Letters JV-CIEH #3

8/11/2019 Letters JV-CIEH #3

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School of Earth Sciences,

University of Bristol,

Wills Memorial Building,

Queens Road,

Bristol, BS8 1RJ

[email protected]

29/08/2014

To the board of the Chartered Institute for Environmental Health,

I am writing to address the response provided to me by the CIEH in response to my criticism

of their recent report, Shale Gas and Fracking: Examining the Evidence. The principal

component of this response consisted of a point-by-point discussion of the issues I raised,

from which broader conclusions were drawn. In this response, the authors make several

implicit and explicit admissions of error and/or omission in the original report, as well asrecognising the need for substantial clarification regarding various misleading statements.

Given that the authors of the report have recognised the need for such corrections and

clarifications, I suggest that the CIEH may wish to consider publishing either an erratum or a

corrected/clarified version of the original document, such that I am not the sole beneficiary of

what is currently a private discussion. To aid in this regard, I comment on the point-by-point

response provided by the authors below.

Authorship and Impartiality: The report is entitled Shale Gas and Fracking: Examining

the Evidence. In the second paragraph, the report states an increasing volume of impartial,

evidence-based information now exists. This briefing draws on peer-reviewed literature and

independent expert opinion to present an accessible yet robust and fully-referenced overview

of the main issues.

Even though the authors make no direct claim to impartiality, the above statements, in

combination with the fact that it is authored by a chartered professional society, will lead

most readers to assume that the intention of the report is to provide an impartial overview. I

certainly think that most readers would be very surprised to learn that the authors never

intended to take an impartial view, as the CIEH have now made clear. Therefore, I do not

think it unreasonable that the report should make its true intentions, as described in the

response to me, but not in the original document, clear at the beginning to all readers.

Introduction: The original statement in the CIEH report makes the claim that shale gas

extraction is unlike conventional gas extraction in that it requires high well densities and

horizontal drilling. In my criticism I point out that this statement is in error, because high well

densities and horizontal wells are common in conventional hydrocarbon extraction.

I firstly note that in the response, the authors completely fail to address my correction

regarding horizontal wells, which I take to be a tacit admission of error, and therefore must be

corrected in the original report.

The authors clarify that the comparison they are making is with either offshore oil and gas

projects and/or current developments in Qatar and Russia. This clarification should be stated

in the report. Without this clarification, the original statement is misleading. The primary

audience for this report is (presumably) the UK, and the subject is onshore drilling. Thereforethe natural comparison to be made, without the suggested clarification, is with existing


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onshore drilling in the UK.

Readers will therefore be misled if they make this most obvious comparison, because

conventional fields with high well densities can be found in the UK. For example, over 100

wells have been drilled in the 40km2surrounding Gainsborough, a high well density similar

to what might be expected in a shale gas development. Similar well densities can be identified

in fields across the East Midlands oil province. I recommend that the authors make use of thefollowing download if they require further information:

www1.gly.bris.ac.uk/~JamesVerdon/Downloads/UK_Onshore.kml.

Seismicity: The initial statement used by the CIEH is poorly phrased. They argue that the

seismic risk is therefore potentially greater, which begs the question greater than what?

Greater than in the areas of North America that are unfaulted (relatively speaking: few

structural geologists would ever describe any region as being completely free of tectonic

structures)? Perhaps yes. But is the seismic risk also greater than for the many hydraulic

stimulations carried out in areas of North America that do have complex geology, but yet

where induced seismicity is still rare? By leaving out crucial details, the CIEH report is open

to misinterpretation, and should be clarified.

The use of the statement by Professor Stephenson is an oversimplification of the issue. In

order to trigger seismicity, a hydraulic fracture must not only impinge on a fault, but impinge

on a fault that is critically stressed in the current stress field such that it is already close to the

failure criteria. Only a small subset of faults will meet this criterion, hence why induced

seismicity is a rare occurrence, even in faulted areas.

