Background

The Irish EPA issued a report on Fracking: Current Knowledge and Potential Environmental Impacts, in early May 2012, and the Irish Times covered the event with a headline, “Fracking process risk not ‘significant’.” Neither the report itself nor EPA’s press release justifies that headline as it inaccurately summarises the findings of the report. The findings are more complicated and raise a number of critical concerns about going forward with fracking in Ireland. Those concerns are underlined by the recent report that the UK is having second thoughts about fracking (See Independent in Sources).

When the EPA launched the study by David Healy of Aberdeen University, there were criticisms in the press raised by some in the environmental community, based in part on claims that the University had too close a relationship with the fossil fuel industry, implying it would be biased in its assessment. The report shows no signs of any bias. Indeed its sources include a broad range of organisations that have closely followed the controversies surrounding fracking, including important academic studies in the US indicating potential groundwater contamination and very high greenhouse gas (GHG) emissions from fracking (see Osborn et al. and Howarth et al. in the Bibliography in Report). The report also includes studies supportive of fracking. There is a bias towards peer-reviewed scientific studies and we will return to this issue at the end.

The report is subtitled, “A Short Summary of Current Knowledge and Potential Environmental Impacts,” and it cost only €6,000. So we should not expect more than it promises – a short, inexpensive summary. EPA is committed, in conjunction with other agencies, to undertaking a more comprehensive study to be commissioned in 2012. This report offers a good start for laying out the basic risks from fracking and what we should look for in further assessments by EPA.

The Report

Perhaps the most important contribution of the report is its clear analysis of geological conditions and the implications for fracking in Europe, where shale gas formations exhibit more complexity than the relatively simple subsurface structures in North America. This is not surprising since the author, David Healy, is Senior Lecturer in Geomechanics in the Department of Geology & Petroleum Geology at the University of Aberdeen. Healy discusses the complex geology of rock fractures and the difficulties of predicting, or controlling, the impact from fracking operations on the existing fracture network in the subsurface, including the risks of creating new fractures or opening existing fractures other than those intended for the extraction of gas. This uncertainty in turn creates the risk of ground water contamination or seismic activity. In light of these concerns, Healy argues for the need for careful and detailed understanding, including mapping, of the subsurface conditions at any site being considered for fracking. Clearly such understanding must come before fracking is allowed to start at any site.

Fracking presents a number of significant risks. Like other assessments, this report argues that the actual operation of fracking (i.e., injecting large volumes of water mixed with sand and toxic chemicals), most often conducted thousands of feet below the surface and below drinking water sources, is not the main source of the risks. Rather the risks are associated with the quality and integrity of the well casing and cementing that are part of the infrastructure for fracking, the disposal of fracking liquids when they are returned to the surface after the actual fracking process, and the release of methane and toxic chemicals. There are also serious issues with the source of all the water required for each fracking well.

The most disturbing risk from fracking is the contamination of ground and surface water, especially that used for drinking purposes, from methane and the toxic chemicals in the fracking flowback liquids. The consensus seems to be that this threat comes from leaks or failures in the well casing and/or from the storage, handling and disposal of the fracking flowback liquids since the liquids and methane from any leaks, failures and spills can migrate to shallow drinking water and surface waters. Healy argues that these threats require strict regulations. They also require oversight of operations by regulatory agencies, including monitoring of well casing construction and maintenance as well as monitoring of the handling and disposal of fracking flowback fluids. The report indicates that current EU and Irish law require the full disclosure of all chemical additives used in fracking.

The report passes over, with limited discussion, the problems with the disposal of flowback and other fracking liquids, the source of very large volumes of water, and air emissions from fracking. Each has complications in Ireland. Fracking liquids have to be disposed somewhere and Ireland’s basic and still inadequate wastewater treatment facilities do not seem sufficient as disposal sites. The requirement of very large quantities of water for each well will put a severe stress on water resources in the west and northwest, just when Dublin and surrounding communities in the east are planning on tapping into some of these same water resources for their water needs. Climate change impacts likely will reduce further the water available for different sections and sectors of the country. Only a brief note is made of the consequences of emissions to the atmosphere of methane and chemicals, yet some assessments have indicated that fracking may have a larger greenhouse gas (GHG) footprint than coal.

