Sir Humphrey’s Role in Somerset Fracking Obfuscation

It has recently been reported in the local press that the Chew Valley, Bath and Mendip will remain free from fracking for Shale Gas. This is based on an announcement by Ben Howlett MP (Bath) following a meeting that he and James Heappey MP (Wells) had with the responsible Secretary of State the Rt Hon Andrea Leadsom. Ms Leadsom wrote to Mr Howlett saying that “Bath and the surrounding areas are not located in the British Geological Survey’s ‘shale prospective area’.

NB – Mr Jacob Rees-Mogg doesn’t seem to have been invited to Ms Leadsom’s tearoom surgery.

Ms Leadsom’s letter to Mr Howlett is reproduced on his web site and is reproduced below in blue italic.

Mr Howlett commented “As the Minister, Andrea Leadsom, said in her response to me I regret that this situation has been unclear both to me and my constituents and am relieved and reassured by her response“.

However, Ms Leadsom seems to have persuaded Sir Humphrey Appleby GCBKBEMVOMA (Oxon), (a “master of obfuscation”) to draft the letter for her as it is simultaneously both truthful and utterly disingenuous. Let’s see what Sir Humphrey had to say and whether what was unclear is now clear and whether we can also feel “relieved and reassured”.

Sir HumphThank you for attending my tearoom surgery recently. I hope you found our discussion about the shale reserves in Bath and the Mendip Hills helpful and thank you for raising this matter with me.

Not a good start. Why was the conversation about ‘shale reserves’ rather than the ‘coalbed methane resources’ that the gas companies have been searching for in this area for the past 20+ years?

These companies (include Pendle Petroleum in 1985, Union Texas Petroleum Inc in 1995, GeoMet Inc in 2000 and UK Methane in 2014) were all looking for CBM according to the licence applications and relinquishment reports filed in Sir Humph’s filing cabinet.  Considering that these companies all delivered their reports to Sir Humph’s Department saying they were looking for CBM it is odd he didn’t bother have a peek to find out and so save embarresment.

Also Shale Gas ‘reserves’ (what can be technical and economically extracted) certainly don’t exist because the economic value of any Shale Gas in the area have certainly not be calculated. The dextrous use of the word ‘reserve’ rather than ‘resource’ is a careful double blind to hide behind. So they were discussing something that hasn’t been calculated (reserves) for something that isn’t of primary interest in the area (Shale Gas).  Of course Sir Humph knows all about this because his Department has published a note on this very point in order to prevent, rather than create, confusion – Resources vs Reserves: What do estimates of shale gas mean?

And what about the tearoom cake reserves?

Sir HumphBath and the surrounding areas are not located in a ‘shale prospective area’ according to shale resource estimates by the British Geological Survey.

So what? The companies are not primarily looking for Shale Gas. Opps – there is the word ‘resource’ instead of ‘reserve’. This is because BGS has got a map of Shale Gas resources but it hasn’t got a map of Shale Gas reserves – because it hasn’t calculated any.

In addition, Bath (as a World Heritage sire) and the Mendip Hills (as an Area of Outstanding Natural Beauty) are afforded the highest level of protection within our planning system.

The highest level of protection is afforded to hydraulic fracturing for Shale Gas at the exclusion of CBM.  The definition of “associated hydraulic fracturing” and related protection in the Infrastructure Act 2015 is specific to shale and stuff “encased in shale”, which does not include coal – as confirmed in writing to us by Sir Hump’s very own Department.

Sir HumphIn addition, there are currently no active Petroleum Exploration and Development Licenses (PEDLs) in the Bath area. In 2008 the Government issues PEDLs in Bath and North East Somerset, as part of the 13th round licences. In July 2014, three of the PEDL licences in this area were relinquished by the licence holders and another licence was extended for further year until July 2015 but has since been relinquished.

