.5, arerelatively small, even by UK standards. TheUK experiences over 50 such eventseach year, and typically experiences onemagnitude 4 earthquake every 1.5years, which is almost 1,000 times largerthan the Preese Hall events. Inaddressing whether seismicity poses a risk

to wellbore integrity, the authorsmight have been better exercised by

have well densities comparable to those ofunconventional gas fields, it is clear that, asa general rule, this is not the case, and it ismisleading to suggest otherwise.

SeismicityInstead of asserting that UK geology issubstantially more faulted that that of NorthAmerica, as Dr Verdon suggests, we usethe rather more measured statement thatBritain tends[emphasis added] to havemore complex and fractured geology [thanthe US]. Of course there are parts of theUS with very complex geology, but thatparticular statement was intended as a

general one. We go on to be more specificby highlighting that the Fylde, home to theUKs only fracked shale gas well, is knownto be faulted, and that the BGS has warnedagainst fracking in faulted areas.

We fully acknowledge Dr Verdonsassertions that the UK experiences many(small) earthquakes each year, and that themagnitudes of the Lancashire ones wererelatively low (hence our statement that

While fracking activities triggered theearthquakes, they may have occurrednaturally at a later date and, given theirrelatively low magnitude, it is unlikely thatsimilar events would cause significantdamage to properties and infrastructure.However, the fact remains that the twoearthquakes in Lancashire were triggeredwhen the UKs only shale gas well to datewas fracked, and that these earthquakesdamaged the wellbore so severely that thewell had to be abandoned. We do notimply that this damage impinged onwellbore integrity in this case. We merelyhighlight that such incidents, which damagea wellbore to that extent, have the potentialto result in integrity failure. Weacknowledge in the report that data arelacking in this area, with the implicationthat further work needs to be done toestablish whether or not this represents apotential problem.


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considering whether these regularoccurrences have posed wellbore integrityissues for the 2,000 onshore, and over10,000 offshore, wells that have drilled in

the UK.

2.2. Water and ground contaminationSGR/CIEH cherry-pick the study by Jacksonet al. (2013) in their discussion ofgroundwater contamination. Such cherry-picking gives the misleading impression thatthis is the only study performed in theregion, when it is in fact only one of many.Moreover, SGR/CIEH neglect to discuss themyriad issues raised over this paper, for

example the limited number of water wellssampled (140), the non-randomness of thesampling process, and the lack of a baselinefor comparison. There have in fact beennumerous studies of groundwater in thePennsylvania region and further afield. Forexample: Molofsky et al. (2013), who studied over1,700 wells in Pennslyvania, with some thatincluded baseline conditions, and found nocorrelation between methane and shale gas

wells (and found correlation instead withtopography, implying a natural methanesource). A study of 230 water wells made by theCentre for Rural Pennslyvania, which foundno impacts from shale drilling.A baseline study made by the USGS inundrilled parts of Sullivan County, PA,which recorded similar levels of naturallyoccurring methane to those found byJackson et al. (2013).A second baseline study made by theUSGS across the Pennsylvania-NewYork border, which again recorded similarlevels of naturally occurring methane tothose found by Jackson et al. (2013). The study performed by Warner et al.(2013) - the same Duke Universityteam as Jackson et al. (2013)over theFayetteville shale, Arkansas, which foundno impact from drilling.The fact that all of these studies have beenneglected represents a serious omission

from the report. Similarly, the failure bySGR/CIEH to examine in any detail the raw

Water and ground contaminationDr Verdons suggestion that we havecherry-picked one study and given themisleading impression that this is the onlystudy performed in the region does notacknowledge the context within which thisstudy was referenced. There are, ofcourse, examples of studies which havefound no evidence of contamination, as Dr

Verdon rightly points out. We referencedthe Jackson study (and others) as examplesof ones which found evidence of methanecontamination, in order simply to counterclaims by Cuadrilla (and many others withinthe industry) that no such evidence exists.We make no suggestion, either implicit orexplicit, that the studies we referred to arethe only ones in the region. We go on tosay very clearly that local environmentalimpacts may be less severe in the UK than

in the US, due to more stringent (thoughstill inadequate) regulations, and that thereality is likely to lie somewhere betweenwhat proponents claim and opponentsfear. We believe this to represent a fairand balanced assessment of the situation,which is largely unknown for the UK.


