REINFORCED OBJECTION BY FRACK FREE FORMBY TO AURORA’S PLANNING APPLICATION FOR EXPLORATORY FRACKING AT GREAT ALTCAR           

Background

Frack Free Formby lodged a detailed objection to this planning application in mid-October 2019, citing 16 grounds for refusal to the development. Lancashire County Council issued a Regulation 25 letter to Aurora on the 25^th October 2019, seeking further information in the light of comments from its consultees.

Aurora responded on the 9^th December 2019 but Lancashire County Council did not display the response on its internet planning portal until the 10^th January 2020. It then invited consultees to react to the new information supplied by the 21^st February 2020.

Frack Free Formby has carefully considered Aurora’s response and found it complacent, incomplete, and (in part) misleading. Accordingly, it has lodged the following reinforced objection to the proposed development, concentrating on issues concerned with Seismicity, Climate Change, and Air Quality.                                                                                                           

Seismicity

1. It is noted that Aurora has now acknowledged that induced seismicity from its proposed fracking operation could reach a level of 3.1ml. This equates to an approximate TNT value of seismic energy yield of 32 metric tons, equivalent to detonating a massive ordnance air blast bomb up to 3km underground. Local residents are clearly worried about the prospect of earthquakes induced by fracking causing structural damage, subsidence and heave. This is not the only concern however.
2. The County Council is reminded that the fracking well at Preece Hall was irrevocably damaged by a seismic event of 1.5ml in May 2011, which deformed the bottom 170 metres of the well, making it ovoid instead of round. Damage of this nature might lead to the creation of ready-made conduits, encouraging the fugitive migration of unrecovered gas and fracking fluid into groundwater sources and ultimately the land surface. This is almost inevitable anyway because the steel tubing of older, abandoned, fracking wells will corrode over time, and the concrete casing will crack and shrink in response to formation pressures.
3. Fugitive migration could also occur if fracking operations are authorised in rock formations which contain a large number of fault lines. Aurora downplayed this prospect in its planning application, providing figure 17.1 in its Environmental Statement (Appendix 1). The same figure was used in Aurora’s public exhibition in November 2018, and publicly challenged by representatives of FFF.
4. Aurora’s Managing Director admitted at the time that the figure was only intended as a typical example of the geology of the Bowland Shale, and was not indicative of the Formby and Great Altcar area. FFF’s research has unearthed two illustrations of the actual geology under the proposed well pad at Great Altcar i.e. a regional section around Formby, and a geoseismic cross section near the old Formby oilfield (Appendix 2). Both are taken from the UK Onshore Geophysical Library.
5. The regional section was initially displayed as a wall chart at the Regulators ‘roadshow’ held in Aughton in October 2016. It clearly shows a proliferation of inter-connecting fault lines running from deep underground up to the land surface. The geoseismic cross section was featured in a government report and illustrates the ‘castellation’ of the rock layers, confirming that the main fault lines lead directly to the surface. Clearly therefore the geology of the proposed well site is likely to be prone to large scale seismic events.
6. Local residents have already raised concerns about the safety considerations of Aurora drilling fracking wells close to the old Formby oilfield. Aurora has responded that most of the old wells were shallow and all were securely abandoned; and that their integrity is a matter for Regulators to determine. It is implied (but not explicit) from Aurora’s site plan that it intends to direct its lateral drilling initially away from most of the old oilfield wells. Nevertheless, the close proximity of inter-connecting fault lines in the underlying geology is a matter for concern.The integrity of these wells was mentioned when Aurora applied to Lancashire County Council for planning permission in 2011 for exploratory boreholes on the old oilfield site. Paragraph 3.3.4 of the application stated that “The Formby oil seep is still active as evidenced by the natural occurrence of oil within drainage ditches and in the shallow subsurface (Figure 5).” This figure is reproduced in appendix 3. FFF believes that this is also evidence both that the old wells have decayed and of the presence of underlying fault lines, confirming that the local geology is prone to fugitive migration.
7. Some of the problems encountered at fracking wells in other parts of Lancashire stem from a lack of knowledge of the presence of fault lines, and because an operator drilled too close to them. Aurora contends that subsurface controls are outside the remit of Lancashire County Council, and a matter for Regulatory bodies. FFF believes however that Regulatory supervision of fracking operators is inadequate, and that local residents deserve specific assurances on this issue before a decision is made on the planning application. It is aware of legal advice that the County Council can consider safety concerns if they are not satisfied that they will be fully addressed by Regulators before granting consent.
8. There is of course also the prospect of the government lifting the moratorium on the actual fracking process and increasing the red traffic light figure in due course. FFF argues that earthquakes of 2.9ml have occurred while operators tried to stick to the 0.5ml limit, and a higher red-light limit might mean greater hydraulic pressure being applied – triggering even higher and more frequent earthquakes. We believe that a similar outcome could arise in the event of using acid stimulation instead of fracking, or to augment lower pressure levels while hydraulically fracturing.

