Schist! The UK is not FOR SHALE


(Revised Nik Holliman July 2015)

 Unconventional gas extraction, or hydraulic fracturing, produces both value and environmental destruction and in this sense it is not unconventional. On the other hand the technology and a gigantic extractive industry, so supportive of the status quo, so confident about horizontal drilling, that generate anxiety and confusion, are by no means conventional. Any confusion is partly due to the fact that reliable figures for all strategic commodities and materials are always difficult to obtain, for reasons of competitive advantage, confidentiality and the protection of trade formulations. It also has something to do with the information we are presented with, which is based on the experience drawn so far from the seemingly unregulated onshore operations in the USA, where conditions are so very different from those in the U.K. and the EU.

In order to avoid adding to the confusion this article attempts to muster opposing arguments in a schematic form, leaving the reader to evaluate unconventional gas extraction autonomously. After all, the alternative would be to rely on the wisdom of consultants, experts and pundits, which invariably seems to lead to guarded judgements designed to defend the clients’ interests, ideas poached from a public consultation process and a fat fee.

When massive energy projects are in question, public deference to authorities and experts magnifies the confusion. Two examples drawn from the last 60 years demonstrate this. In the 1950s and 1960s the public deferred to experts who convinced the majority that nuclear power would provide electricity that would be too cheap to meter. Officially, the North Sea gas and oil project that took off in the 1970s was heralded as the solution to the problem of providing cheap, ‘clean’ energy. Both of these major public projects led to huge costs: economically, financially, environmentally and in terms of health and safety. Nuclear power ended up as a very expensive and risky way of producing electricity and decommissioning will prove to be even more so. The ventures in the North Sea resulted in bills from British Gas that increased with such regularity ,in for example the 1980s, that householders would never notice if their energy efficiency measures were effective. Next, the offshore gas and oil fields were mortgaged in the 1980s and 1990s in order to pay for the de-industrialisation of the UK, coupled with the demolition of organisations representing the abstract labour classes and the destruction of work-based apprenticeship schemes. At present, unconventional oil and gas extraction threatens to be another exercise in political economy rather than a logical and progressive piece of that jigsaw that a modern energy policy is supposed to be.

The proposed schema can help us decide which of these two it is by moderating the authorities’ gift for ambiguity and compromise and the tendency for a few environmentalists and journalists to over-state their case. In addition, arranging arguments and facts in this form gives the reader the opportunity to use the schema as the basis for a decision matrix that serves to objectify the subjective elements that always creep into arguments about any major decision that will affect a society and everyone’s environment for the next 18-30 years. Such a projected timetable makes it clear that ‘fracking’ is an important trans-generational issue, as indeed were/are the nuclear power programme and the extraction of gas and oil from under the North Sea.

The differences between today’s world and those of a few decades ago are enormous but we do have the opportunity to take heed of the precautionary principle, the warnings about impacts and unintended consequences -including whether there is a concealed commitment to use taxpayers’ money to subsidise onshore gas and oil operations in the same way that offshore operations were subsidised to the tune of £60bn between 1970 and 1990.[i]

Another difference is that there is more enlightenment about environmental problems and more awareness of reckless conduct in corporate and public life. There is too a wisp of understanding that environmental problems are also public health issues that will have a major impact on a national, publicly provided health service, free at the point of delivery. Left unresolved, many environmental problems could produce fallout that overwhelms the National Health Service and any other kind of publicly provided health system.

Prof. Christopher Harvie in: “The Guardian” 14/02/1995


Hydraulic fracturing for shale gas: arguments for and against


Evidence /



Evidence / source

i) The situation in the UK and EU is not comparable to that in the USA where there is more space, lower population densities and far greater economies of scale in production. Its successes as the world leader in ‘fracking’, followed by Canada, are not easily replicated.

