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“.

Andrea Leadsom Misses the CBM Point

Recent local press reports (Bath Chronicle, Chew Valley Gazette) have trumpeted the news that Ben Howlett MP (Bath) and James Heappey MP (Wells) have been assured by Andrea Leadsom, Minister of State for Energy and Climate Change, that North East Somerset and the Mendips are not in the ‘shale prospective area’ and that there is “no frackable shale gas to be found” with Mr Howlett adding that “I am delighted to find that Bath and the Mendips do not have frackable shale gas under the surface and is therefore safe from the risk of fracking”.

However these statements miss the point that the primary hydrocarbon of interest to the gas companies in the area is Coalbed Methane (CBM) not Shale Gas. The previous licence holder for BANES/Mendip, UK Methane, said in its PEDL 227 relinquishment report (September 2015) that:

The licence is still possibly prospective for:

  •   Coal Bed Methane in the Westphalian Coal Measure
  •   Namurian Shale Gas
  •   Avon Group (Lower Limestone Shale) – Shale Gas Potential
  •   Devonian – Potential Conventional Play in Variscan structures”

The latest maps of Andrea Leadsom’s own department (updated 21/12/2015) show that  more than 1,000 square kilometres of the West Country have just been licensed for onshore oil and gas exploration including the Somerset-Wiltshire border, the Forest of Dean and the Somerset coast from Clevedon to Minehead despite none of these licenses being in the shale prospective area. At the time of the 14th Onshore Licensing Round UK Methane were still sitting on the Mendip PEDL so it couldn’t be put forward for consideration.

Despite what Andrea Leadsom has said there is nothing stopping the Bristol-Somerset coalfield being licensed yet again in the next licensing round for exploration of CBM. It is worth noting that the safeguards to shale gas fracking in the Infrastructure Act 2015 do not apply to CBM including surface drilling in protected areas such as AONBs and World Heritage Sites and fracking at depths as shallow as 200m.

So this good news story rings rather hollow. Nothing has changed except a larger area of Somerset is now licensed for oil and gas exploration than ever before.