PEDL 227 covering the most prospective area for CBM was not available in the 14th Licensing Round because the previous licence hadn’t been relinquished in time. There is nothing stopping the Bath and Mendip area being licensed again in the 15th Licensing Round if anyone were interested – as it has been in the past. Sir Humph obviously hasn’t looked at the 2008 PEDL licence applications or the relinquishment reports otherwise he probably wouldn’t have even drawn attention to them considering what they contain – a plan to comprehensively extract the entire hydrocarbon resource in the area using a combination of fracking, mining and underground coal gasification.

Sir Humph:  “Even if there were shale gas reserves, the recent announcements on fracking would make obtaining permissions for drilling at the surface extremely unlikely.

Note the use of the word ‘reserves’ again – there aren’t any Shale Gas ‘reserves’ because they haven’t been calculated and nor have the ‘resources’ from which you would calculate the ‘reserves’.

What has been estimated by GeoMet Inc and others is the CBM ‘gas in place’ – i.e. the CBM ‘resource’ from which you might calculate a CBM reserve.

The recent announcement on fracking don’t apply to CBM anyway.

Sir Humph: “Thirteen blocks located to the west and east of Somerset are being considered as part of the 14th licensing round, subject to the Habitats Regulations Assessment consultation. A map of licences being considered in the 14th licensing round can be found here.

Ah, right. Thirteen blocks in west and east Somerset are being considered as part of the 14th Licensing Round even though they are also not in the BGS shale gas prospective area either. Err, so they must be being licensed for something else other than shale gas, something like CBM and Shale (Oil) – as stated in Sir Hump’s list of licences.  So, not being in the BGS shale gas prospective zone is a good thing in Bath, but not in any way relevant in Weston, Frome or the Forest of Dean – based on the same criteria of not being in the BGS shale gas prospective zone (Ed. Has Sir Humph got that right, it sounds like nonsense?).

Sir Humph’s Department has actually licensed 1,200 square kilometres in the Forest of Dean (CBM), Wiltshire (CBM) and the Somerset coast (Shale but not Shale Gas) that is not in the BGS Shale Gas prospective area. So the talk about not being in the BGS shale gas prospective area and the careful use of the words ‘reserve’ and ‘resource’ is just a meaningless ruse that only Sir Humph could articulate to make everything sound OK?

Sir Humph also forgot to mention that the Habitats Regulations Assessment consultation had three possible outcomes all of which resulted in the licenses being issued, no matter how sensitive the area or the consultation response.

Sir Humph: “PEDLs do not give permission for specific operations, such as drilling. Rather, they grant exclusivity to licensees, in relation to hydrocarbon exploration and extraction (including for shale gas but also for other forms), within a defined area. Any licensee looking to explore for hydrocarbons would have to apply for planning permission and various permits in advance of any drilling.

Sir Humph is fixated on only articulating “Shale Gas” at the exclusion of the “other forms” such as CBM and even Underground Coal Gasification. Why would Sir Humph not want to say CBM or “Underground Coal Gasification”?

Sir Humph: “I am grateful for the opportunity to discuss this matter with you and with James Heappey MP recently, and hope that this brings assurance that there are no known shale reserves in your area and currently no plans to explore for any.

Phew, so now we know that there are no shale ‘reserves’ in the area (the ones that haven’t been calculated, so how could there be any?). But what about the CBM ‘resources’ – the ones that have been calculated and the ones that UK Methane recently said in their relinquishment report (filed in Sir Humph’s office) were “probably prospective” and which any company can apply for an exploration licence for the next time around.

Sir Humph: “I regret that this situation has in the past been unclear to some of your constituents, and I hope you can take the necessary steps to alleviate their concerns.

Glad that Sir Humph has cleared up that confusing mess by providing a carefully worded explanation of what isn’t significant in this area. Pity he didn’t mention anything that was of primary interest even if it isn’t covered by recent reassuring legislation.

Bernard: “But surely the citizens of a democracy have a right to know“.

Sir Humph: “No. They have a right to be ignorant. Knowledge only means complicity in guilt; ignorance has a certain dignity“.