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statistics of PA DEP infringements leadsthem to make misleading statementsregarding well integrity. Considine et al.(2012) did so, and found that of over 3,500

shale gas wells drilled in Pennsylvania, only2 had caused stray gas migration intoshallow groundwater, which represents afailure rate of 0.06%. In both cases, repairswere made to the offending well, and waterquality remediated. These findings mirrorthose made by the Groundwater ProtectionCouncil (2011), who studied tens ofthousands of wells in Ohio and Texas,finding well failure rates of lessthan 0.1%.

2.3. Water use and waste waterIn their discussion of water consumption,SGR/CIEH make the claim that wellsare generally fracked several times overtheir lifetime. This is erroneous. Almostall shale wells are only ever fracked once.With respect to water consumption, thereader would surely be better informedif the authors were to consider waterconsumption over the full life-cycle of shale

gas extraction, and in comparison withother forms of energy generation. Suchstudies exist in the literature, but havebeen neglected by SGR/CIEH. For example,Clark et al. (2013) find that shale gas use inthe power sector represents only anincremental increase in water consumptioncompared to conventional gas. Similarly,Scanlon et al. (2013) found that shale gasconsumed substantially less water than coalin electricity generation, and that the switchfrom coal to shale gas played an importantrole in adapting to recent droughts inTexas. The memorandum of understandingsigned between Water UK and the UKOnshore Operators Group (UKOOG) is alsosurely of significance to this discussion.With respect to the NORM content offlowback water, SGR/CIEH neglect recentwork byAlmond et al. (2014), whoexamined this issue in detail, and foundthatin no scenario was the 1%exceedence exposure greater than 1mSv

the allowable annual exposure allowed forin the UK, and that the radioactive flux

Water use and waste waterWe concede that instead of stating thatwells are generally fracked several timesover their lifetime we should have saidwells are sometimes fracked several timesover their lifetime. Dr Verdon suggeststhat Almost all shale wells are only everfracked once. We would be interested tosee any data Dr Verdon has on the refrackrate among shale gas wells drilled to date

which supports his assertion.That fracking is water-intensive isundisputed. The extent to which thisrepresents a problem, however, is thesubject of much discussion, which is a verylong way from achieving consensus. It wasbeyond the scope of our report to carry outa detailed analysis of the evidence on waterconsumption, and we therefore did notmake any claims of our own on this matter.Instead we simply presented the views ofWater UK (the water trade body) and theChartered Institute of Water andEnvironmental Management (CIWEM).These bodies, respectively, have warnedthat Where water is in short supply theremay not be enough available from publicwater supplies or the environment to meetthe requirements for hydraulic fracturingand Climate change scenarios predict lesswater availability in the future so whetherthis level of water use is appropriate in thelong term to source energy requires further

research.


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of per energy produced was lower for shalegas than for conventional oil and gasproduction, nuclear power production andelectricity generated through burning

coal.

2.4. Local air qualityIn the section on air quality, SGR/CIEHpresent no data pertaining to air qualityduring shale development, and are onlyable to make unsubstantiated assertions.However, such data is available: forexample Bunch et al. (2014) examinedextensive air quality measurements madeover the Barnett Shale, and did notfind levels of air pollution that would causeconcern. Similar surveys in Pennsylvaniamade by the PA DEP (2010) "did notidentify concentrations of anycompoundthat would likely trigger air-related healthissues associated withMarcellus Shaledrilling activities", and overall emissionsinventories show areduction in air pollution

as power generation has switched from coalto shalegas (PA DEP air emissions

We would also point out that makingcomparisons between life-cycleassessments of different fuel sources, aspresented by Dr Verdon, can obscure the

problems arising from high levels of wateruse on a specific site.With regard to Dr Verdons comment on theNORM content of flowback, we have madeno judgement as to whether or not theselevels are acceptable (indeed have made nospecific mention of NORM). We simplystate that fracking fluid returning to thesurface is now classed as radioactive waste(following the introduction of new Europeanlegislation in 2011), and is thus likely to

