Attached and at the bottom of the post, is the letter I received today from DECC Correspondence Unit in response to the letter I delivered to 10 Downing Street on 1st December. (Apologies for it being in 3 bits – technical issues!)

My response is as follows:

Dear Mr McHugh,

I have no idea how you were selected for the task of responding to our letter to Mr Cameron, and have no idea how you went about composing this response, but as it consists entirely of the poorly thought through responses already in the public domain, I suspect it exercised the copy and paste facility on your computer more than your own grey matter. However, I am happy to give you another chance, and would like you to personally reflect on the following points and then go away and seek out some proper answers for us.

Taking your letter paragraph by paragraph:
Paragraph 1 – It is a trivial but revealing point that you thought our letter was dated the 10th January. It was actually dated 1st December. I guess you were given this task on 10th January and got round to your copy and pasting on the 12th.

Paragraph 2 – Thank you for the admission that “the Government is committed to ensuring that we maximise economic recovery of UK hydrocarbon resources“. This is totally consistent with the blinkered, myopic energy policy and big business inveigling that we have come to associate with this Government. It is a pity you cannot honestly make the statement substituting the word renewable for the word hydrocarbon. So, can you please explain how this statement fits with the Government’s legally binding commitments on climate change?

Paragraph 3 – That the “Government’s position on UK unconventional gas resources matches that which it takes towards conventional oil and gas ” underlines that the Government just does not ‘get it’. The technologies involved are fundamentally different. The risks are fundamentally different, and more significant. These extreme technologies, alongside deep coal bed methane and underground coal gasification, represent the desperate last attempts to squeeze out the last drops of hydrocarbons for the earth’s crusts. This is consistent enough with the highlighted statement in paragraph 2, but ought to shout out ‘BEWARE’ to anyone of intelligence. The economics are dodgey enough – but that is only a risk to the Government’s risk-loving mega-rich investor friends. Given the Government’s self-confessed inability to recognise the fundamental differences in this branch of the oil and gas industry, it invalidates any claim to have “full regard to the protection of the environment”. The conventional industry’s track record in this country is hardly blemish free. These unconventional industries have appalling records everywhere they have been established. Yet the Government remains steadfastly blasé. Perhaps, for example, you could tell us exactly what is DECC’s suggested remedy for a contaminated aquifer?

Paragraph 4 – This paragraph acknowledges the many reported and confirmed issues with shale gas in the US. I am sure that you would acknowledge the similar problems experienced in Australia. These are the only countries to date that have experienced commercial scale fracking. Problems are beginning to emerge in countries dabbling with fracking, e.g. Poland and China. Where do Australia/USA/Poland/China rank on the World Environmental Protection Index? Dismally at 48/49/22/116 respectively. The only frack site in the UK ran into immediate problems. Fracking will assuredly see us tumble down the EPI rankings. The question for you therefore has to be just how much evidence, that points to the fundamentally flawed nature of this technology, is required to trigger the precautionary principle with this Government?

Paragraph 5 – Again you highlight the arrogant and blasé disposition of the Government by assuming we have an adequately “robust regulatory system” to ensure “high standards of safety and environmental protection”. The hydrocarbon industries have always been amongst the worst performing industries – using tried and tested (and all too often failed) conventional methods. The litany of mining disasters and health issues lingers to this day. Serious spills of oil and gas from North Sea platforms occur at the rate of one a week, undermining oil companies’ claims to be doing everything possible to improve the safety of rigs – under this supposedly robust regulatory system! ( http://www.guardian.co.uk/environment/2011/jul/05/oil-gas-spills-north-sea ) We have seen for ourselves (Llandow Public Inquiry) that even when planning committees reject this industry’s application, after full and detailed scrutiny, the system is rigged to undermine local democracy and allow the industry full reign.

Paragraph 6 – Assurances about the the EA requiring full disclosure of chemicals used in fracking are undermined by a few inconvenient truths. There is no such thing as proprietary frack fluid. You do not buy it off the shelf with a nice contents label and a MSDS. It varies at every stage of the fracking and with variations in local geology. You would need a presence at every single fracking operation, at every single site, to sample the fluid used every time. This is a practical impossibility. So the EA asks the industry to declare what it is using. I have already demonstrated the lies that UK frackers, Cuadrilla and their friends, tell about the chemicals they use ( https://bridgendgreens.wordpress.com/2011/11/24/the-blatant-lies-of-the-frackers-and-their-friends/ ). After Cuadrilla fracked in Lancashire, the EA tested the flow back water. They identified all sorts of nasties flushed out of the shales, but there was no sign, in the analysis I have seen, of the chemicals Cuadrilla admitted to using – leave alone the ones they may not. The fact is that the EA can only identify things it makes an effort to look for. I cannot find things that it is not looking for. Do you 100% trust the industry to be completely honest about every chemical it uses in every frack job? Really?

Paragraphs 7,8 & 9 – same issues as paragraph 6.

Paragraph 10 – The Select Committee’s 2011 report can be systematically taken apart ( https://bridgendgreens.wordpress.com/2011/05/24/analysis-of-the-conclusions-and-recommendations-of-government-shale-gas-inquiry/ ), but let me focus on the essence of its absurdity that you so kindly flag up: “Shale gas extraction poses no direct risk to underground water aquifers, provided the well is constructed properly”. As various studies (e.g. Ingraffea, A. 2011. Unconventional gas Development from Shale Plays: Myths and Realities Related to Human Health Impacts) into the lifelong effectiveness of well casings shows a 5% failure rate in new oil and gas casings, and a 50% failure rate in wells 30 years old, the only rational conclusion is that shale gas extraction must pose a a significant risk to underground water aquifers. Would you agree?

Paragraph 11 – Contains the similar ‘Big Ifs’ of assuming “operational best practice” and “enforced through regulation”. This has already proven inadequate at one single, solitary site in Lancashire. Can you please explain how this can be expected across the many tens of thousands of largely remote and isolated sites across the country, if full scale production goes ahead as the Government clearly hopes? If only 1% of frack jobs has a problem and only 1% of well casings fail, have you any idea of the likely consequences?

Paragraph 12 – Please explain the “control measures to mitigate the risk of seismic tremors” that the Government claims to have imposed. What are they mitigating against? Do you think they are going to stop seismic activity happening? Do you think that they are going to stop seismic activity compromising the integrity of the well casings? Get as technical as you like – I am a geologist.

Paragraph 13 – What fab news, that there is going to be a “new Office of Unconventional Gas & Oil“, it suggests that Government does, after all see this branch of the industry as different . However, given that it appears to be, from what you say, a marketing office to attract investors; and given that investors regard Government regulation as a ‘hazard’, according to UK Shale Gas Business Confidence survey; the goal of a simplified and streamlined regulatory process is hardly re-assuring to us, as it clearly aimed at appeasing and attracting investors. Do you think you might get told off for copying and pasting this bit?

Paragraph 14 – Given the fact that you admit that “it is not at this stage possible to confirm that these constitute an economic resource, or to offer any estimates of how much resource may be technically and economically recoverable”, setting up a new Office of Unconventional Gas & Oil seems somewhat premature, wouldn’t you agree?

Paragraph 15 – In the spirit of mutually sharing “further information about shale gas and fracking”, I would recommend you look here: http://frack-off.org.uk/ or any of the links here: http://frack-off.org.uk/resources/fracking-links-library/ . “I hope that this is helpful.”

I look forward to continued correspondence with you.

Yours sincerely,

Andy Chyba
The Vale Says No!
Frack-Free Wales
Anti-Fracking Network