Regulatory approaches in other countries and recommendations for further research for establishing best practices for fracking are outlined in the report. Of note, the EU has appointed a Technical Working Group on the regulation of shale gas extraction, there is an EU Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR), and the US EPA is publishing in 2012 an assessment of the impacts from fracking on groundwater. Given the uncertainties of our knowledge of many aspects of fracking operations, these reports should prove essential to any decision on fracking, and any decision should await the results of these reports.

The report criticizes much of the coverage on fracking in traditional media and websites, because such coverage is not peer-reviewed. The report also seems dismissive of any pressure from environmental groups on fracking decisions. All the while it stresses the critical need for more peer-reviewed analyses of fracking issues. We think the criticism is misplaced, as is the reliance on peer-reviewed studies. Peer-reviewed studies, which undergo rigorous scientific review and analysis by others in the particular field, are critically necessary for our understanding of the technical, scientific issues surrounding fracking. But while peer-reviewed studies may be necessary, they are not sufficient for our understanding of fracking. Fracking is as much about energy and land-use policies as it is about technical aspects. How fracking and methane emissions figure into Ireland’s energy policies and reliance on agriculture, a methane-producing activity, and how fracking impacts local land-use policies, and who gets to set those policies, are matters for thoughtful commentary in a participatory democracy, not necessarily peer-reviewed studies.

Conclusion

The report stresses that strict regulation, monitoring, and active enforcement is required to avoid many of the problems and risks from fracking, a conclusion shared by most assessments of fracking. Most agencies are capable of developing strict regulations, if they are freed of influence from the companies with vested interests, and are watched carefully by the public. Yet having the most detailed regulation, e.g., of the well casings and handling of flowback liquids, will have no effect unless the operators are subjected to oversight, inspection and enforcement with real consequences for violations.

As we have pointed out in earlier Reports in irish environment, the environmental oversight and enforcement infrastructure is sadly lacking in Ireland. There is little, if any, staffing, funding, expertise, or commitment for oversight and enforcement in most local authorities, and the shale gas formations are located in areas where the local authorities are most vulnerable to these deficiencies. EPA has general expertise in many areas but likely would require expanded enforcement authority and extensive training for its staff to oversee, monitor, inspect and enforce fracking regulations when developed. The larger question is where are those staff members coming from in the first place given the current economy, and historic lack of support by the government for active environmental enforcement, reinforced by recent statements by the EPA Director General. See “New York Plans to Frack, The Public Reacts: Implications for Fracking on the Island of Ireland,” in the Report section of irish environment (May 2012).

If nothing else was learned from the BP oil spill in the Gulf of Mexico, we learned from the President’s Commission that it was the failure of the well casing that was a major cause of the explosion and resulting spill and that, critically, it was a “culture of complacency” within the governmental regulatory agency, with little regulation or inspection or enforcement, that created the conditions for that worst environmental disaster in US history. We need to be watchful that fracking does not become Ireland’s environmental disaster for those same reasons.

Sources

David Healy, Hydraulic Fracturing or ‘Fracking’: A Short Summary of Current Knowledge and Potential Environmental Impacts, for the Irish EPA, a STRIVE Small Scale Study Report  www.epa.ie/downloads/pubs/research/sss/

“Fracking process risk not ‘significant’,” Irish Times, 11 May 2012  www.irishtimes.com/newspaper/breaking/2012/0511/breaking27.html

“Government backtracks on fracking,” Independent, 21 May 2012 www.independent.co.uk/environment/green-living/government-backtracks-on-fracking-7768853.html

The National Commission on the Deepwater Horizon Oil Spill and Offshore Drilling www.oilspillcommission.gov/