require off-site treatment and disposal. Ourpoint is not that the levels of radioactivityare particularly high, and therefore harmful(which Dr Verdons response seems toimply), but simply that the high volume ofwaste waterclassified as radioactive andtherefore probably (though not definitely)requiring offsite disposalis likely to placea burden on waste water treatmentinfrastructure.Dr Verdon does not dispute the high

number of daily vehicle movementsrequired to transport water and wastewater to and from the sitea primaryconcern for those living close to frackingsites.

Local air qualityThe intent of this section, as with otheraspects of the briefing, was to providecontext and overview. We would assumethat Dr Verdon would not dispute that thereare in fact 3 potential sources of airpollution from fracking operations as wehave outlined, namely impacts arising fromunderground activities; on site operations;and vehicular movements to and from thesite.Regarding Dr Verdons claim that thissection contains unsubstantiatedassertions we would not concur with thisopinion. He will note the use of words likecan and may within the text. We areconfident that the vast majority of scientists

would not disagree with any of thesequalified statements for example the


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inventory, 2011). Given that such data isavailable, Ifind it disappointing thatSGR/CIEH did not make use of it.

fracking process within the well itself whichmay release a range of airbornecontaminants or local air pollutants fromfracking can include volatile organic

compounds (VOCs), particulate matter(PM2.5 and PM10) and nitrogen oxides(NOx).We are aware of studies elsewhere, mostnotably the US, including those sources DrVerdon cites in his correspondence whichoffer evidence suggesting no major issueswith the specific pollutants assessed inthose studies. However, we are also awareof other work suggesting that despite agrowing body of evidence, a number of

data gaps persist. Most importantly, there isa need for more epidemiological studies toassess associations between risk factors,such as air (and water) pollution and healthoutcomes among populations living in closeproximity to shale gas operations.2With regards to the Bunch et al study, thiswork focused on Volatile OrganicCompounds (VOCs). As such the scope ofthe work, whilst extensive in terms of themeasurements made, nonetheless did not

cover pollutants of current concern within aUK context and in particular those typicallyassociated with traffic and other uses ofinternal combustion engines i.e. particulatematter (PM) and NO2. We would suggestthat Dr Verdons claim regarding the Bunchet al study that the work did not find levelsof air pollution that would cause concern issomewhat misleading as it does not qualifythe statement. More accurately this workdid not find levels of VOCs that would causeconcern. However, as outlined in thepreceeding paragraph there is other, morerecent work, suggesting that further work isneeded across a wide range of airpollutants.Dr Verdon will also undoubtedly be awarethat for the UK, air pollutants such asPM2.5, PM10 and NOx (particularly NO2)remain a concern. He will be aware, ascited in the text, that the Commons

2

http://www.researchgate.net/publication/261741800_Environmental_Public_Health_Dimensions_of_Shale_and_Tight_Gas_Development


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3. Climate change

The most notable omission in this section isthe findings of the IPCC made in the recentFifth Assessment Report. In this report, theIPCC state that in mitigationscenariosreaching about 450 ppm CO2eqconcentrations by 2100, natural gaspowergeneration without CCS acts as a bridgetechnology, with deploymentincreasingbefore peaking and falling to below currentlevels by 2050 anddeclining further in thesecond half of the century. The IPCC havemade it clearthat they see natural gasextracted from shale as a key component ofgreenhousegas mitigation strategies fromnow until 2050.In their assessment of the impact of shaledevelopment on renewable investment,SGR/CIEH neglect the potential positiveimpacts of abundant natural gas ondeployment of renewables. A report by theBrattle Group (2013) found a strongcomplementary relationship between

Environmental Audit Committee is currentlyconducting an inquiry (following on from its2011 Report). In February 2014 the EUCommission issued the UK Government

with a Letter of formal notice for breachingnitrogen dioxide (NO2) limit values in 16 of43 zones across the country3. NO2 is apollutant typically closely associated withthe use of vehicles and specifically internalcombustion engines. Whilst weacknowledge that the problem isparticularly acute in urban areas, it isunclear at present how widespreadintroduction of fracking across the UKwould impact on this specific pollutant and

indeed others associated with increasedvehicular movement.With regards to the potential for shale gasto reduce overall air pollution within the UK,we accept that future possibility. Howeverto achieve this will be dependent on a widerange of factors. Leaving aside trafficemissions, key amongst will be a switchaway from/phase out of coal.

