The question of set-back distances

The following letter from a local doctor is an extremely good summary of the issues relating to fracking sites and set back distances. We trust that the officers at our County Council will pay it due regard.


Planning Officer, Lancashire County Council                                                                                 25 April 2018

Dear Mr Mullaney

Re: Hydraulic Fracturing: Public Health & Safety and Residential Setback Distance:

A North Yorkshire Planning Inspector has recently stipulated a local ad hoc 500m minimum residential separation distance from fracking sites, on the grounds of public health and safety. This decision has understandably led to calls for appropriate formal national setback regulations. The issue is of particular concern for those Lancashire residents living at 350m, closely adjacent to the Cuadrilla site on Preston New Road, Little Plumpton, who may soon be the first in England to be impacted by an active shale gas site.1

The recent historical context is a consequence of the controversial 2014 Public Health England Review.2 The government was then, in effect, granted written permission from a ‘trusted medical authority’, to proceed with fracking. This document concluded that fracking presented a ‘low risk’ to public health, even for this densely populated country. However, the PHE Review was widely considered by experts to be of questionable credibility and was severely criticised at the time of publication.3, 4. One contemporaneous BMJ editorial stated that the correct conclusion that Public Health England should have drawn, was that the public health impacts remained undetermined and that more environmental and public health studies were needed. ‘More attention should have been paid to drilling in areas that are densely populated. Studies suggest that health risks are modified by geographical distance of residences from active shale gas extraction. Recent evidence suggests a higher prevalence of some adverse birth outcomes for those living in closer proximity.’ 5. It is notable that the 2014 PHE Review made no recommendation for any regulation of minimum residential setback distance. This glaring omission is like a rather large chicken which is belatedly returning home to roost.

Fast forward to 2018, and there is now abundant and accumulating evidence from the USA, of the potential harm, not only from the release of toxic volatile organic chemicals,6,7,8 but also from breathing in the diesel exhaust micro-particle PM 2.5 emissions from the numerous on-site diesel compressors and associated heavy diesel truck traffic, which are all probable significant contributory factors to the harmful impacts on health from fracking. In general, each 10-µg/m3 elevation in combustion related fine particulate air pollution may be associated with approximately a 4%, 6%, and 8% increased risk of all-cause, cardiopulmonary, and lung cancer mortality, respectively. 9.

Several studies have also indicated that proximity to the industrial activity associated with fracking sites is a determinant of harm, such as exacerbation of asthma,10 increased acute cardiology and neurology admissions to hospital 11 increased dermatological and upper respiratory symptoms 12 low birth weight 13 and preterm births.14

In April 2017 it was determined that a 300m setback originally proposed in Maryland would not protect residents from unacceptable noise levels.15 Maryland, like New York State, has now quite sensibly banned fracking. There is also concerning research on harmful levels of carcinogenic respirable crystalline silica (RCS) dust from fracking sand in sites16 and this may also impact close residents. Many recent air samples from these sites have demonstrated elevated RCS dust above the acceptable occupational exposure limits.17

Based on historical emergency evacuations in the USA and thermal modelling, people within low setback distances from fracking sites are potentially vulnerable to thermal injury during a well blowout/fire/explosion. According to air measurements and vapour dispersion modelling, the same populations are susceptible to carcinogenic benzene vapour and toxic hydrogen sulphide gas exposures above health-based risk levels. 18

I entirely agree with the North Yorkshire Planning Inspector that I would prefer my family to live more than 500m from a fracking site, rather than at 350m, which is currently the case for some extremely anxious Lancashire residents living adjacent to the site at Preston New Road, Little Plumpton. Distance is not an absolute measure of protection. Unfortunately, there is currently no defined setback distance that assures safety.

The evidence from peer-reviewed papers suggests that fracking in England may not be effectively regulated. It is highly likely that some regulatory agencies may lack the staffing, knowledge of recent research and resources necessary to monitor and enforce effective regulation of the industry.19

However, there cannot be less stringent public health and safety regulations for fracking close to Lancashire residents than those stipulated for North Yorkshire or elsewhere. Nor should there be arbitrary and variable ad hoc decisions made by local planning officials without an evidence base.

It seems that the government is determined, at all costs, to force fracking on our population. There is recent evidence for negative health effects of in utero exposure to fracking sites, with the largest health impacts, such as low birth-weight seen for in utero exposure within 1 km of the drill-sites13. Upper respiratory symptoms and skin conditions were also reported to be increased within 1km of fracking sites.12

Prohibiting the development of an industry that is potentially so harmful to the health of local residents, that has doubtful economic viability and runs counter to the direction of the necessary energy transition, should be regarded as a reasoned and sensible decision.

