Below are my rather hurried of the cuff remarks – I simply haven’t time to do a thorough job on it at the moment – but feel free to plunder my fuller report that I prepared for Welsh Government some time ago on behalf of Frack-Free Wales:
A shorter synopsis of this report is found here:
1 Do you think that the Environmental Report has identified the significant environmental effects of the activities that follow the licensing round? If not, what other significant effects do you think we have missed, and why?
Fundamental underestimation of potential scale of the industry for starters, given experiences in other production areas.
Lack of consideration of impacts of VOCs from various sources in the processes.
Lack off any significant consideration of the impact of chemicals known to be used in fracking on human health and biodiversity
No consideration of the silicosis danger for workers (in particular) from the type of sand preferred by the industry as a prop pant.
Astonishing misrepresentation of the threat of well-integrity being lost and the implications this has for fugitive methane emissions and groundwater contamination.
Failure to comprehend that the seismicity issue is not confined to surface impacts – but far more certainly on said well-integrity, which can be compromised by seismicity well under the 3.0 threshold
There is also no consideration of the full range of significant negative population impacts in terms of jobs lost (especially in leisure/tourism and agriculture; impacts on property values; the transient nature of the jobs associated with the fracking process etc.
2 Do you agree with the conclusions of the report and the recommendations for avoiding, reducing or off-setting significant effects of the activities that follow the licensing round? If not, what do you think should be the key recommendations and why?
There is no acknowledgement that this activity id fundamentally different to all previous onshore oil & gas exploitation and that it needs a bespoke set of strict regulations and the resources to impose them. The whole issue of accountability needs addressing – as currently companies can split themselves up into smaller units and get operators off the hook by simply going bankrupt and disappearing of the face of the earth. Directors need to accept criminal liability and personal sanctions in return for the massive incomes they take.
3 Do you agree with the proposed arrangements for monitoring significant of the activities that follow the licensing round, detailed in the Environmental Report? If not, what measures do you propose?
These are, quite frankly, pathetic – relying far too often on the operators to self-monitor and self regulate.For example, frack fluids can aviary at every site and each consecutive farce you at each site. Some will be mild, some will be highly toxic cocktails. Operator disclosure is not enough. Every single frack job at every single site needs sampling and analysing. This would be a massive undertaking – but anything less is inadequate and will be subject to abuse.