Climate change

Concerns about the role of shale gas inundermining action on climate change werea central thrust of the report. We firstaddress Dr Verdons specific comments andthen make some broader comments.

Firstly, his statements regarding the IPCCare selective and misleading.

The fact that the IPCC Fifth AssessmentReport (AR5) states that natural gas powertechnology is a bridge technology does notnecessarily imply that shale gas will playany significant role in curbing GHGemissions. Indeed, we note that the medianscenarios presented in AR5 for stabilisingatmospheric concentrations between430ppm and 530ppm indicate that totalcarbon emissions from all natural gassources would be about 100 GtC (Figure6.15, Chapter 6). This is about the samesize as the carbon locked up in the worlds

3http://europa.eu/rapid/press-release_IP-14-154_en.htm


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renewables and natural gas, because theflexibility of natural gas provided backup tointermittent renewables in a way that coaland nuclear power cannot. This relationship

is evidenced by the fact that Texas, aleading state in terms of shale gasdevelopment, is also leading the way withrespect to renewable, and especially wind,energy.

current reserves of conventional gas (Figure7.2, Chapter 7). Hence, burning any of thereserves of unconventional gas (includingshale gas), without Carbon Capture and

Storage (CCS) technologies, would likelytake emissions beyond that level. And it isimportant to note that these scenarios alsorequire unabated coal use to virtually haltnow. If this does not happen (which is, ofcourse, highly unlikely), the necessaryrestrictions on natural gas use will be evengreater. We note that the uncertainties inthese scenarios are significant, but withreserves of unconventional gas beingconsiderably larger than those of

conventional gas, the potential for us to farexceed internationally agreed targetsthrough exploiting these reserves is veryreal.

Dr Verdons statement The IPCC havemade it clear that they see natural gasextracted from shale as a key component ofgreenhouse gas mitigation strategies fromnow until 2050 is also,not a balancedinterpretation of the relevant chapters of

AR5. The IPCC presents a wide range oftechnology and policy options and discussestheir implementation in a range ofscenarios. Many interpretations of theseoptions and scenarios are possible.Nowhere is shale gas described as a keycomponent.

Dr Verdon highlights the complementarynature of some renewables with natural gassources in the electricity supply sector.However, other gas sources are available,such as biogas and synthetic gas(processed from biomass) to which atransition could be made. A report by theNational Gridsuggested that 5-18% of UKgas could come from biogas by 20204. Withmuch stronger measures on energyconservation in homes, offices and industry,this proportion could be significantlyincreased.

The central argument of the section,

4National Grid (2009). The potential for Renewable Gas in the UK. http://www.nationalgrid.com


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4. Socio-economic issuesWhile the impact of shale development ongas prices is disputed, SGR/CIEHneglect a key aspect of the potential

economic impact, which is the impact onthe wider economy, and to the exchequer.It is expected that the need to import gaswill cost the UK economy over 15 billionp.a.. This is money lost to the UK economy,paying no tax and creating no jobs.Domestic shale development ensures thatthis revenue stream remains in the UK.SGR/CIEH compare jobs created in bothshale and renewable energy industries.This is a false comparisonthere is noreason why we cannot encourageinvestment in both of these industries.SGR/CIEH claim that shale development willhave a negative impact on tourism, butprovide no evidence to back up this claim.In fact, a recent study by OxfordEconomics (2013) has shown that, the 2009

though, is worth repeating: while shale gasmay replace coal locally, overall coal (andother fossil fuel) use is increasing. In theabsence of a global cap on emissions, the

use of shale gas will be as well as, notinstead of, coal, thereby resulting in anoverall increase in emissions. This is awidely understood conclusion, which waseven made by the UK government itself5.Proven reserves of fossil fuels are alreadyaround five times larger than those whichcan be burnt and still give us a relativelyhigh chance of keeping below theinternationally agreed 2C globaltemperature increase. Exploiting new fossil

fuel sources is likely to make it much harderto keep below this target, even iftechnologies like CCS can be rolled out on alarge scale. This is the central thrust of thewarning by the Committee on ClimateChange that we quoted.

