Welsh Petroleum and Gas Consultation Guidelines

DEADLINE IS MIDNIGHT ON TUESDAY 25th SEPTEMBER – PLEASE RESPOND TODAY!

What’s this? Another consultation?

Yes, indeed. They just keep coming, don’t they? But don’t go away – this one is a bit different.

In what way?

Firstly, it’s a consultation run by the Welsh Government, not the people in Westminster. And secondly, they are consulting on its new policy to oppose fracking and not allow any further oil and gas exploration in Wales.

That sounds like excellent news. How come they’re allowed to do that?

Because of devolution, basically. The Wales Act 2017, which received Royal Assent last year, hands control over the consenting of energy projects – including the future onshore licensing of oil & gas extraction – to the Welsh government from 1st October this year.

Hmm. It would be nice to get that kind of local decision-making in Yorkshire and Lancashire too, wouldn’t it?

We can but dream. The point is that the Welsh government are on the verge of shutting down any chance of fossil fuel production in Wales (including fracking)  – but they are consulting on this policy first before they put this plan into practice. Which is where you come in.

I don’t live in Wales. Am I allowed to respond to the consultation?

Yes, anyone in the UK is invited to respond to the consultation (we’ve checked). So this is an opportunity to support a government-led policy (for a change) and add your voice to the consultation.

OK, I’m in. How do I respond?

The home page for this consultation can be found here. As you’ll see, there are quite a few PDF documents on this page, as the Welsh Government have produced a range of Consultation documents which they are asking people to comment on, but don’t let that put you off. The document on the principles behind the consultation itself can be found here.

The easiest way is to respond online, which you can do so by clicking here.

You can also download the response form here: 180703-petroleum-consultation-response-form

And then email it to: YmatebionYnni-EnergyResponses@gov.wales

Or post it to: Fossil Fuel Policy – Petroleum Consultation, Division of Decarbonisation and Energy, Department of Energy, Planning and Rural Affairs, Welsh government, Cathays Park, Cardiff, CF10 3NQ.

However, you would need to get postal responses in the post by first thing Monday morning to arrive before the deadline on Tuesday, so we recommend using the online form

DEADLINE IS 23.59 ON TUESDAY 25th SEPTEMBER.

OK. What can I say in response to the consultation?

As you’ll see, the format is a series of boxes asking if you have a view on some the Consultation Documents that are on the home page. We’ve prepared some possible responses, but if you have time, please read the documents yourself and write your own response.

YOU DON’T HAVE TO ADD COMMENTS TO EVERY BOX BUT PLEASE MAKE SURE YOU ANSWER ‘YES’ TO QUESTION 8 – giving brief reasons in the box below it. 

QUESTION 1 – Do you have a view on the Climate Change evidence?

This question refers to summary sections 5.10-5.20 of the Consultation Document and the advice they received from the Committee on Climate Change (CCC) , which you can find on this PDF (it’s only 3 pages long). this discusses the CCC’s three tests for exploitation of shale gas, and whether these can be applied to Coal Bed Methane (CBM) production. Here are some things that you can mention in your reply.

