Concerned about water pollution?

The Northern Ireland Environment Agency is currently undertaking a consultation on Significant Water Management Issues. The deadline for responses is 22nd June 2014. Email and postal addresses are included below.

The consultation documents for each of NI’s three river basin districts refer to the risks posed by mineral extraction and refer to unconventional gas exploration and extraction. They all say the same thing. Here is an extract from the North Eastern River Basin District consultation document, p31. [emphasis added].

“Pollution of surface waters can occur as a result of run-off from the land area around a quarry or mine, hydrocarbon or herbicide spills, excess herbicide or fertiliser applications, run-off from soil and spoil heaps which may contain toxic metals and phosphates. Pollution of surface waters can also occur indirectly by pollutants being transported in groundwater.

Mineral extraction by its very nature poses risks to groundwater. Removal of the overlying land in the working area means that the vulnerability of the groundwater to pollution is increased as the natural protection is removed. Therefore, it is important that proper precautions are taken to ensure the risk of pollution is minimized. Pollutants may include oils, fuels and hydraulic fluids, metals (for example, Cadmium, Mercury), pesticides, flocculants used in settlement ponds and nutrients.

Unconventional gas exploration and extraction refers to the use of high volume hydraulic fracturing (fracking) of previously impermeable rock to permit the extraction of natural gas on a commercial scale from unconventional sources such as shale gas deposits, coal seams and tight sandstones. At present, there is no exploratory or commercial drilling underway in relation to this in Northern Ireland.  

What are we already doing about this?

New legislation was introduced through the Planning Reform (Northern Ireland) Order 2006 which requires the initial review of old mineral permissions. Mineral mapping has been undertaken to highlight where specific reserves are located, what type they are and what constraints exist in the form of environmental designations. Northern Ireland Government Departments, through the shale gas Forum, are in the process of identifying the regulatory framework applicable to onshore oil and gas exploratory activities in Northern Ireland, and the linkages between the existing regulatory regimes. Such activities may include high volume hydraulic fracturing. As part of the planning process, NIEA requests hydrological risk assessments for quarries, to assess risks from dewatering and how they can be mitigated. NIEA provides guidance notes for applicants.

Possible options that could be put in place?

Significant all-Ireland research project to be scoped that will contribute to providing the evidence base for the regulation of fracking.”

(North Eastern River Basin District, http://www.doeni.gov.uk/niea/swmi-north-eastern-reduced-size-2.pdf p31.)

NI’s three river basin districts are:

North Eastern River Basin District – Bush, Glens & Rathlin, Larne Lough, Belfast Lough, Lagan, Strangford, Quoile and South Down

North Western River Basin District – Faughan, Roe, Burn Dennet & Foyle, Strule, Derg & Mourne, Owenkillew, Lough Melvin & Arney, Upper Lough Erne and Lower Lough Erne

Neagh Bann River Basin District – Ballinderry, Moyola, Lough Neagh, Lower Bann, Braid and Main, Six Mile Water, Upper Bann, Blackwater and Carlingford & Newry

People can respond to this consultation at a general or local catchment level.

The consultation questions are the same for each area:

1. What do you consider to be the most significant issues affecting the water
environment in the North Eastern [or other] River Basin District?
2. What do you consider to be the most significant issues affecting the water
environment in your Local Management Area?
3. How do you think these issues should be addressed, and what would you choose to do first?
4. Are there any projects that we could work on in partnership to help improve the water environment in North Eastern [or other] River Basin District?

Here is a very simple response you can use as a template, although putting it in your own words would help:   (A more detailed version will be added later.)

 

This consultation is open from the 22nd December 2013 to 22nd June 2014. You can respond by :

• sending a response by e-mail to:  riverbasinplanning@doeni.gov.uk
or
• sending a written response to:
River Basin Planning – Consultation,
Water Management Unit
DOE NIEA
17 Antrim Road
Tonagh
Lisburn
BT28 3AL

Upcoming Event

Bushmills, Wed 28th May – 7.30pm, Dunluce Parish Centre, 13 Priestland Rd.