The UK is one of the 4 most densely populated and urbanised countries in the world, along with the Netherlands and Belgium.

i) US production of unconventional gas reached»7.5 trillion ft3(212bn m3) in 2011, or 39% of all natural gas production and a 33% increase on 2005 levels. Export of shale gas is under review.

Energy Information Office, US Department of Energy


The UK Government gave permission for hydraulic fracturing to resume, in principle.

December 2012


“We are going all out for fracking.”

Prime Minister Cameron, January 2014


The current UK Government is committed to fracking.

Announcement of 28/07/14


Consumption of primary energy per capita is lower in the UK than in the USA and Germany.

“Germany is advised to keep the fracking option open.” EU Energy Commissioner,

Gunther Oettinger.

“BZ am Sonntag”


State Economics

Minister of Germany, Herr Gabriel

Bildangswerk fur Kommunal-politik Bayern eV (BKB)

ii) The shale basins in the UK are smaller and more dispersed than the US ones, therefore less likely to deliver similar results. Also the source rock in the UK usually contains less gas at a lower pressure.

The British Geological Survey’s (BGS) shale gas research group.

ii) The current UK Government is committed to fracking because half the area of the UK, especially the North of England, is underlain by 1329 trillion ft3 (37.64 trillion m3) of recoverable and non-recoverable shale gas.

Special offers:

Tax ‘breaks’ to energy companies,

It is too early for the Chancellor to predict financial benefits for communities.

Head, UK Energy Research Centre in BBC R4 “Today” interview (12/11/14)

There is an urgent need for more CH4supplies at gas-fired power stations because ‘The lights will go out.’

Special offers:

100% of the business rates collected from shale gas schemes will go directly to local authorities (LAs) in return for giving planning permission for fracking.


£0.1m / test drill and 1% of future revenues to communities.


A State fund of 2m euros for the technical development of fracking.


Chair, INEOS, the petro-chemical group

6% of revenues pledged to homeowners, landowners and local communities.

(“Today” interview, BBC R4 29/9/14)


INEOS to extract shale gas from under the Midland Valley of Scotland, for its carbon chemistry division and to supply Grangemouth refinery.14th competitive round for fracking licenses.

This Swiss group’s £600m+ investment over 5 – 6 years in shale gas extraction was announced on 20/11/14.


Confederation of British Industries’ (CBI) Climate Change Board


iii) Historically some members of OPEC and other bodies manipulated their figures for reserves and production in order to preserve a seat at the conference table.

In the 90s and 00s statistics for oil reserves were artificially stabilised. No assurance has been given that the figures for shale gas reserves are authentic and realistic.

iii) There are abundant shale deposits under half of the UK, especially in the North of England,(and under UK inland waters, where social impacts would be lower).


£1.3 billion m3 of gas in shale deposits under Germany.

National Environment Office (UBA)

0.7 - 2.3 billion m3 of gas in shale deposits under Germany.

Bundesanstalt fur Gewissen-schaften und Rohestoffe (BGR)

The recovery factor from shale in the USA is 8% - 29%. The UK rate will be lower because of the difference in the composition of the shales.

Co-ordinator of BGS shale gas research, Ed Hough, “The Economic Impact on UK Energy Policy of Shale Gas and Oil”, House of Lords Economic Committee


“…estimates of the UK’s shale gas resource still incomplete…”


It is estimated that 130 trillion ft3 (3.68 trillion m3) of the onshore reserves of CH4 could meet the UK’s needs for 50 years.


25% of shale gas will be extracted in the first year. For 20 years production will then taper off.    


Chair, INEOS Upstream

iv) The scope for reducing per capita primary energy consumption is greater in countries that are less dependent on motorcars, domestic air travel, air conditioning, etc than the USA.

e.g. in Denmark and the Netherlands where fracking was rejected..

iv) Licenced tests in Denmark (40% share) and Poland by TOTAL.

The G7 countries and the EU will need more primary energy if they are to grow their economies according to the demands of the ‘global’, competitive market and face the rise of the BRICS or MINT group of national economies.

