Actions to take

Submissions need to be received by 20th March 2019

This is an application for Cuadrilla to vary their Environmental Permit.

We have identified the following key areas of concern. You could refer to all or just a couple if you feel it appropriate. Feedback need not be long but does need to refer to specifics of the document rather than just a general concern about fracking.

1) This is “permission creep”.

On a basic level, the company are seeking to alter the chemical make-up of the fracking fluid, and make changes to the monitoring. This will be the 9th version of the Environmental permit. How many more will we expect.

2) Caudrilla are using misleading terminology.

By not using the dictionary definition of “non-hazardous” they give the appearance that the substances they propose to add to the fracking fluid are not harmful. In fact some are highly toxic and very damaging to human, aquatic and animal health.

The Environment Agency should in our opinion challenge the use of technical terminology as this potentially off putting to non- specialists. As residents we have the right to be provided with clear and accessible information.

Public Consultation is a statutory duty of the Environment Agency. The UK Government guidance on consultations is that they should “use plain English and avoid acronyms” and the Environment Agency’s own guidance to applicants states the non-technical summary supplied with the application should use “non-technical language as much as possible, avoiding technical terms, detailed data and scientific discussion”.

However, in the Non-technical Summary, technical terminology from the Environmental Permitting (England and Wales) Regulations 2016 (EPR 2016) is used. Under EPR 2016, the term non-hazardous does not take its common meanings, it merely means that such a pollutant does not meet the toxic, persistent and bio-accumulation criteria for a hazardous substance.

In short, this means that a non-hazardous pollutant can be extremely harmful to both public health and the environment.

By not stating that the meaning of the term non-hazardous is taken from the Environmental Permitting Regulations rather than its dictionary definition, Cuadrilla has deliberately sought to mislead the public and the media over the classification of the proposed fracking chemicals.

3) Inconsistencies in the Risk Assessment and Waste Management Plan.

It is proposed that glutaraldehyde (1,5-pentanedial) is used a preservative at concentrations up to 1 litre per cubic metre of fracking fluid. Glutaraldehyde is acutely toxic to fish and is also highly toxic to aquatic algae.

No account of toxicity is taken in the revised Environmental Risk Assessment (HSE-Permit-INS-PNR-005). This would again lead a member of the public to assume that there was no risk of harm to the environment.
There is no mention of glutaraldehyde disposal in the Waste Management Plan (HSE-Permit
PNR-006), where it is again described as “non-hazardous to groundwater”. However, it is toxic in sewage treatment plants yet there is no statement on disposal of hydraulic fracturing water containing glutaraldehyde. Which raises questions about the waste audit and disposal methods.
In short, insufficient information has been provided on chemical classification to allow the public to reach an informed conclusion on the proposed additives.

4) Changes to the monitoring of air and ground water.

With regard to the monitoring of ambient air and ground water, Cuadrilla have claimed that a “significant body of results have been collected since monitoring commenced during summer 2014”.

However, the amount of data generated during fracking activities is extremely limited with “just two out of the forty one stages installed along the horizontal section fractured fully as designed, and less than 14 per cent of the sand we had planned to inject into the shale rock put in place” (Cuadrilla News 06/02/19).

To use fracking experience as a basis for changing the site monitoring regime is highly premature.

5) Insufficient information about the changes to the monitoring.

In relation to air quality, Cuadrilla have proposed “a much enhanced continuous monitoring station has been installed which provides much higher temporal resolution monitoring of key target pollutants”.

No information is provided to the public on its location and its sensitivity to wind direction.

The recent BGS report on methane monitoring indicated that monitoring from a single location is highly dependent on the prevailing wind. As such, Cuadrilla have failed to provide sufficient information for a member of the public to reach an informed conclusion on air monitoring.

In the absence of sufficient information on the proposed variation, this consultation cannot be considered fair or open.

6) The use of mains water to dilute flow back waste for reuse.

In The Waste Management Plan para 2.3.2 p15 Cuadrilla state they will use mains water to dilute flow back, if solids exceed tolerances and are too high. However, the flow back will likely contain some radioactivity and chemicals. Is it Best Available Technique (BAT) to use mains (domestic) water to do this?

7) The volume of Harmful chemicals. For ONE well.

As well as the biocide glutaraldehyde there are an additional 33 chemicals listed in appendix f that Cuadrilla would like to add to the fluid. They are listed as Non Hazardous but as mentioned in comment 1, the definition is not as simple as it may sound.

Appendix f lists the names and concentration of the chemicals but does not show the total quantity that will be used in fracking operations. Based on the volume of water required to frack 45 stages, each using up to 765 m3 many tonnes of additives will be required.

Take glutaraldehyde for example, at a concentration of 0.1 litres per m3 x the number of fracking stages x the volume of water permitted as stated in the Hydraulic Fracture plan = to 3,443 litres =3.6 metric tonnes. Methanol concentration is up to 10 litres per m3 therefore its usage could be up to 344,250 litres = 273 metric tonnes.

Insufficient detail is provided in our opinion and is deliberately vague to create the impression the chemical concentrations are smaller and less harmful.

While not every chemical has been investigated here, we wouldn’t be about to drink any of them. Despite industry claims these are “food grade” there is nothing wholesome about them.

The Daily Telegraph revealed on 11 February that the government has suppressed a report which forecasts a dismal future for fracking in the UK, while government ministers have continued to quote reports which now appear to be hugely exaggerated.

Please write to your MP demanding that he or she insists on the immediate publication of this report.

See “Contact your local political representatives” below for details of how to contact your MP.

Sign this petition

“Make Hydraulic Fracturing (Fracking) illegal in the UK”

… we all get petition fatigue but this one is important so please sign and share!

https://petition.parliament.uk/petitions/200307

And this petition too!

“Support Kirby Misperton Protection Camp”

… this one is in response to the astroturfers’ cynical attempt to use 38 Degrees against fracking protest – they really do need teaching a lesson so please sign and share 🙂

https://you.38degrees.org.uk/petitions/support-kirby-misperton-protection-camp

Contact your local press

…if you are not happy with their coverage of the fracking debate. The more letters they receive from locals the sooner they will realise that their commercial interest lies as much with those who buy their papers as those who advertise in them. Details below:

Click to see more...

• • • Blackpool Gazette – letters@blackpoolgazette.co.uk
    • Lancashire Evening Post – lepforum@lep.co.uk
    • Lancashire Telegraph – lt_letters@nqnw.co.uk
    • Lytham St Annes Express – news@lsaexpress.co.uk

If you have any further contact details we should add here please let us know by email at welcome@frackfreelancashire.org