I got a very promt reply from Bristol water, who say they are aware of the implications of shale gas extraction, but expect the Environemtn agency tand local authorities to contact them at an early stage of a planning application for drilling. Though not however statutory consultees, they feel they should be!!
They sent me the follwoing, which can also be found on the 'Water UK' website. Alex
POLICY POSITION – Risks to water supplies posed by gas shale
extraction
Introduction
There has been much publicity recently over the potential reserves of shale gas in the UK.
Whilst this is still in exploratory stages in the UK the technique used for extraction of shale
gas (known as “fracking” or hydraulic fracturing) has been associated with risks to drinking
water sources in the US. Trial extractions have taken place in deposits in the Fylde in
Lancashire but the Department of Energy and Climate Change (DECC) report shows
potential development sites across large parts of England and Wales.
There is a mixed evidence base on the magnitude of the risks involved but nonetheless there
is some acceptance that they do exist. Although water companies would not wish to hinder
economic development there is a view that the risks to water supplies (and in particular
drinking water supplies) need to be addressed.
Risks
The primary risk of concern to water companies is that associated with contamination of the
drinking water aquifers that overlie shale gas reserves as a result of the “fracking” process
allowing gases, such as methane, to permeate into drinking water sources from previously
confined rocks.
This is associated with the design and construction of the boreholes sunk to allow shale gas
extraction. In the UK, the design and construction of shale gas extraction boreholes is
assessed by the HSE through specific regulatory controls, which among other things require
verification of the design by an independent third party (DECC, 2011).
In addition contamination caused by chemicals used in the process entering the drinking
water aquifer either via fractures caused by the process or potentially by existing pathways
should also be considered a risk.
In addition there are a number of indirect risks associated with shale gas extraction that
include:
· Discharge of contaminated effluents recovered from the “fracking” process to surface
drains, sewers or the environment.
· Damage to assets associated with any ensuing seismic activity that could cause
damage to water mains and sewerage infrastructure.
Regulatory framework
There is already a regulatory framework in place before shale gas extraction can commence
in the UK. A UK petroleum exploration and development licence (PEDL) is required along
with drilling consents and planning permission. The EA (or SEPA in Scotland) and the HSE
are consulted on environmental risk and safety risks respectively but the details on what goes
into these risk assessments are not fully understood by Water UK at this present time.
Under current planning arrangements inclusion of water companies in the process is not
required but, as has been demonstrated in recent trial sites, such liaison can provide helpful
information to both the water company (in terms of updating risk assessments for their
Drinking Water Safety Plans) and to the gas extractor.
Proposals for change
Water UK would urge government to consider the introduction of legislation to ensure that
water undertakers in the UK are statutory consultees, in addition to the environmental
agencies, on proposed shale gas extraction sites and that the protection of drinking water
sources is considered within this framework as a priority.
There should also be full disclosure of the chemical composition of the fluids used during the
extraction process on a site-specific basis so that the water industry can consider risks to
drinking water sources.
Finally, more visibility of the safety measures being put in place from the planning stage to
mitigate against any risks identified that may either directly contaminate drinking water
aquifers or indirectly provide pathways for contaminants that already exist in the
environment. Consideration should be given to the wider potential safety issues rather than
just the borehole design risk, for example, whether seismic activity associated with the shale
gas extraction could damage utility infrastructure.
European context
Water UK also endorses the European Commission’s intention to produce common European
standards for the exploitation of shale gas provided that any technical extraction frameworks
are supported by appropriate environmental standards that pay due attention to protection of
drinking water.
In addition the Water Framework Directive and its daughter directive for groundwater
provides for Water Protection Zones (WPZs). These provide a regulatory mechanism by
which Member States can address the potential for any pollution or hydro-morphological
damage, which could include any caused as a result of “fracking”.
Jim Marshall
Business and Policy Adviser
Water UK
Version 1 - Final – 21 November 2011
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