Looks like the Environment Agency have made their mind up...either through blinkers, bribery, lies or bullying... Think they may need some extra pressure...any thing you can find to pick up on and add to/reply to in their response letter below, please feel free. These people need to know we stand together! We have received and acknowledge your letter of 12 December 2014 outlining your concerns about shale gas activities, and the Environment Agency’s role in regulating these activities. We understand that there are many who feel like you, and who share your concerns that the extraction of shale gas may pose harm to human health and to the environment. You letter raises a number of points, which we have addressed in turn below: You asked whether we have watched the film Truth for the Dash for Cash. We can assure you that we have watched the film. There is a range of information and evidence available on this subject; as the environmental regulator we use our own experts and draw upon best available knowledge and practice to make evidence based decisions. We note that the film is not accurate regarding the United Kingdom’s legislation and regulation of activities such as exploration of shale gas, and that many of the practices highlighted in the film are of shale gas activities in other countries, will not be allowed in this country. Disclosure and combination of chemicals You quote the film when you state that “Fracking companies do not have to disclose exact details of the chemicals they will inject into our land (25-75% of which will remain there) because they are commercially confidential”. You also state that “it is not clear that the whole process uses toxic chemicals; the substances combined are a lethal concoction of toxic chemicals”, and that “fracking companies have been caught lying as to the quantity of chemicals they will put in the ground” Some countries where shale gas activities occur (i.e. those referred to in the film) may not have regulatory systems in place that give government organisations the authority to require companies to disclose the chemicals that operators are using. However, in the United Kingdom, we have legal powers under Regulation 60 of the Environmental Permitting Regulations 2010 to require companies to disclose the chemicals proposed for use, and the concentration of those chemicals when they apply for an Environmental Permit. We disclose information on the chemicals and their maximum concentration on the Public Register, which you can view by visiting an Area Environment Agency office. We acknowledge that shale gas exploration poses risks to the environment and to people. We have undertaken a comprehensive assessment of the environmental risks of shale gas, and found that risks are at their highest if not managed or mitigated properly. If managed properly then the risks reduce. Every industry has its own risks, and it is the Environment Agency’s role to make sure that companies can demonstrate that they understand the risks to the environment from their operations and show how they will reduce those risks to an acceptable level. We consider that we have the right regulatory powers and controls in place to manage environmental risks arising from the exploration of shale gas. Because we require companies to disclose the chemicals that they propose to use, and their concentrations, we are able to assess the environmental risks posed by them. We can then ensure that any Environmental Permit incorporates the appropriate protection measures to control the activity, including safe storage and handling of all chemicals to ensure that the level of protection stipulated in the legislation is achieved. We have the authority to stop activities on a site, if controls are breached and/or if a significant risk becomes apparent. We work closely with other organisations that have a role in the regulation of shale gas, including the Office of Unconventional Gas and Oil, the Department of Climate Change, who are responsible for managing any earthquake risks, and the Health and Safety Executive, who regulate the health and safety risks to people. The Health and Safety Executive is responsible for ensuring the appropriate design and construction of a well casing for any and gas boreholes, and ensuring well integrity, which links closely to our role in the mitigation of environmental risks. Damage to countryside The way that a site is established and laid out is a matter that is determined by the relevant Mineral Planning Authority who is responsible for considering and determining planning applications. Environmental risks/incidents You have quoted that “forty-three percent of all operator spills have already caused groundwater contamination in Weld County, Colarado” Our controls require operators to construct and manage sites so that any spills would be retained and do not cause pollution to water. Such controls include construction of an impermeable liner across the site, which drains to a holding tank that is sealed off in the event of a spill to prevent discharge to ground or watercourse. Potentially polluting materials must also be stored in sealed containment. If there is an incident which causes pollution of the environment, environmental damage, or if there is a breach or non-compliance with environment legislation, we have a range of enforcement powers available to us. Our powers include enforcement notices, suspension and revocation of permits, injunctions and ultimately criminal sanctions, including prosecution. Any enforcement action will be proportionate to the risks posed to people and the environment and also to the seriousness of the breach of the law. We can also require operators to undertake remedial work to rectify the environmental damage. Caves under the Mendips You state that “you make no mention of the dangers to the caves or the mines under the Mendips? How can the fracking companies know where they are drilling?” Our previous letter of 27 November 2014, referred directly to your concerns regarding the potential exploration of shale gas in the Mendips. Any company wishing to drill in this area will need to demonstrate to us that they understand the risks to the environment from their operations. They will need to provide us with a conceptual model showing nearby rivers, lakes, wells and boreholes, and the hydrogeological relationship between the unique geological formation in the Mendips and any freshwater or saline aquifers that their proposed borehole passes through. Our regulatory controls are in place to protect people and the environment. If the activity poses an unacceptable risk to the environment, the activity will not be permitted. Well casings You have stated that “it is evident from the video, the well casings crack, the percentage of cracked wells clearly stated on the video. How is there NOT a risk toxic chemicals will enter groundwater? The Health and Safety Executive regulates the working practices adopted by operators. These include the health and safety management of the site, well integrity and the reporting of dangerous occurrences. Where leakage from a well into rock formation is suspected, acoustic tools are available to locate the leak and steps can be taken to seal it. Risks from fluids left in the well, will be controlled through the environmental permit granted for the activity. Such controls include use of best practice for decommissioning wells once activities cease and monitoring of groundwater. Under the Environment Agency/Health and Safety Executive ‘working together’ agreement, we will be jointly inspecting and sharing information on sites where hydraulic fracturing is taking place. Yours sincerely Miss K Thomas National Requests Team Leader Environment Agency
Posted on: Tue, 30 Dec 2014 14:02:27 +0000
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