In their response, the CIEH authors claim that they do not imply that deformation of the

Preese Hall well impinged on integrity. However, anyone unfamiliar with events at Preese

Hall reading the statement the far greater potential risk from such incidents is that of well-

integrity failure the Lancashire earthquakes damaged the well so severely it had to be

abandoned will be misled to make this inference. The authors should therefore make the

clarification in the original report that there was no impairment of well integrity at Preese

Hall, and that well integrity concerns were not the reason for well abandonment.

Finally, I note that the authors have ignored my recommendation that they examine existing

records of onshore wells to determine the extent to which wellbore integrity might be an

issue. I draw the authors attention to the recent work published by Davies et al (2014)1, and

in particular their section 4.5, which considers onshore UK wells directly, finding one site

where wellbore integrity has been an issue, out of over 2,000 onshore wells. Perhaps the

situation might be better characterised as not that the data are lacking, but that the authors are

not interested in looking at it. I cannot see how the authors can fail to cite relevant papers, and

then claim that data are lacking.

Water and Ground Contamination: The authors have missed the reasons for my citing the

additional Pennsylvania studies. My aim was not simply to draw attention to other studies that

have not shown methane contamination, but because these papers have a direct bearing on

whether the Jackson et al. (2013) paper really does provide evidence for contamination due to

drilling. In my criticism of the CIEH report, I noted the well-acknowledged issues faced by

the Jackson et al. paper, most notably the small number of (non-random) samples, and the

lack of a baseline. The authors have failed to note or address these criticisms in their

response.

1Davies et al., 2014: Oil and gas wells and their integrity: Implications for shale and unconventional resource

exploitation. Marine and Petroleum Geology 56, 239-254.


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The Molofsky et al. and CRP papers are of relevance because they provide a far greater

number of samples covering the same area. As the number of samples increases, the apparent

correlation found by Jackson et al. disappears, implying that the correlation found is likely to

be spurious.

The UGSG reports are relevant because they provide data from similar areas that have not yet

seen shale gas extraction, thereby providing a proxy baseline. The baseline samples taken bythe USGS find similar methane levels to those found by Jackson et al.. Again, given that

similar methane levels have been found in areas that havent been drilled, this calls into

question the Jackson et al. conclusions. Importantly, the methane found by the USGS in

undrilled areas had a thermogenic isotopic signature, demonstrating that this particular

measurement cannot be relied upon to distinguish naturally occurring methane from that

caused by drilling, as the CIEH report infers.

Given the above observations, all of which are subsequent to the Jackson et al. paper, the

evidence presented becomes less than convincing. This is why discussing all of the above

studies, rather than cherry-picking the Jackson et al. study, is vital, as they have a direct

bearing on the evidence presented. The CIEH report should be amended to properly reflect

the uncertainties inherent the Jackson et al. paper. In particular, the comment made in thereport that the thermogenic isotopic signature suggest[s] drinking water contamination

resulting from drilling operations should be removed or amended, because similar isotopic

signatures have been recorded in areas that have not been exploited for shale gas.

In addition, in their response the CIEH authors claim to have cited other studies: We

referenced the Jackson study (and others) as examples of ones which found evidence of

methane contamination (my emphasis). The only references in the CIEH paper that do so are

Jackson et al. (2013) and Osborne et al. (2011). The authors should be aware that these two

papers in fact use the same dataset, with the Jackson et al. paper containing additional

samples in addition to the entirety of the Osborne et al. dataset. It is hardly surprising that two

papers that use the same dataset should report similar [] findings.

Finally, the statement the reality is likely to lie somewhere between what proponents claim,and opponents fear, while technically true, is so vague as to be completely meaningless.

Water Use and Waste Water: The correct statement to be used is, as per my original

comment, shale wells are rarely fracked more than once in their lifetime. I am glad that the

authors have acknowledged their error, and look forward to seeing a correction.