  • There is no evidence that the three Tests as described by the Committee on Climate Change will be met by the shale gas industry, as there has only been one well fracked in the UK to date. Therefore it is correct for the Welsh government to oppose fracking and other fossil fuel production in Wales.
  • The Committee on Climate Change acknowledges that there is little research into the climate change impact of Coal Bed Methane production, but the impact of fugitive methane on the climate – along with the emissions from burning the gas itself and the emissions from the thousands of vehicles needed to service well sites – would make it wholly inappropriate for this industry to be established in Wales.
  • The regulatory system for shale gas production in England has already been shown to be anything but ‘gold standard’ and relies on a system of self-monitoring by the fracking companies.
  • Planning conditions and other regulations at well sites in England are breached with impunity, as has been shown at Kirby Misperton in Yorkshire and Preston New Road in Lancashire. The Environment Agency and other regulatory bodies show little appetite to sanction companies that break the rules, and are happy for the fracking industry to continue to ‘mark its own homework’ as regards regulation.
  • There is no proof that any gas recovered from fracking or Coal Bed Methane production in Wales would replace imported gas, as required by the Committee on Climate Change Test two. Gas would be the property of whatever private company that produced it, and the company would sell it to whoever they choose. It’s noted that currently over 30% of gas produced offshore in the UK is exported.
  • Given the scale of the climate crisis affecting our planet, starting a new fossil fuel industries would seem to be extremely damaging and negative move, and would probably prevent Wales (and the rest of the UK) from meeting its climate targets.
  • There is no evidence that additional production emissions from shale gas wells will be offset through reductions elsewhere in the UK economy, as required by test 3 of the Climate Change Committee.
  • Fighting climate change is the greatest challenge we face, and the Welsh government should do anything they can to reduce the country’s emissions of both CO2 and methane – starting by implementing this policy which is being consulted on.

QUESTION 2 – Do you have a view on the Socio-Environmental evidence?

This question refers to summary sections 5.21-5.38 of the Consultation Document and the socio-economic and environmental reports they received from these sources.
– A Regeneris / AMEC / Cardiff University report from 2015 – see this PDF (122 pages)
– A review of the above report by the Cardiff Business School – see this PDF. (8 pages)
– A review by the Geoenvironmental research centre, Cardiff University – see this PDF. (40 pages)

A lot of the stuff contained in the above is quite technical,  but here are some points you can make in your response.

  • A report by Professor Peter Styles of Keele University has warned against fracking in coal-mining areas, saying that this could cause earthquakes and other environmental issues. The key points of his review, which you can access here, is that companies and regulators have failed to use all available geological data, as they are required to do, for planning application purposes, and that historic coal mining data has been overlooked or ignored.
  • The Cardiff Business School report concludes that ‘unconventional gas in Wales is unlikely to be of the scale and nature to create any longer term transformative economic effects for the region’. Therefore – given the climate change and environmental impacts this industry has around the world – there seems little point in allowing this to develop in Wales.
  • The Cardiff Business School report also says, ‘unconventional gas economic impacts are likely to be transitory with much of the regional economic activity supported during early stage operations, and with drilling crews expected to be highly mobile.’ Developing a shale gas or CBM industry in Wales is therefore unlikely to provide many jobs, and very few long term jobs – particularly when set against potential job losses in the farming and tourism industry, both of which are major employers.
  • The widespread and well-documented environmental impacts of fracking and CBM are not explored in detail within the evidence provided, and there seems to be a great deal of negative evidence that should also be considered. Much of this is documented in the Compendium of Scientific, Medical, and Media findings Demonstrating Risks and Harms of Fracking (5th edition), which is highly recommended reading.
  • The Compendium concludes: Growing evidence shows that regulations are simply not capable of preventing harm. That is both because the number of wells and their attendant infrastructure keeps increasing and, more importantly, because some of fracking’s many component parts, which include the subterranean geological landscape itself, are simply not controllable.”
  • The U.S. Environmental Protection Agency released the final version of a six-year, $29 million study in December 2016, highlighting the conclusion that hydraulic fracturing has caused contamination to drinking water resources across the country. Tom Burke, EPA Deputy Administrator, said “We found scientific evidence of impacts to drinking water resources at each stage of the hydraulic fracturing water cycle.”

There is a lot more that can be said on the social and environmental impacts of fracking, so please feel free to add your own comments.

QUESTION 3 – Do you have a view on the Health evidence?

This question refers to summary sections 5.39-5.48 of the Consultation Document and this three-page report from Public Health Wales. As with the notoriously uninformed Public Health England, they claim that risks should be low as long as the industry is robustly regulated, and recommends a Wales-specific review. We think this is ignoring much of the evidence out there, so here are some things you can say.