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North East Somerset Election CBM-Frack-Info-Pack

Local Resources

In the interest of promoting an informed debate on unconventional gas exploration and development in Somerset here are some local resources, including new maps which are based entirely on open information from the UK Government. Hopefully these resources will help to inform the local political discourse in the lead up to the election.

Briefing Notes & Reports

Web Sites

Maps

The first map shows all of BANES and the area identified as prospective by US coalbed methane specialists GeoMet Inc. Note that their assessment of coalbed methane resources didn’t cover all of BANES  and information is missing to the south of the City of Bath. As a World Heritage Site the City of Bath is now off-limits to gas exploration. Areas of Outstanding Natural Beauty are also off-limits, although drilling underneath them from outside may not be. The Mendip AONB is shown on the map. Fracking has also been excluded from groundwater protection zones, although the government hasn’t yet decided which ones. The maps shows protection zones 1 and 2 which relate to areas where surface pollution could enter aquifers within 50 days and 400 days respectively. Lastly the map illustrates a hypothetical grid of gas wells within the prospective area, according to GeoMet’s specification of one well every 32 ha or 566m, which matches the government’s Planning Practice Guidance on CBM Well Spacing. GeoMet propose drilling at depths between 152m and 1524m which also pretty much matches the government’s Planning Practice Guidance on CBM Drilling Depth. When questioned about the minimum drilling depth the current licence holder, UK Methane, obfuscated. The Infrastructure Act 2015 doesn’t seem to cover CBM so the 1,000m trespass threshold in the Act doesn’t apply – the coal seams can already be accessed by virtue of the Coal Industry Act 1994. Currently only PELD 227 is extant and is held by UK Methane and Eden Energy. The rest of BANES is up for grabs again by the gas companies in the 14th on-shore Licensing Round. DECC will not tell us where companies have expressed an interest in despite a Freedom of Information request and appeal.

BANES GeoMet Coalbed Methane

BANES GeoMet Coalbed Methane Prospective Area and Groundwater Protection Zones

Click on the map to open a detailed A3 PDF file. The next map shows the detail of PEDL-227 held by UK Methane. This map includes the CBM prospective area, as identified by GeoMet Inc, the groundwater protection zones, the grid of hypothetical wells and entrances of old mine workings. Note the avoidance of mine workings by GeoMet.

PEDL227-GeoMet-GWPZ

PEDL 227 GeoMet CBM Prospective Area and Groundwater Protection Zones

Click on the map to open a detailed A3 PDF file. The last map also shows PEDL-227 and the CBM prospective area but this time in relation to the surface water catchments which include a portion of the Chew Valley, the Cam Brook Valley, the Somer and Well Brook Valley and the Mells Brook Valley.

PEDL227-GeoMet-Catchments

PEDL 227 GeoMet CBM Prospective Area and Surface Water Catchments

Click on the map to open a detailed A3 PDF file.

Fracking & the Weights and Measures Act 1824

Mr Jacob Rees-Mogg MP has recently replied to constituents who expressed their concern about fracking in relation to the Infrastructure Bill. The Bill has now passed into law as the Infrastructure Act 2015 after MP’s were given just one hour to debate the Lords’ revised and watered down amendments.

Mr Rees-Mogg jumped the gun by replying before the Lords’ amendments were approved by Parliament and stated that “The Government made a number of alterations to the Bill such as declaring an outright ban on fracking in National Parks and, of particular relevance to North East Somerset, Areas of Outstanding Natural Beauty” – whereas the Lords have watered this down to allow horizontal drilling under national parks and AONBs so long as it starts outside the areas. World Heritage sites such as The City of Bath are protected.

In his letter Mr Rees-Mogg also states:

“The Government has proposed to allow developers to access the ground up to 5000 feet below private land without the risk of breaching trespassing laws”

The trouble is that 1000 metres does not equal 5000 feet, it is not even close.

If Mr Rees-Mogg insists on using the Weights and Measures Act 1824 as his standard for measurement then he should make more effort to get the conversion right. Any school pupil will tell you that 1000 metres is about 3000 feet, not 5000 feet. More precisely it is 3281 feet. So, Mr Rees-Mogg has exaggerated the depth at which trespass extends by a factor of 1/3. It is hard to imagine how he came up with the figure of 5000 feet unless he was thinking about the maximum (rather than the minimum) depth that coalbed methane (CBM) can be extracted from the Somerset coal seams.