I am aware that there are few publicly available datasets that record the number of times a

well is re-fracked. However, this sort of information could easily have been ascertained with

the briefest of conversation with operating groups. The original comment in the CIEH report

makes it apparent that the authors were not prepared to take this step, and appear to have little

familiarity with current industry practice.The authors claim to have simply presented the views of Water UK. However, the

memorandum of understanding signed by Water UK and UKOOG must surely rank amongst

the most significant of their communications on the issue. In that the authors neglect to

mention this memorandum, it is apparent that they have failed to fully present the views of

Water UK. If they wish to claim that they are accurately representing Water UKs views, the

CIEH report should at the very least be amended to include a mention of this memorandum.

I agree that life-cycle assessments of water use might not necessarily tell the full picture. That

being so, I would equally argue that life cycle assessments have an important role to play, and

certainly should not be dismissed out of hand without extensive justification. Nothing in the

original report or the response provided gives any reasonable justification for the authors

decision to entirely omit these (or any other) life-cycle assessments from their report. They


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should either provide such justification in their original report, or mention the findings of

such studies.

My comments regarding NORM stem from my concern regarding the sensitivity of the issue

of radioactivity in the public mind, where this issue is often poorly understood. While I agree

that flowback water containing NORM may require additional processing, the authors should

make clear in the original report that the NORM content of waste fluid, as studied by Almondet al., does not pose a safety risk, even if it may increase the complexity of the treatment

pathway.

I should add that while the flowback water at the Preese Hall well did contain NORM, these

levels will be dependent of the local geology and will be variable. Therefore, the CIEH

statement would be better characterised as and may be classified as radioactive waste,

depending on local geology, pending further measurements after future stimulations.

Local Air Quality: I do not dispute whether there are different potential sources of air

pollution during the shale gas extraction process. However, I am interested in whether or not

these potential sources of pollution will actually create air quality issues. As such, I welcomethe use of measured data wherever possible, while it appears that the CIEH does not.

In the original report, VOCs are cited as a potential pollutant. In my criticism I point out

papers that have made extensive measurements of VOCs. In response the authors claim that

the measurements made in these particular papers [do] not cover pollutants of current

concern within a UK context. This statement can only therefore be read as implying that,

according to the authors, VOCs are not of current concern within a UK context, which

stands in contradiction to their assertion in the original report.

The references I cited (Bunch et al. (2014) and PA DEP (2010) provide direct measurements

of VOCs. The CIEH report directly identifies VOCs as a possible local air pollutant. I fail to

see why it is that, because these papers do not also measure PM2.5/10 or NOx, the data they

provide on VOCs should be considered so irrelevant that they be omitted entirely, unless thecomments about VOCs are entirely removed from the report (which the authors may choose

to do, seeing as in their comments they appear to dismiss VOCs as a concern within a UK

context).

In the context of this report, to any reasonable reader the use of can and may implies a

reasonable level of probability. In their response, the CIEH authors backtrack to reduce the

significance of their statements to, in effect, near-meaninglessness any probability between

0 100%. The CIEH response presumes to know what the majority of scientists might

think. I would not presume to speak on behalf of any of my colleagues, but I would

respectfully submit that the majority of scientists are not interested in can and may, they

are interested in quantifying risks, or at the very least they are interested in identifying the

factors that may exacerbate risks, and the steps that can be taken to mitigate risks. The CIEHreport should attempt to do so, because the clarification provided by the CIEH response

renders their original comments made in the report near to meaningless.

I agree with the CIEH response that a key factor in reducing UK air pollution will be the

switch away from coal, although I note that if the authors believe it to be key, it should

surely be stated in the original report. I would add that a switch away from diesel vehicles to

those powered by LNG would also be helpful in this regard. However, this discussion is

omitted from the original report, which could have examined whether shale gas development

in the UK might help accelerate the switch from coal, and from diesel to LNG, as it has done

in the USA. The reference I make to the PA DEP air emissions inventory (2011) shows

exactly this effect.


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Climate Change: The IPCC do not see shale gas development as inconsistent with reaching

climate change targets, which is the implication of the CIEH report and response. I quote

Ottmar Edenhofer, co-chair of the AR5 report, when asked about shale gas at the AR5 release

press conference: We have in the energy supply also the shale gas revolution, and we say

that this can be very consistent with low carbon development, with decarbonisation. That's

quite clear (my emphasis added).