Per capita primary energy consumption has not levelled off nor declined globally and the USA’s highest per capita consumption rate makes it atypical.


Germany and

France imposed moratoria on fracking.


Nicolas Sarko-schiste,

ex-French president, is pro-fracking.

“Le Monde” 27/9/14

v) Energy conservation / efficiency can reduce energy use and CO2 emissions, and secure energy and power supplies.

For each £1 invested in conservation measures, over £3 worth of benefits can be recouped.

v) The demand for fossil fuel is still increasing in the UK and the rest of the world.

The exponential demand or the sigmoid growth curves for energy flattened slightly i.e. the rate of increase in consumption slowed down in the UK, but not globally.


Unison e.g. urges an energy review of homes to avoid large-scale fracking.

Conservation/efficiency will not bridge the gap between the demands of growing economies and the supply of conventional fossil fuels.


vi) Prof. John Twidell’s renewable energy strategy to meet the UK’s annual demands, by annual plant capacity, including plant with storage capability, is as follows: a) wind onshore 25GW, wind offshore 35GW

The UK’s wind regime is one of the best in   Europe for power generation.

Wind power accounted for 14.2% of UK power compared to 13.2% for nuclear on 22/10/14. Wind turbines generated 20% of power on 25/10/14.

(National Grid)

vi) With 40 wells / pad, shale gas could generate 19706GWh of electricity over its lifetime compared to a typical wind farm of 546 ha, with 26 turbines that could generate 3719GWh over its lifetime.

Report of the Institute of Directors (IoD)


b) tidal range 30GW, tidal stream 1GW, wave 10GW

Everywhere in the UK is <130 km from the sea - lower transmission losses and more potential beneficiaries.


c) sewage, organic waste and algal digestion gas (CH4) 1.5GW

UK sewage engineers produced bio-gas during WWII


2 UK energy companies will offer bio-gas accounts.


CH4 digestion of chicken droppings has been demonstrated.

Harold Bates, 1973.


d) combined heat and power biomass 2GW


e) medium-to-large hydro 2GW, small hydro 0.5GW, solar photovoltaic 5GW


?) geothermal energy:100MW/

km-2 pad / 20 year period.

John Twidell and Tony Weir in: “Renewable Energy Resources”


?) Solar energy will play an important role in the UK’s renewable energy ‘mix’.

e.g. Passive solar space heating, drying , solar water heating and

some photo-



vii) Fracking is not essential to the supply of the UK’s energy mix or the energy split for power generation. The gas energy gap is the result of other complex pressures within the capitalist system.

Energy prices drive other prices by more than 10 times their nominal value. This in turn fuels crises. (Paul Mobbs, economist)

vii) Fracking is essential in order to supply CH4 to more gas-fired power plants and avoid the energy ‘crunch’ and power cuts.

Coal-fired power stations have been de-commissioned e.g. Easington and more gas-fired power stations are due to come online. 4 nuclear power stations have been de-commissioned.

‘The lights will go out.’ argument is scare-mongering that ignores load-shedding for example.

Lighting accounts for <20% of the UK’s power load and 90% of this is due to over-illumination.


viii) Fracking is an energy-intensive extractive process.

The hydraulic / compression equipment, generators and pumps are heavy users of power. Drilling hard or bed-rock is power intensive.

viii) The current UK Government is committed to fracking.

Announcement of 28/07/14


Supplementing conventional fossil fuels with 130 trillion ft3                 of shale gas, in order to meet growing demand for CH4, will add to CO2, NOx and fugitive CH4 (a more reactive greenhouse gas than CO2) emissions.

The natural environment sets a limit on how much CO2and CH4can be absorbed / sequestered.

ix) CH4 is a chemical bond of one part carbon and 4 parts hydrogen, which determines that it produces less CO2during combustion than other fossil fuels e.g.   the CO2 emissions of coal / kWh produced at a power station.