What is equally worrying as Mr Rees-Mogg’s innumeracy is that the Infrastructure Act doesn’t seem to apply to CBM. The Coal Act already gives powers for drilling in coal seams without trespass. During the limited debate on the Bill Tessa Munt MP asked in relation to CBM whether “there should be a prohibition on all gas exploitation at depths of less than 1,000 metres?  but she received no reply.

On CBM extraction the Government’s Planning Guidance says:

“Extraction is likely to be achievable between 200 and 1500 metres, depending on the coal permeability and other issues. At shallower depths the gas pressure in the coal is likely to be insufficient, while at depths greater than 1500 metres the pressure of the overlying strata is likely to have reduced coal permeability restricting the flow of methane.”

The GeoMet Inc assessment of CBM in Somerset suggested extracting coalbed methane at depths between 152m (500 feet) and 1524m (5000 feet) and there would seem to be nothing in the Infrastructure Act to prevent that happening.

Despite a Freedom of Information Request and an appeal the Department of Energy and Climate Change has declined to say where in Somerset gas companies have applied for new licenses as part of the 14th onshore licensing round. Almost everywhere in the Bristol Somerset coalfield, apart from the City of Bath, is therefore still at risk of becoming a gas field. UK Methane are expected to apply for planning permission for test drilling in PEDL 227 at any time.

The Bad News and a Glimmer of Hope

NEWS ALERT!

The bad news is that FFCV has located a Department of Energy and Climate Change (DECC) report from 2000 prepared by American coalbed methane (CBM) specialists GeoMet Inc which lays bare what the government already knows about coalbed methane exploration in the Chew Valley and surroundings – the extent of the prospective area, the estimated volume of the gas and the number of wells needed to extract it. In the 400 sq km around the Chew Valley lake 108 sq km are considered prospective and if fully developed would require about 300 gas wells on a 566m well spacing. It is quite shocking that this public information has not been made available to local communities (or to BANES) so that they can make informed decisions about unconventional gas and how it might affect them, their families and their businesses. What is more this report was not referred to in the report on unconventional gas prepared for BANES by the British Geological Survey – even though they make reference to it in their national CBM evaluation. Read our web page on the subject and the report and maps we have prepared from the original government report and digital map data.

FFCV CBM Report

FFCV CBM Report

The glimmer of hope is that BANES has been informed by DECC that three of the four current Petroleum Exploration and Development (PEDL) licences covering Somerset have been relinquished (i.e. given back to the State) by the gas companies (PEDLs 225, 226, 228), including most of the Chew Valley catchment. However these PEDLs could be put back into the pot and offered again to other gas companies for exploration and development as part of the 14th Onshore Licensing Round, which is imminent. On the basis that these areas have now twice been evaluated by gas companies and twice they have decided not to develop them it is imperative that they are now excluded from further licencing rounds to protect them. Help make this happen by writing to BANES, to your MP and most importantly to Rt Hon Michael Fallon (correspondence@decc.gsi.gov.uk) the minister of state responsible for onshore unconventional gas. That the government should knowingly licence these sensitive areas exposes the extent to which the administration is willing to gamble with what David Cameron only recently described as one of “Britain’s greatest assets” – the beautiful countryside of the West Country – not to mention your well being.

Further bad news though is that licence PEDL 227 has been extended indicating that the company UK Methane is probably planning to apply for planning permission to drill an exploration bore hole. The DECC/GeoMet report indicates where within that PEDL the exploration might take place and if productive how may wells might be needed to extract it – its about 85.

Somerset PEDL Map

Somerset PEDL Map (Source Frack Free Somerset)

Let your MP know what you think and make sure they know what the government actually knows about unconventional gas in their constituencies rather than listen to their parroting and cheer-leading of the coalition government’s position.