The CIEH response regarding conventional and unconventional reserves is illogical. There is

no reason why all conventional reserves (located mainly in Russia, Qatar and Iran) should be

burned before we begin looking at UK shale gas reserves. In other words, why should the UK

consumer be forced to import Russian gas, rather than producing it domestically, simply

because the conventional field reserve estimates were booked before unconventional ones?

The gas is currently still in the ground in both places. Several studies, including that shown in

the CIEH report (Figure 3) have indicated that the cost of compressing and shipping LNG

from these distant sources leaves a higher CO2 footprint than domestically produced shale

gas.

Earlier in their response, the CIEH themselves quote from a report that states burgeoning

unconventional gas production today tends to replaceproduction that would have comefromoffshore locations or countries rich in conventional gas, such as Russia or Qatar (my

emphasis added). Assuming the CIEH authors support the view they quote (and it is central to

their response to the earlier criticism) then they have now contradicted themselves.

Incidentally, in their response the authors claim that reserves of unconventional gas [are]

considerably larger than those of unconventional gas. In their 2013 assessment2, the EIA

estimate world shale gas reserves of 97Tcf, compared to conventional reserves of 6,741Tcf.

Even considering the broader category of unproved resources, the EIA estimate 7,201Tcf of

shale gas and 8,842Tcf for conventional. I would be interested to know of the CIEH authors

source for their currently unsubstantiated comment.

I concur with the assertion that without a global cap on emissions, coal use will continue,

preventing us from keeping below a 2C target. However, this argument could be applied toany technology used in the UK: we could substantially increase the amount of renewable

energy in the UK, but without a global emissions target we are unlikely to stay below a 2C

target. More specifically, the fact that without a global cap on emissions we are unlikely to

reach a 2C target is true whether or not we develop shale gas in the UK. As such the line of

argument pursued by the CIEH is at best tangential to the issue in question, namely whether

or not we should develop shale gas in the UK.

Socio-economic issues: I am aware that the increasing cost of gas imports can be made as an

argument for increased investment and expansion of energy conservation and renewable

technologies. I fully support such an argument. However, the majority of scenario estimatespredict that the UK will continue to import significant quantities of natural gas, even with

increased investment in and expansion of renewable energy sources. In their response, the

CIEH authors have pinned their argument to what could be described as the most hopeful

case, rather than that considered to be the most realistic according to most experts.

I have also noted the mixed messages emanating from our current government regarding

renewable energy, and am aware that this may have an impact on investment. As a supporter

of renewable energy, this disappoints me as much as it does the CIEH authors. However, it is

not clear that the governments current treatment of renewables is relevant to the question of

whether shale gas should be extracted, unless the CIEH can present evidence that the

governments lukewarm attitude to renewables is a direct result of the discovery of the UKs

shale gas potential, as opposed to other considerations (such as the unpopularity of renewable

2 http://www.eia.gov/analysis/studies/worldshalegas/


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levies on bills, or the dislike among parts of the rural electorate of large-scale wind turbines).

The evidence I have presented, and which has not been disputed by the CIEH, shows that

there is no reason the two industries cannot be developed in tandem.

As regards the impact of shale development on tourism, the CIEH authors did not note the

lack of academic research on this issue in the UK to date, as they claim in their response.

They stated directly that shale gas development could have severe consequences in, forexample, agriculture and tourism. This is not a statement suggesting a lack of research. If the

authors feel that there has been a lack of research on the impacts on tourism, they should

correct the original report to reflect this, rather than assert that there could be severe

consequences (an extremely emotive comment). As such, the authors response shows the

need for a correction, while the sources for their claims should be made specific, as the

authors have agreed to in their response.