Comparison by weight of the energy values (calorific or heat of combustion) of fossil fuels:

Natural CH4 gas = 54.00 MJ/kg

Shale CH4 gas = 54.50MJ/kg

Coal = 32.50MJ/kg

Diesel oil = 44.80MJ/kg.

(The Society of Environmental Toxicology and Chemistry recommends comparisons related to 1 kg.)


Where gas competes with coal in power generation, the use of shale gas could lower CO2 emissions.

International Panel on Climate Change (IPCC),2014

The UK has a unique potential for deep, offshore, underground, coal gasification (UGS) - minus fracking’s associated risks.

Algy Cluff, CE Cluff Natural Resources re: his 8 offshore licenses and its Kincardine license area, underlain by 335m tonnes of coal. “City AM” (17/11/14)


Inconsistent with national and international environmental agreements, directives, laws, pacts and protocols.

The Climate Change Act.

Montreal Protocol on ozone destroying gases. National Planning Policy Framework (paragraph 93). Renewables Directive (EU).

EU pact (24/10/14) to reduce CO2 emissions by 40% by 2030.


Inconsistent with 2020 UK CO2 emissions targets

National Guidance (to LAs).


“The science of global warming, the maths of our emissions…led to the categorical conclusions that shale gas must remain in the ground.”

Kevin Anderson, Tyndall Centre for Climate Change.


Fracking is not a logical response to climate change.

Response to Climate Change (RTCC)  


x) Fracking is a more expensive method of extracting gas and oil (enhanced recovery relying on artificial drive - chemical flooding) than drilling and extracting (primary recovery relying on natural forces - gas cap or solution gas drive) from oilfields in Russia or Saudi Arabia.

Based on the IoD’s scenario of 100 pads, each with 10 vertical wells and 4 horizontal wells (laterals) / vertical drill, Ernst & Young’s study (April 2014). Estimated that 4000 laterals drilled over an 18-year period would cost £33bn (in supply chain activities alone), £17bn worth of specialised skills (jobs) and equipment, £2.2bn worth of steel; £1.6bn for rig manufacturing. £4.1bn for waste storage and transport.

x) Adopting a more expensive extractive process is justified by the Increase in world fuel prices, geo-political problems/risks and the imperative to establish security of supply.

World fuel prices are increasing with world population increase, further development of the BRICS and MINT countries, signs of ‘peak’ oil and general resource depletion and the changing geopolitics of the world e.g. Libya.

The current decline in conventional oil prices, caused mainly by the productivity of the ‘fracking’ industry in the USA, limits the ability of fracking companies to re-pay investment loans towards a more expensive process of extraction.

I-Gas Energy,   which has licences to ‘frack’ in Lancashire and the Midlands, recorded a fall in profits, i valuation and share prices -attributed to recent falls in the price of oil.(26/06/15)

Unconventional oil and gas extraction has brought down the price of conventional oil and gas in the USA.

“City AM” 17/11/14&

BBC R4 City News 18/11/14

Fracking is driven by deeper crises in national and international economies and

the US energy policy seems to be driven by a rush for self-sufficiency and homeland security – not lower prices.


There is a possibility of creating millionaire farmers now exists.

Chair and founder of Ineos petro-chemical group (20/11/14)


To bring a single pad on stream would cost £333m -UK Onshore Operators’ Group (UKOOG)


xi) This is new technology and insufficiently tried and tested.

No evidence of the safety of pioneering fracks in the NE.

There is a long history and accumulated experience of extracting conventional fossil fuels.

xi) In the N.E. of England and other parts of the UK small-scale ‘fracking’ has already taken place for 20 years without problems.

Interview on the “Today” programme BBC R4 June 2014


In the late 1990s employees of Mitchell Energy invented hydraulic fracturing in order to mine the Barnett shale deposits in Texas.


Drilling into the Paris basin tested the nerves of Parisians in the 1980s

Guy Debord, “

Commentaires sur ‘La Societe du Spectacle’“


Shale oil extraction was very successful in the P.R. of China and USSR

in the early 1980s.