Socio-economic issuesDr Verdons point about money lost to theUK economy due to gas imports can equallybe made as an argument for accelerated

investment and expansion of: energyconservation measures (especially inhomes); biogas; electric heating; solar hotwater panels; and a wide range of otherrenewable energy technologies. We discussthis further below.

On the issue of investment beingencouraged in both shale gas andrenewable industries, we note, for example,the current governments championing ofshale gas, while announcing its intention toimpose major restrictions on onshore windfarms. We also note its poor treatment inrecent years of the solar photovoltaicsindustry and the domestic energy efficiencyindustry6.

5MacKay, D.J.C and Stone, T.J. (2013) Potential greenhouse gas emissions associated with shale gas extraction

and use. A report for DECC. Available at: https://www.gov.uk/government/publications/potential-greenhouse-

gas-emissions-associated-with-shale-gasproduction-and-use.6See, for example: Webber P (2014). DECC creates more chaos in the energy efficiency sector.

http://www.sgr.org.uk/resources/decc-creates-more-chaos-energy-efficiency-sector


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recession aside, tourism in Pennsylvaniahas increased substantially in recent years,at the same time as the Marcellus shale hasbeen under development.

6. Can we manage without shale gas?In this section, SGR/CIEH neglect the manydifferent uses we have for natural gas.Specifically, they focus on the use ofnatural gas in electricity generation, whichaccounts for only about 1/3rd of ourconsumption, the rest being used indomestic heating and cooking, and in

industrial processes. SGR/CIEH make noattempt to examine how we might managewithout shale gas in these sectors, whichleaves a gaping hole in their analysis.Even in their discussion of the electricitysector, SGR/CIEH focus solely on the pricecomparison between fossil fuels andrenewables. The fact that renewables arebecoming cheaper is to be welcomed.However, the decreasing cost ofrenewables has little bearing on whetherrenewables alone will be able to meetthe needs of the UK consumer, both interms of overall demand, and in meetingthat demand as and when the consumerrequires it (i.e. without intermittency).This question, rather than price alone, isthe pertinent one with regards the issue ofwhether or not we need shale (or any

Regarding possible negative effects ontourism, we note the lack of academicresearch on this issue in the UK to date.However, our communication with people in

Lancashire (SGR is based in Lancashire)provides some anecdotal evidence that localbusinesses have serious concerns. Weagree that we could have been morespecific in explaining our sources in ourreport. However, we are not convinced thatthe report Dr Verdon refers to on tourism inPennsylvania provides relevant evidence,given that there are major social, economicand environmental differences between thatstate and the UK, and the report does not

explicitly investigate potential effects offracking.

Can we manage without shale gas?This is a very broad area, which brings innumerous issues, so our short analysis onlysought to scratch the surface.

We realise that we only briefly mentionedenergy conservation as a key way ofreducing dependence on natural gas

sources and, on reflection, we should havebeen more explicit in describing suchmeasures. Arguably the most importantexample is in reducing demand for gas forspace-heating in the buildings sectors viaimproved insulation. This can play a verylarge role but, unfortunately, as we notedabove, the current government has a poorrecord in this area. For example, recentfigures from the Dept of Energy andClimate Change indicate installations ofhome insulation have fallen 77-93%following the introduction of the latestgovernment schemes7.