  • There is a huge amount of peer-reviewed evidence showing that fracking is detrimental to health – summarised here – and this alone is reason enough for the Welsh Government to not allow unconventional gas production.
  • In 2016 the UK organisation Medact reviewed over 350 academic papers published in the previous twelve months on the impacts of fracking for shale gas in the following areas: air and water quality, health, climate change, social well-being, economics, noise and light pollution and seismic events. Following the release of this report, Medact released a statement saying that “hydraulic fracturing for shale gas (‘fracking’) poses significant risks to public health and calls for an immediate moratorium to allow time for a full and comprehensive health and environmental impact assessment (HIA) to be completed.” You can read a summary of the report here, or download the full report here.
  • A peer-reviewed research paper published by Johns Hopkins Bloomberg School of Public Health shows that expectant mothers who live near fracking wells in Pennsylvania are at an increased risk of giving birth prematurely and for having high-risk pregnancies.
  • Research studies in Pennsylvania have found that drilling and fracking activities have been associated with a 27% increase in cardiology hospitalisations for people living near fracking wells.
  • A research paper from the Johns Hopkins Bloomberg School of Public Health research shows that people with asthma who live near bigger or larger numbers of active unconventional natural gas wells operated by the fracking industry in Pennsylvania are 1.5 to four times likelier to have asthma attacks than those who live farther away
  • Research published in Reviews on Environmental Health concluded that exposure to chemical pollution near fracking well-sites can be linked to reproductive and developmental health impacts including infertility, miscarriage or spontaneous abortion, impaired foetal growth, and low birth weight.
  • Another study by the University of Pittsburgh found that babies born to mothers near fracking wells in Pennsylvania had a lower birth weight compared to babies born away from fracking sites.
  • A Yale University study found that people living near fracking wells had increased numbers of skin conditions and upper respiratory conditions.

Question 4 – Do you have a view on the Transport and Planning evidence?

This question refers to summary sections 5.49-5.57 of the Consultation Document and this report. Here are some points you can make.

  • The report identified that there would be the following negative impacts: Potential for accelerated road surface degradation; Risk of increased accidents; Risk of accidental release of hazardous material during transportation; Air pollution impacts; Noise and on Nature conservation. These problems – and more – have been found everywhere else that the unconventional gas industry has established itself, and therefore this industry should not be welcomed in Wales.
  • Unconventional gas production requires hundreds of HGV truck movements per well site, which can have a serious negative impacts on nearby residents and communities.
  • The impact of fracking or CBM production on the small roads of the Welsh countryside could be very damaging, and would result in more traffic accidents, degradation of the road surfaces,
  • The Welsh government should also consider the impact of all this extra traffic on the tourist and farming economies of rural Wales, which could be significant and damaging.
  • The air pollution caused by the vast increase in HGV traffic can have far-reaching health impacts. Research by Johns Hopkins Bloomberg School of Public Health show that residents living near fracking wells are nearly twice as likely to suffer from a combination of migraine headaches, chronic nasal and sinus symptoms and severe fatigue.
  • The disposal of waste water from fracking and CBM would be a significant problem, as re-injection causes earthquakes and there would be too much volume to clean in processing plants (if that were possible).

Question 5 – Do you have a view on the Decommissioning evidence?

This question refers to summary sections 5.58-5.62 of the Consultation Document and this report from Natural Resources Wales. We haven’t gone into this in detail as we are opposed to fracking and CBM well sites being established in the first place, so don’t feel it’s worth getting into long discussions about how they’re decommissioned, but you could make the following point.

  • Well sites can leak methane for many years and the regulatory system is not capable of the level of long term monitoring needed to ensure leaks are blocked in a timely fashion. It is much better not to allow fracking and CBM well sites to be established in the first place than worry about how to prevent methane leaks after the damage has been done.

Question 6 – Do you have a view on the Economic evidence?