JW Smith, *Synthfuels” in: “Perspectives on Energy” 3rd ed. 1982

xii) There are no set standards for the common pad (wells / pad, size of pad) or for hydraulic fracturing.


(Cuadrilla is a member)

xii) “It is early days yet.”

Research Fracking in Europe (ReFINE)

xiii) There is a lack of data about the viability of extracting shale gas in the U.K.

Prof Andrew Aplin, University of Durham

xiii) Test drills can reveal the necessary information.

Test drills planned for the Gainsborough Trough area (Total E&P UK), Lancashire (Cuadrilla)


Petroleum Exploration & Development Licence (PEDL) No. 227 covers the Mendips, Somerset

UK Methane


PEDL applied for to test drill in Salford.



? PEDL applied for to frack under London (the Paris basin margins).

London Local Power (RTCC)

Many “known unknowns”: e.g. which geological fault lines are still active?

Prof. Richard Davies (ReFine)

In the next 2-3 years 20-40 exploratory wells will be drilled in order to find the answers.

Chief Executive of UKOOG

What will be the flow rate of CH4 from shale deposits?

Prof. Richard Davies (ReFine)

Gas flow rates will be tested for 90 days at 2 sites in Lancashire


xiv) 30 000 wells would be needed in UK to exploit shale gas (i.e. 5000 pads each with 6 vertical wells)

Prof Andrew Aplin, University of Durham

xiv) In the gas-richer shales under the North of England, fewer wells may be needed.


xv) Since AD 1086 property ownership, rights and the law of trespass extend below finished ground level. Both the 1947 & 1990 Town & Country Planning Acts required/s that any building, engineering or mining on, in, over or under the ground first secures planning permission.

Property rights extend deeper than mineral rights but ownership is different. It is undisclosed whether rights and ownership extend to the depth of the horizontal drills (laterals) for fracking.

Who owns the gas in shale deposits? Freeholders? How deep will licences be valid for?  

xv) Rights and ownership do not extend as deep as the laterals.

The current UK Government is committed to fracking.

Planning law will be changed and powers will be taken from LAs and given to the Environment Agency.

There are tunnels and horizontal drills under many areas of the UK that might be used as precedents: e.g. under Dover, London, Ramsgate, Lancashire, Derbyshire, Nottinghamshire Yorkshire, Durham and Northumberland.

The geometry of the earth can set a limit to conflict-free entitlement and ownership below ground.

The earth’s curvature and its 30km deep crust.

What’s mine is mine and yours is mine. So keep on mining.

Precedent: Mining is based on claims by those who usually have no right to claim

74% of the British public are against changes to the trespass laws that would allow fracking companies to drill under homes without permission.

Greenpeace / Friends of the Earth petition


The current UK Government is committed to fracking. And will change the law of trespass.

Announcements of 28/07/14 and later.

xvi) Fracking will increase the despoliation of Areas of Outstanding Natural Beauty (AONBs), the countryside, the coastline (Dorset), national parks, protected landscapes and rural/urban, tourist/visitor attractions.

Each pad of 2 ha (4.8 acres) will house facilities, infrastructure and generate carcinogens, carcinogenic mutagens (Radium-226), dust, noise, vibration, HGV traffic, due to 24hr operations.

xvi) The impact of fracking has been exaggerated. Drilling pads will not ‘sterilise’ land for other uses nor put the land out-of-bounds.

The Environment Agency gave permission for fracking to take place under the Peak District National Park in Derbyshire. (27/06/14)

Light pollution nuisance from 24hr operations.

Night-time photograph of a pad in the US State of Pennsylvania by Jim Lo- Scalzo, dpa.


Vibration nuisance from 24hr operations.

Disturbance to historic buildings, local domestic, social, industrial and commercial activities e.g. sleep, fine motor skills, schooling, field experiments, mensuration, weighing.