Another key measure to reducedependence on natural gas for space-heating is a large-scale switch to efficientelectric sources. Heat pumps (especially air-

7Carrington D (2013). Number of households getting help with insulation plummets.

http://www.theguardian.com/environment/2013/dec/30/number-households-insulation-lofts-plummets-

green-deal


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other) gas. SGR/CIEH make no attemptto answer this, leaving a second gapinghole in their analysis.Fortunately, the National Grid have

provided a number of future energyscenarios, while Friends of the Earth havealso made an admirable attempt tooutlining their ideal future energy scenario.Whether one considers the NationalGrids Gone Green scenario, or Friends ofthe Earths Clean British Energyscenario, it is clear that even under themost optimal assumptions there is asubstantial need for natural gas in the UKsenergy sector, and that this need will

exist for some time to come, regardless ofwhether we choose to develop shalegas. SGR/CIEH claim a lack of space to gointo detail comparing renewables andshale gas. However, when this work hasalready been done, in great detail, by theNational Grid, it seems very strange indeedthat SGR/CIEH would want to completelyneglect their findings.Finally, SGR/CIEH note that in nationswhere extensive hydropower is available,

certain nations are able to becomesufficient in renewable energy. This is allwell and good, but has no bearing on thesituation in the UK, where we do not havecapacity for substantial hydropower, and istherefore irrelevant with respect to theissue of whether or not we need shale gasin the UK.

To conclude:I will couch my conclusions in the spirit inwhich this letter has been written, namelythat of providing peer review. Given theextent of factual errors, cherrypicking,failure to consider relevant literature, logicalfallacies and statements unsupported byevidence; were this report subjected to thekind of robust peer review on whichmodern science is based, then I do not

source) have a particular potential here8.Indeed, a large increase in the fraction ofUK energy supplied through electricity useespecially for heating and transportis at

the heart of numerous low carbon transitionstudies. This is why we made the mainfocus of this section the issue of replacinggas in the electricity supply sector. There iswidespread agreement for such a shiftacross government, industry andenvironmental NGOs. Again, on reflection,we could have made this point moreexplicitly.

And, as we noted above, concerted efforts

to increase the use of biogas are a key partof efforts in this area.

Furthermore, we also note that there are anumber of low carbon transition studiesthat have modelled UK scenarios which donot include use of gas with CCS. Forexample, WWF modelled two suchscenarios in their 2011 study9and theCentre for Alternative Technology modelledone in detail in their 2013 study10.

ConclusionAs with any briefing paper, particularly onethat seeks to provide an overview of anumber of complex aspects associated withwhat is currently a highly emotive andcontentious subject, there will always bescope for further improvement. However,we would reiterate, that this briefing didnot set out to provide an in-depth critiqueof every aspect referred to within the

8MacKay, D. (2009) Sustainable Energy without the hot air.9WWF (2011). Positive Energy: how renewable electricity can transform the UK by 2030.

http://www.org.uk/renewables10CAT (2013). Zero Carbon Britain: Rethinking the Future. http://zerocarbonbritain.org/


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believe it would make it through topublication. To put things more bluntly, thereport represents a shocking lack ofscholarship, and falls well short of the

standards one would expect from aprofessional society.My concerns have their principal basis inthe accurate portrayal of a delicate andsensitive topic. However, I feel I shouldalso point out the impact of the CIEHsendorsement of this report, both on theinstitution as a whole and on the rank and-file membership.The CIEH Professional Code of Conductplaces great importance upon maintaining

the standing and credibility of theorganisation (paragraphs 2.2 and2.3). More specifically, paragraph 4.5 statesthat members should take allreasonablesteps to ensure that information providedby them in a professional capacity on amatter within their knowledge orcompetence is accurate and complete. It isclear that this report achieves neitheraccuracy nor completeness.Presumably, the CIEH as an institution

wishes to add its voice to the debate overUK shale development, and morespecifically to have an influence onpolicymakers and regulators. However, byattaching their name and making claims ofimpartiality to a report that is neitherimpartial nor reaches the standard ofscholarship expected of a professionalbody, the CIEH risks of making itselfappear less than competent and less thanimpartial in the eyes of stakeholders at theheart of the UK shale discussion. As such,the more likely outcome is that the views ofthe CIEH are seen as both partisan and ill-informed, and therefore to be dismissed,with the net result that the CIEH ismarginalised from the debate, rather thanmore deeply involved.I also have concerns on the implications ofthis report for the rank-and-file membershipof CIEH, on whom this report reflectsextremely badly. Note, for example, thatthe lack of scholarship shown in this report

has already become the subject of ridiculeon social media. I myself do not regularly

publication. Rather it draws on relevantpeer-reviewed literature and independentexpert opinion to present an accessible yetrobust and fully-referenced overview of the

main issues, which readers may thenexplore in more detail.

