This is what WinACC told DECC about why we oppose fracking in reply to their consultation, April 2014

1 Do you think that the Environmental Report has identified the significant environmental effects of the activities that follow the licensing round? If not, what other significant effects do you think we have missed, and why?

No.
a. Climatic impact of exploring for more fossil fuels
It is clear from the work of many climate scientists that, as a general principle, exploration for fossil fuels should cease simply because globally identified fossil fuel reserves, if burnt, will be sufficient to raise global temperatures above the dangerous threshold of 2°C. In fact it has been estimated that between two-thirds and 80% of such fuel reserves should remain in the ground.

It is pointless and even reckless therefore to encourage the exploration and production (E&P) of yet more fossil fuels. It follows that to avoid dangerous climate  change it is not sufficient to seek to ‘minimise greenhouse gas emissions as a contribution to climate change’ [Table NTS.2]. The report acknowledges that UK emissions will increase as a result of the E&P of unconventional oil and gas yet it is obvious that emissions must be abated.

b. Energy security
Arguments about shale gas underpinning the UK’s energy security should be countered with the stronger argument that increased investment in energy saving, energy efficiency and renewable energy will provide such security much more quickly and probably more cheaply.

c. Water use in stressed areas
Although on a UK-wide scale some experts seem to be relatively relaxed about the increased demand for water for fracking (ref.1) they acknowledge that the situation will be different in water stressed areas. In SE England the population and number of households is steadily increasing, climate projections suggest a hotter and drier climate with more rain in the winter and less in the summer, the distribution network is old and relatively leaky and the per capita consumption of water is increasing year on year. Consequently in 2007 the Environment Agency classified SE England as an area of ‘serious water stress’ (defined according to the availability of water, current and forecast demand, and population growth) (ref.2).

Indeed, the government’s Committee on Climate Change said in July 2011 that almost half of the UK could be affected by severe drought by 2035. The situation is emphasised in Figure 2.2 (ref.1) which shows that water is estimated to be available for abstraction for new licences for less than 30% of the time in most of the area south-east of a line from the Wash to the Severn estuary. It hardly seems practical on that basis to attempt to extract shale gas from that area.

We concur with the view of the National Trust, RSPB and four other conservation bodies which believe ‘it should be a legal requirement that the water industry is consulted in the planning process. This will help ensure that demands on public water supply and waste water treatment can be met without compromising the natural environment, and before planning permissions are granted.’ (ref.3)

d. Protection of National Parks, AONBs, SSSIs etc.
We consider that under no circumstances should shale gas exploration be contemplated in National Parks, AONBs, SSSIs and similar regions. We are deeply concerned at the effects of any air and water pollution on such areas and the effects of water extraction on water courses, springs etc.

References
1. Grant, Laura, and Chisholm, Alastair. Shale Gas and Water. Chartered Institution of Water and Environmental Management, January 2014 and summary in Grant, Laura. “Getting to the Facts of Fracking.” The Environment, April 2014.
2. Anon. (2008). Future Water: The Government’s water strategy for England. London, DEFRA: pp.98.
3. Anon. Are We Fit to Frack? RSPB and 5 other groups, March 2014.

2 Do you agree with the conclusions of the report and the recommendations for avoiding, reducing or off-setting significant effects of the activities that follow the licensing round? If not, what do you think should be the key recommendations and why?

No.
a. Shale gas is not necessarily cleaner than alternatives
It is not clear what quantitative assumptions have been made about the effects of methane leaks on the atmosphere during the E&P phases and even after well abandonment. A recent review of experience in the USA sets an upper limit of almost 8% for fugitive emissions which, with the latest IPCC estimate of the 20-year global warming potential of 86 for methane, has led some commentators to suggest that shale gas is almost as polluting as coal over 20 years. (refs.4, 5) Recent presentations from the USA (ref.6) suggest that wells can continue to leak methane into the atmosphere after abandonment which further weakens the ‘cleaner alternative’ argument. 

References
4. Brandt, A. R., G. A. Heath, E. A. Kort, F. O’Sullivan, G. Petron, S. M. Jordaan, P. Tans, et al. “Methane Leaks from North American Natural Gas Systems.”
Science 343, no. 6172 (February 13, 2014): 733–35. doi:10.1126/science.1247045. Howarth, R., Shindell, D., Santoro, Ingraffea, A., Phillips, N., and
Townsend-Small, A. Methane Emissions from Natural Gas Systems Background Paper Prepared for the National Climate Assessment, February 25, 2012.
Webster, Robin. “Are We Underestimating Natural Gas Emissions?” February 13, 2014.
http://www.carbonbrief.org/blog/2014/02/natural-gas-emissions-are-being-....
5. http://www.climatecentral.org/news/limiting-methane-leaks-critical-to-ga...
6. Papers presented at session A53H of the Fall meeting of the American Geophysical Union, San Francisco, December 2013.

3 Do you agree with the proposed arrangements for monitoring significant of the activities that follow the licensing round, detailed in the Environmental Report? If not, what measures do you propose?

No.
a. Need for pre-exploration monitoring to establish baseline values
Baseline monitoring around proposed well sites is absolutely required to avoid subsequent post-drilling arguments about the causes of any perceived changes in environmental parameters. We emphasise that any baseline monitoring of water quality and air quality needs to be maintained for at least one 12-month period before drilling begins because of likely seasonal effects. Clearly methane and chemical additives used in the fracking process should be included in this monitoring.

b. Need for regulation and resources to ensure regulations are met
Recent 15% cuts in the budget of the Environment Agency and the insistence of at least one Minerals Planning Authority (Hampshire County Council) that current regulations adequately cover the E&P of shale gas do not give us confidence that the current situation is fit to ensure that fracking in the UK can be carried out in a way that best protects the environment and does not contribute to climate change.

c. The post-abandonment phase of wells
Possible leaks of methane into the atmosphere after a shale gas well has been abandoned are not addressed (see section 2a above and p.32 in the report). Who will be responsible for an abandoned shale gas well and ensure that it does not leak into the atmosphere? Which independent body will monitor wells after abandonment?