Adverse impact on the tranquillity and amenity of e.g. national parks.

South Downs National Park Authority’s Planning Committee 11/09/14


xvii) No LA planning permissions have been given but the Environment Agency has permitted fracking in Derbyshire.

West Sussex County Council (WSCC) and the South Downs National Park Authority’s Planning Committee.

xvii) Planning/mineral applications were submitted to test drill in Roseacre and Little Plempton in Lancashire, Wisborough Green in Sussex, Fernhurst in the South Downs National Park and in East Yorkshire.

Cuadrilla’s application to Lancashire County Council (LCC)

Celtique Energie’s Weald applications to WSCC and the South Downs National Park Authority.


LCC refused planning permission to Cuadrilla to ‘frack’ in two locations in   Lancashire by 9 to 3 against.(29/06/15)


Celtique’s mineral applications for permission to test drill at Wisborough Green were rejected by West Sussex County Council (WSCC) (23/07/14) and at Fernhurst by the South Downs National Park Authority’s Planning Committee


Celtique failed to demonstrate exceptional circumstances and that the public interest will be served. (11/09/14)

The CE of Celtique, Geoff Davies, claimed that the rejection of their application is “based on a subjective and unjustified interpretation of planning guidance.” (11/09/14)

Celtique has appealed against the Wisborough Green decision and applied for a planning application to test and evaluate shales for 3 years at Boscal Bridge, West Sussex.

xviii) Air pollution: green- house and O3 depleting gases, fugitive emissions of CH4, radon and volatile organic compounds (VOCs).

Fugitive CH4 from leaks, venting, flow back fracking fluid and drilling on site is 25x more potent a greenhouse gas than CO2.

xviii) The current UK Government is committed to fracking.

Announcement of 28/07/14

Airborne C6H6 H2S, HCHCO detected at some US pads.

Response to Climate Change (RTCC) 30/10/14


With the best regulation. pollution is still inevitable.

UN Environment



xix) Soil / ground pollution on pads and from spillage etc is deleterious to agriculture.

Policy article of the BKB eV

Bavaria, referring to the Oberpfalz.



xx) Noise generated on site, e.g. low frequency noise from machinery.

Inconsistent with Environmental Noise (England & Wales) Regulations 2006; Environmental Noise Directive 2002/49 EC (END); Control of Pollution Act 1974 - Part III



xxi) Process / Wastewater: large quantities of toxic process/ wastewater will be discharged off site and require stringent, transparent management plans.

Inconsistency with EU water legislation and the precautionary


xxi) In the UK toxic process/wastewater will not be held on site - according to an official statement – as it currently is in the USA.


xxii) Groundwater: “…unless proven that there is no risk to groundwater” fracking should not proceed.

Water Framework Directive.

EC Drinking Water Directive.

xxii) The current UK Government is committed to fracking.

EU Directives do not always take precedence over national laws.

Risk of ground- water depletion:


e.g. 9 - 8 million litres H2O required to drill and fracture from 1 lateral.

Groundwater Protection Council (US) Report, 2009


e.g.157.5 million litres of water are extracted per fracking well in Michigan

The Center for Michigan, Michigan, USA


The German Environment Minister stopped frack- ing in Bavaria by using water rights / laws (11/08/14

Allgauer Anzeigeblatt)

Bavarian Ministry for Business will give licences for test drilling on 2600 km2 of the   Oberpfalz.

July 2014

e.g. 140 000 -150 000 gallons of water are extracted per day per frack

California Food & Water Watch (8/14)


Risk of ground- water pollution:


e.g. 3bn gallons of wastewater from >9 pads were injected into the aquifer under central California leading to an aquifer contaminated with As, Tl and other substances.

Inconsistent with state law

(California State Water Resources Board 7/10/14)

and US

Drinking Water Act.


xxiii) Well water: risk of contamination by fracking activities.

Evidence from conventional mining activities the world over and from some US fracking sites.

xxiii) Faulty and badly maintained wells were responsible.