In summary our view is, respectfully, thatmany of Dr Verdons criticisms eithermisrepresent our text or are not wellgrounded in the available evidence. Hencewe believe our report remains a usefulevidence-based guide of the majorenvironmental and socio-economic issuesrelated to shale gas development in the UK.

The panel of authors of this document havenow responded appropriately to thecomments made by Dr Verdon.

Comments from Graham Jukes

On the question of impartiality, I note thatDr Verdon has omitted to state in hiscorrespondence whether the views andcomments that he has expressed are his

own personal views or whether they havebeen endorsed by the University that he isassociated with. Given the comments hehas made about one of the authors of thisreport, his additional omission to make astatement of interest about any connectionwith the Oil and Gas Industry given hiscomments on social media channels castsdoubt on the credence of the views he hasexpressed.

Dr Verdonsfinal comments call intoquestion the professionalism not only ofthose who the CIEH has charged withproviding an excellent review of the currentlandscape, but the professionalism andstanding of the CIEH itself and itsmembers, which cannot go unchallenged.

The claims of factual errors, cherry-picking, failure to consider relevantliterature, logical fallacies and statementsunsupported by evidence, shocking lackof scholarship, falls well short of thestandards one should expect from a


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interact with CIEH members (at least, notto my knowledge). However, it would notbe surprising if some of your membershipwere working in sectors that are, or are

likely to, interact with the nascent UK shalegas industry. For example, in many casesoperators are looking to developrelationships with independentenvironmental consultants in order toensure their footprint is minimised.However, for those whose first interactionwith the CIEH is this report, it mightbe a natural assumption (erroneously, Ihope) that the lack of professionalismshown in this particular report is

representative of CIEH members moregenerally. One wonders whether this mightbecome a source of embarrassment,or indeed the cause of lost opportunitiesand marginalisation, for CIEH memberswho might otherwise have a role to play inadvisory and/or regulatory roles.Given the above failings, I would appreciatea response from the CIEH that outlines andjustifies the decision-making process thatlead to the CIEH attaching their name to

this report. In particular, if the stated aimwas to produce an impartial, evidence-based report, why the CIEH felt itappropriate to appoint as lead author anelection candidate for a political party thathas stated is opposition to the industry inthe starkest terms, and who hasdocumented publicly her involvement inprotests outside of drilling sites?I would also be interested to know whetherthe document was subject to any kind ofreview process by the CIEH (external orinternal) prior to publication? Of course,once published there is no going back, but Iwould also appreciate your response andcomments on the issues to which I havedrawn attention above.Yours sincerely,Dr. James Verdon, Ph.D., M.Sci,MA(Cantab),NERC Research Fellow,School of Earth Sciences,University or Bristol.

professional society rebuffed in thisresponse havenot been substantiated, areincorrect and misleading.

The report that has been produced by theCIEH is robust and factually referenced.The CIEH membership together with theregulatory authorities responsible forensuring the health of people and theircommunities are well served by itspublication.

There is no evidence that has beenpresented to suggest that the CIEH code ofconduct has been breached and concerns

expressed by Dr Verdon are misguided, andunfounded.

I dismiss entirely the remainder of thecomments by Dr Verdon as not evidencedand completely without foundation.

On the final point about peer review. Thereport prior to publication was circulatedinternally for comment and thosecomments were taken on board by the

authors. Final copy was submitted to meand published under my authority as adocument worthy of carrying the qualitymark of the CIEH.

Response by the authors and peerreviewers of the report compiled and editedbyGraham Jukes OBE CFCIEHChief ExecutiveChartered Institute of Environmental Health

Letters JV-CIEH #2

Documents

Transcript of Letters JV-CIEH #2