I accept that the report examining tourism in Pennsylvania does not directly study the impacts

of shale development on tourism, and never claimed that it did. However, in the absence of

better evidence, it is surely of relevance that tourism has increased in a state that has seen

more shale gas development than almost any other. Without doubt it is better evidence than

the anecdotes provided by the CIEH response. However, since the CIEH seem to think thatanecdotes are an acceptable substitute for evidence, I refer them to the response3made by

over 50 Lancashire businesses and organizations, including Stay Blackpool, which represents

over 200 Blackpool B&Bs and hotels. In this letter, they outline their concerns not about

shale gas but about the effects of anti-fracking protests on their businesses, protests that are

likely to be given greater impetus by self-admittedly partial reports such as that written by the

CIEH, and whose ranks have included the CIEHs lead author.

Can we manage without shale gas? My criticism of this section stemmed from the fact that

the CIEH report had failed to consider the use of gas in the industrial and domestic sectors,

which leaves a gaping hole in their analysis. I am glad that they have attempted to address this

criticism in their response, and I hope that this additional response will be incorporated into arevised report.

As discussed above, I maintain that most studies and most experts expect that the UK will be

using natural gas in both the electricity, domestic and industrial sectors for some time to

come. For example, in their response the authors cite the WWF Positive Energy report. I

note that none of the WWF scenarios anticipate zero use of gas, as implied by the CIEH (the

lowest amount of installed gas capacity is 16GW). Moreover, of their 6 scenarios, the

majority (4) still predict significant gas generation capacity, mitigated by CCS. The

lowermost two scenarios cited by the CIEH are even described as Stretch scenarios by the

WWF (while the others are considered Core), which furthers the impression that the CIEH

are cherry-picking the most hopeful scenarios for their argument, rather than the most

realistic.While I welcome the CIEHs more hopeful scenarios, I believe a report that wishes to

question whether or not we should exploit shale gas in the UK should at least reflect what

most experts believe is most likely to happen, not just what the authors hope might happen.

In summary:

As demonstrated above, the response provided by the CIEH is a weak defense of their

original report. At best, it is clear from the authors own responses that the original report

contains errors; that necessary discussion has been omitted; and that there is considerable

scope for misleading comments to be clarified. I hope that such corrections are made to a

"http://www.nwenergy.org.uk/news/


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revised version of the document, such that the CIEH authors and I are not the sole

beneficiaries of the current discussion. Given the issues with the original report as it stands,

without further corrections and clarifications the remainder of my comments, dismissed out of

hand by Graham Jukes (GJ), remain relevant.

I note that the comments made by GJ imply that this report was submitted and overseen by

him, and published under [his] authority. As such, he has a direct interest in seeing that thequality of the report is not questioned, because doing so may represent a direct challenge to

his authority and reputation. He is therefore in no place to fairly judge whether my criticisms

have merit, and I question his failure to take note of this issue.

I note in passing that GJs comments (Point 3) demonstrate a very poor understanding of

the peer review process. Peer reviewed papers are often rejected on the basis of comments of

one reviewer, even while other reviewers assent to publication. Moreover, the fact that a

report may have multiple authors has no bearing on the quality of a paper, nor how it should

be treated within the auspices of peer review.

Finally, since it is requested of me, I am happy to state that the views presented are my own. I

have not sought endorsement of them by Bristol University, nor do I see how their

endorsement or otherwise should affect the CIEHs response to the material presented. Mycurrent position at Bristol University is that of NERC Early Career Research Fellow: that is to

say my academic funding is provided to me via the Natural Environment Research Council. I

have previously received academic funding from the UK Energy Research Centre, and the

Canadian Federal and Saskatchewan Provincial governments through the PTRC.

However, I am happy to record that I believe that shale gas extraction in the UK could be

beneficial both from an economic perspective, but also environmentally in that more

abundant natural gas supplies can help replace coal in electricity generation and diesel as a

transport fuel. The views I have expressed on social media sites are no secret, but have been

arrived at through impartial examination of the evidence, something that the CIEH has, by its

own admission, failed to do. These views are shared by applied geoscientists from most major

UK universities4

.

Yours sincerely,

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

NERC Research Fellow,

School of Earth Sciences,

University or Bristol.

4 http://www.theguardian.com/environment/2014/jun/04/lancashire-shale-gas-uk-energy-gap

Letters JV-CIEH #3

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