Well barrier failure is likely to occur in a small number of cases.

Energy companies engaged in fracking.


xxiv) Drinking water and the aquifer:

Risk of drinking water contamination and flammable water as recorded in the USA.

These and other risks of fracking are inconsistent with the

EC Drinking Water Directive/

Regulations 98/83/EC.

UK Drinking Water Quality.

COSHH 2002.

ACOP-L8 and

H&SG 274.

1999 Australian food legislation defines tap water as food.

Long-term monitoring data for active and abandoned well sites should be in the public domain. At present they are not. (ReFINE)

xxiv) The fractures are not tall enough to reach aquifers / water tables above the laterals. (ReFINE)

Older shale beds are deeper than the aquifer (and water table) that is usually situated in the Cretaceous beds, or even younger rocks.

1% chance of a stimulated hydraulic fracture propagating upwards of more than 350m. The maximum recorded so far is less than 600m. (Durham Energy Institute et. al.)

xxv) Uncalculated risk of polluting lakes, ponds, rivers, streams and inshore waters

e.g. River Ribble, aquatic nature reserves, and Morecombe Bay in Lancashire.

xxv) The current UK Government is committed to fracking.

Announcement of the 28/07/14

xxvi) Health & Safety hazards: flaring, chemicals, radon, fires, explosions.

All these hazards have occurred at conventional gas and oil drilling pads.

xxvi) In the UK there will be none of the wasteful flaring of CH4 on site that takes place in the USA.


xxvii) There is very little evidence of no risk from radiation and pollution from fracking.

“the British Medical Journal”, June 2014

xxvii) Radiation and pollution from fracking present a low risk.

“…Public Health England anticipates a low risk to public health from direct releases of chemicals and radioactive material if shale gas extraction is properly operated and regulated.”

xxviii) Drilling fracking wells and laterals will generate large volumes of toxic spoil.

Every mining activity in the world generates spoil, acids and heavy metals.

xxviii) Spoil from fracking is kept underground in the USA.


xxix) If fracking chemicals are not divulged, members of the emergency services and COSHH compliance officers will be at risk and environmental groups will be neutered.        

Fracking chemicals are not divulged in the USA and vary according to the energy company concerned (for reasons of confidentiality or competitive advantage).

xxix) In the UK the chemicals added to the huge quantities of water and abrasive particles will be divulged - according to official statements.


Exxon-Mobil has developed a fracking fluid that the EU would permit – Butyldiglycol plus Cholinechloride

Both are ingredients of common household products.

xxx) Induced seismicity is a risk.

It cannot be ruled out. Eg

a propagated earth tremor was recorded in 2011 near Blackpool.

xxx) Induced seismicity caused by mining, reservoir impoundment and hydraulic fracturing have been relatively benign

on the superficial geology.

ReFINE and the Environment Agency

xxxi) The hard rock geology above laterals could be destabilised and cause subsidence and seismic activity.

Evidence of disturbance to the superficial geology was reported in all cases of traditional mining activity - worldwide.  

xxxi) The bedrock above is strong enough to self-support.

The vertical and lateral drills are circular, which is structurally a strong shape.


It is unclear how close to fault lines that fracking can be carried out safely.



There is little data on hard rock and superficial geological disturbance.



The gas industry is famously capital-intensive, not labour intensive.

Unconventional oil and gas exploitation

would not offer or create the diversity, quantity or quality of sustainable work and activity that is possible in the energy conservation / efficiency and renewable energy sectors.

Locally, job creation will be negligible (eg in Lancashire). In the UK the engineers required are in short supply and the lead time for training them is 5 years. Offshore and chemical industry skills are already in short supply.

xxxii) At ‘peak’ production and including supply chain activities, the fracking industry can be directly and indirectly be the source of 64 000 jobs. (Ernst & Young study, April 2014)

the Ernst & Young study is

based on the IoD peak activity scenario described in their report.

xxxiii) Energy efficiency, conservation and renewable energy sources address the issues of security of supply and foreign currency / exchange issues.