Worth attending!

Mike Hill, Chartered Engineer, with oil industry experience, will be talking about Fracking, Safety and Regulation.

James Orr, Director of Friends of the Earth Northern Ireland, will be providing an overview of NI’s track record with regard to environmental regulation, monitoring and enforcement.

Bushmills event poster

 

 

 

Is Rathlin Energy Ltd exploring for shale gas, or not?

Rathlin Energy director David Montagu-Smith has tried to allay the concerns of people in East Yorkshire, by saying that Rathlin Energy are not ‘Sneaky frackers’ (http://www.hulldailymail.co.uk/sneaky-frackers-Rathlin-Energy-insists-East/story-20964187-detail/story.html).

We wonder if their plans for Yorkshire are different from their plans for the North Coast of Northern Ireland. When called upon at various public meetings to rule out fracking for shale gas in Counties Antrim and Derry/Londonderry, the company’s executives (including Mr Montagu-Smith) repeatedly refused to rule it out, saying that they had to explore all of the options for the licenced area (from Magilligan in the west, to Ballycastle in the east and as far south as Garvagh).

The company has applied to drill an exploratory well into the shale layer at Ballinlea in North Antrim under licence PL3/10. The original licences (click CE1-04 and CE2-04) under which their first well was drilled at Ballinlea in 2008, were specifically for the exploration of commercial Coalbed Methane and Shale Gas potential in the Rathlin Basin. (The licences were held originally by Rathlin Energy Ltd’s Canadian owner, Connaught Energy Ltd, and were transferred to Rathlin Energy Ltd in 2007.)

Those licences say:

“This Licence CE1/04 and licence CE2/04 form part of a single integrated exploration programme over the Rathlin Basin. The core elements of this programme are:

  • the development of a hydrocarbon system for the basin,
  • the drilling of one shallow well to provide core, from the Ballycastle Carboniferous coal and organic-rich shale section, that will be analysed for CBM [Coalbed Methane] potential,
  • the drilling of one exploration well, in the Rathlin Basin, to evaluate the Carboniferous section for commercial coalbed methane and gas shale potential,
  • the evaluation of the results from the above to produce a final prospectivity assessment of the licence areas.”

Minister Arlene Foster wrote in a letter responding to queries of local residents (via local MLAs) in November 2011: There may be some additional potential for ‘unconventional’ gas resources including shale gas in the onshore Rathlin Basin, and the Department would expect Rathlin Energy Ltd  to review this in their evaluation of the overall prospectivity of the licence. 

Despite their stated target being conventional oil and gas, Rathlin Energy Ltd’s proposed operational plan for Ballinlea includes drilling down into the shale layer (past the layers expected to contain conventional oil and gas deposits), and undertaking extended well testing using a variety of well stimulation techniques, including (if deemed necessary) dissolving the rock with hydrochloric acid (‘acid wash’ and ‘acid squeeze’), a mini fall-off test to check permeability of the rock, and conventional hydraulic fracturing, using sand, water, and ‘stimulation fluid’. These processes could be repeated at multiple intervals within the reservoir. This would provide information to the company on the viability of commercial extraction of the different types of gas or oil (conventional and unconventional) contained within different intervals or types of source rock (shale, sandstone, coal seams, etc.)

Even if Rathlin Energy Ltd IS exploring for conventional oil and gas, does this not ALSO sound like exploratory drilling for shale gas…the type of exploratory drilling which is necessary in advance of (high-volume) hydraulic fracturing? We think so.

Could, or would, you explore for shale gas without undertaking this type of exploration first? Not likely.

If your target was only conventional oil and gas, would you spend more money drilling deeper than necessary? Not likely.

Is Rathlin Energy Ltd exploring for shale gas? Can you really look at the evidence and say ‘no’?