This question refers to summary sections 5.63-5.71 of the Consultation Document and the reports highlighted in question 2 above. You can make the following points:

  • I would agree with the conclusion in the evidence submitted that ‘Unconventional gas in Wales is unlikely to be of the scale and nature to create any longer term transformative economic effects for the region.’. The potential impacts on health, the rural road system and the climate are, however, likely to be much greater than any potential economic benefit of another fossil fuel.
  • The economic case for shale gas and CBM has not been proven and many people, from Lord Stern to ex-CEO of Cuadrilla Lord Browne have said that a domestic onshore gas industry would not result in lower prices.
  • The Welsh Government would be advised to note that the impact of an unconventional gas industry on the rural economy is likely to be severe. As a draft government report on fracking and the rural economy said in 2015, “Shale gas may transform a pristine and quiet natural region, bringing increased industrialisation. As a result, rural businesses that rely on clean air, land, water and/or a tranquil environment may suffer losses from this change, such as agriculture, tourism, organic farming, hunting, fishing and outdoor recreation.”

Question 7 asks if you have any evidence that you think the Welsh Government should look at. If so, you can post the links or upload the documents.

Here are some that we feel they should look at, but please add your own if you have different ones.

Fracking and Historic Coal Mining: Their relationship and should they coincide? Professor Peter Styles, Keele University https://www.keele.ac.uk/media/keeleuniversity/facnatsci/schgge/news/2018/Fracking%20and%20Mining-%20Styles%202018.pdf

The implications of fracking in UK Gas Import substitution – Professor Calvin Jones, Cardiff Business School.
https://cdn.friendsoftheearth.uk/sites/default/files/downloads/FOE-Frack-Import-Report_0.pdf

Shale Gas Production in England – a Public Health Assessment – Medact
https://www.medact.org/wp-content/uploads/2016/07/medact_shale-gas_WEB.pdf

Compendium of Scientific, Medical, and Media findings Demonstrating Risks and Harms of Fracking (5th edition)
https://www.psr.org/wp-content/uploads/2018/04/Fracking_Science_Compendium_5.pdf

Fracking Industry Wells Associated with Premature Birth – Johns Hopkins University
https://www.jhsph.edu/news/news-releases/2015/study-fracking-industry-wells-associated-with-premature-birth.html

Fracking Industry Wells Associated With Increased Risk of Asthma Attacks – Johns Hopkins University
https://www.jhsph.edu/news/news-releases/2016/study-fracking-industry-wells-associated-with-increased-risk-of-asthma-attacks.html

Developmental and reproductive effects of chemicals associated with unconventional oil and natural gas operations
https://www.degruyter.com/view/j/reveh.2014.29.issue-4/reveh-2014-0057/reveh-2014-0057.xml?format=INT

Studies find Babies near Fracking well-sites have lower birth weight:
http://archive.alleghenyfront.org/story/study-finds-babies-near-fracking-sites-had-lower-birth-weight.html

Study: Fracking associated with migraines, fatigue, chronic nasal and sinus symptoms – Johns Hopkins University
https://hub.jhu.edu/2016/08/25/fracking-health-migraine-sinus-fatigue/

Question 8 asks if you agree with the proposed policy: We will not undertake any new petroleum licensing in Wales, or support applications for hydraulic fracturing petroleum license consents.

We strongly recommend that you answer ‘Yes’ to this question.

Below that there is a box where you can give your reasons for this. We would suggest you write this in  your own words, including some or all of these points.

  • impact on climate change
  • impact on human health
  • impact on Wales’s rural economy
  • environmental damage caused by fracking and CBM
  • threat of drinking water contamination
  • difficulty in getting rid of contaminated waste water
  • impact to road system
  • negative effect on wildlife
  • threat to local communities from traffic, air pollution, etc.
  • risk of earthquakes in former coal-mining areas
  • no social licence for fracking
  • etc etc!

Question 9 allows you to upload more documents if you wish to support the above.

And that’s it! Please remember to send this in and then pour yourself a drink for a job well done!