In previous crises e.g. in1939-45, homeland economies and efficiencies achieved a great deal.

xxxiii) Fracking helps to address the problem of security of supply viz

embargos, sabotage, terrorism, Putinesque valve control and the need to import any natural gas.

IoD estimates that to reduce gas imports from Russia or North Africa by 50% by 2030 would require 100 pads with about 4000 vertical wells in order extract the required volume of CH4.

Any export of shale gas contradicts the security of supply argument.

The USA plans to export some liquefied shale gas.


xxxiv) The extraction of more fossil fuel resources contradicts any policy to reduce fossil fuel use and CO2 emissions.

The UK is a signatory to the Non-fossil Fuel Obligation.

xxxiv) By extracting shale gas the current UK Government is committed to reducing CO2 emissions.


U of Cambridge Sustainability Institute’s conference on “Rewiring the Economy” (02/07/15)

“We will need a different kind of economy to get there.” “It will require us to find different ways of doing things.”

Prince Charles



“The Guardian” newspaper’s “Keep it in the Ground” on-line campaign.

“…welcomed and commended...”

Prince Charles



The movement for divestment in fossil fuels.

Now supported by two of the world’s biggest foundations: the Wellcome and the Gates.


xxxv) Little attention to trans-generational issues such as climate change, waste heat and CO2 emissions. No attention to the development of non-fossil fuels and ‘renewables’.


xxxv) Attention is paid to the trans-generational issue by securing future supplies of fossil gas.


xxxvi) The precautionary principle is not being observed.


xxxvi) The precautionary principle has yet to be enforced.


xxxvii) “Unacceptable adverse impacts” need to be taken into account

National Guidance (paragraph 144)

xxxvii) The current UK Government is committed to fracking.

Announcement of 28/07/14

xxxviii) The Department of Energy & Climate Change’s “Public Attitudes Tracker” found that public endorsement for fracking fell 5% from 29% (March 2014).

The latest government finding is that 74% of interviewees have some awareness of shale gas, 24% support fracking and 24% oppose it.

xxxviii) 57% of 4000 interviewees support shale gas extraction and 16% oppose it.

Survey by Populus, commissioned by UKOOG, 2014.

xxxix) Numerous local or national demonstrations, petitions, pickets etc in opposition to fracking took place in the UK during 2013 and 2014.

e.g. by groups in Dorset, Lancashire, Somerset and Sussex and by Friends of the Earth and Greenpeace.

xxxix) The current UK Government is committed to fracking.

Announcement of 28/07/14.


Industry and the Government were absent from almost all national debates on fracking.

xxxx) Unknown unknowns: fracking will leave little territory in crowded areas of the planet - unchanged by man - for future research, to serve as controls or for problem solving.

Many ‘untouched’ areas of the earth have intrinsic value and revealed important information of immense use value. Many ‘pristine’ areas have served as controls.  

xxxiv) This should not stop the quest for more shale gas in order to meet today’s needs because everyone will be better off in the future anyway.


Note:   Hydraulic fracturing is not strictly the same as fracking, which requires drilling down to a depth of around 1000-5000m, several horizontal drills (laterals) per vertical drill, vast amounts of water under pressure, unspecified chemicals and sand or ceramic shot. Neither is it coal bed gasification nor coal/oil gasification.

Hydraulic fracturing takes place in the open cast stone quarries of Portland, Dorset, where its physical impact on the surface is noticeable, bedrock is drilled and the non-compressibility of water is harnessed.

In an open market any energy company is invited to apply for a licence to frack under half of the area of the UK, including,

under special circumstances, the national parks and AONBs.

Announcement of 28/07/14




                                             Revised November 2014

                                             Revised December 2014

                                             Revised January 2015

                                             Revised July 2015


                                Nicolas Holliman