However, If the shale-gas industry is forced on Lancashire residents then the precautionary principle must apply and there should be an evidence-based attempt to formally regulate to reduce the potential adverse health impacts on those living close to sites, particularly for the most vulnerable: pregnant women, children, the chronically ill and the elderly.

As the bare minimum precautionary measure, fracking must not be allowed to take place within 1km from any dwelling.

I look forward to receiving your response.

Yours sincerely,

FP Rugman

Dr Francis Paul Rugman MB ChB, MSc (Distinction) FRC Path, FRCP (London).

(Co-author, Health & Fracking: The impacts and opportunity costs. Medact, London, 2015,

and retired Consultant Haematologist) 

References:

  1. Hayhurst R Drill or Drop https://drillordrop.com/2018/04/13/shale-gas-companies-     threaten-legal-challenge-over-minimum-gap-between-homes-and-fracking-sites/#more-62864
  2. Kibble A et al, Public Health England Review, 2014, Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of the Shale Gas ExtractionProcess.https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/332837/PHE-CRCE-009_3-7-14.pdf
  3. Stott R et al Public Health England’s draft report on shale gas extraction BMJ 2014;348:g2728
  4. Gornall J. Public Health England’s troubled trail BMJ 2015;351:h5826
  5. Law A et al Editorial : Public Health England’s draft report on shale gas extraction. Mistaking best practices for actual practices. BMJ2014; 348 doi: https://doi.org/10.1136/bmj.g2728
  6. McCoy D, Saunders P, Rugman F, Hill M, Wood R, Health & Fracking: The impacts and opportunity costs. Medact, London, 2015
  7. Middleton J, Government gives green light for fracking – and for serious public health and environmental risks Statement of UK Faculty of Public Health.http://www.fph.org.uk/government_gives_green_light_for_fracking_–_and_for_serious_public_health_and_environmental_risks

    last modified: 27/10/2016)

  8. Watterson A & Dinan W Public Health and Unconventional Oil and Gas Extraction Including Fracking: Global Lessons from a Scottish Government Review J. Environ. Res. Public Health 2018, 15(4), 675; doi:10.3390/ijerph15040675
  9. Pope CA et al ‘Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution’ 2002;287(9):1132-1141
  10. Rasmussen SG et al Asthma Exacerbations and Unconventional Natural Gas Development in the Marcellus Shale JAMA Intern Med. 2016 Sep 1; 176(9): 1334–1343.
  11. Jemielita T et al. (2015) Unconventional Gas and Oil Drilling Is Associated with Increased Hospital Utilization Rates. PLoS ONE 10(7): e0131093. pmid:26176544
  12. Rabinowitz PM Proximity to Natural Gas Wells and Reported Health Status: Results of a Household Survey in Washington County, Pennsylvania Environ Health Perspect. 2015 Jan; 123(1): 21–26.
  13. Currie J et al Hydraulic fracturing and infant health: new evidence from Pennsylvania.  Science Advances. Published online December 13, 2017. doi:10.1126/sciadv.1603021
  14. Casey JA Unconventional natural gas development and birth outcomes in Pennsylvania, USA Epidemiology. 2016 Mar; 27(2): 163–172.
  15. Boyle MD et al A pilot study to assess residential noise exposure near natural gas compressor stations. PLoS ONE 12(4): e0174310. https://doi.org/ 1371/journal.pone.0174310
  16. Esswein EJ Occupational Exposures to Respirable Crystalline Silica During Hydraulic Fracturing Journal of Occupational and Environmental Hygiene 10, 2013 (7) 347-356
  17. United States Dept of Labor: Occupational Safety and Health Administration: https://www.osha.gov/dts/hazardalerts/hydraulic_frac_hazard_alert.html
  18. Haley M et al, Adequacy of Current State Setbacks for Directional High-Volume Hydraulic Fracturing in the Marcellus, Barnett, and Niobrara Shale Plays Environ Health Perspect DOI: 10.1289/ehp.1510547
  19. Watterson A & Dinan W ‘Dash for Gas’ A Rapid Evidence Assessment of Fracking for Shale Gas, Regulation, and Public Health New Solutions: A Journal of Environmental Health and Occupational Health Policy. 2017, Vol. 27(1) 68–91

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