Climate Change

1. Aurora’s Regn. 25 response on this issue is to clarify that the proposed development at Great Altcar is expected to add 0.07% to the total of UK greenhouse gas emissions from the energy supply sector. Frack Free Formby contends that this ‘man-made’ event will hamper achieving global climate change targets, to try to avoid the dangerous and damaging weather extremes currently being encountered.
2. In 2019 the NOAA Global Climate Summary reported that land and ocean temperature increased at an average rate of 0.07°C per decade, since 1880, and 0.18°C per decade since 1981. Since 1900 world temperatures have increased by 1°C and most of that has been since the 1970s. This rate of temperature increase, since the industrial revolution, is unique in the observed history of the planet. Pre-industrial revolution temperatures have been derived from geological studies and then, since the mid-1800s, recorded temperatures.
3. Since the beginning of the industrial era humans have put almost 2000 gigatons of CO₂ into the atmosphere, which is an increase of 31%, and about 40% has remained there. By comparison, volcanoes make only 1% of the CO₂ that we do. We also emit high levels of methane and nitrous oxide from intense farming. Nitrous oxide is also released by the burning of fossil fuels. The increasing CO₂ in the atmosphere has been identified as coming from the burning of fossil fuels. The increasing CO₂ has the same ratio of isotopes, C₁₂ to C_13, which is found in fossil fuels.
4. The sun is not responsible for global warming. If it were then it would heat the upper and lower layers of the atmosphere together. But warming is only happening in the lower layers, where human greenhouse gases are accumulating. The Milankovitch cycle, which is a 100,000-year cycle, is caused by changes in the Earth’s orbit around the Sun. The warmest part of the last cycle was around 10,000 years ago and we should now be in the cooling period, but instead world temperatures are increasing. There is also a solar sun-spot cycle, which is an 11-year cycle. But the sun has been through many 11-year solar cycles since the beginning of global warming in the 1800s.
5. The oceans are the worlds’ largest carbon sink and warming of the oceans is exacerbating the problem of CO₂ remaining in the atmosphere. Summer sea ice in the Arctic has decreased by 40% since 1978. Sea ice reflects the sun back into the atmosphere, but the dark ocean has now soaked up enough heat to increase the sea levels by 20cm since 1901, due to water expansion. A study by MIT has found that photosynthesising organisms, which absorb CO_2, are much less active in the warmer waters; whereas respiring organisms, that release CO_2, are more active when the water is warmer.
6. Methane in the Earth’s atmosphere, traps 84 times more heat per mass unit than CO₂ over a 20-year period and about 28 times more heat than CO₂ over a 100-year period. Methane released into the environment, due to fracking, has been so intense in some areas that people can literally set light to their drinking water with a match; and eventually this released methane will propagate upwards into the atmosphere.

Air Quality

1. Air pollution from fracking reveals a plethora of recurring problems and harm, and a large body of scientific opinion has been compiled and evidenced which is troubling. Multiple studies in many locations, using a variety of methodologies, point to serious health concerns including cancer risks and chest problems to those who are exposed to high levels of toxins such as formaldehyde and benzene amongst others, that have been emitted from flare stacks.
2. In addition, it has been reported that living near a fracking site, significantly increases the risk of an asthma attack due to sulphur dioxide, nitrogen oxides and other organic compounds. COPD is also more prevalent as well as headaches, migraines, skin, nose and throat disorders due to toxic fumes, airborne silica and diesel particulant matter from the increase in HGVs. Furthermore, studies have revealed that mothers who live near a fracking site can have up to a 40% increase in the chance of a pre-term birth and there have been lower birth weights, congenital heart defects and higher rates of developmental and neurological disorders as well as decreases in fertility rates.
3. Aurora’s Regn. 25 response to concerns about air quality refers to monitoring being
   undertaken by the Environment Agency. Yet in a report commissioned only last year by Unison, it was found that at a time when inflation has increased by 11% in real terms, the Environment Agency grant has been cut by more than a quarter. In addition, environmental health budgets per head of population have more than halved over the past decade. Enforcement visits by environmental health officers have fallen by nearly a half. In the words of the report: ‘Environmental health services have been cut to the bone. Officers are seeing more noncompliance with the law, which leads to much more serious consequences.’
4. This does not bode well as the public is reliant on such agencies to carry out regular, reliable monitoring of the air quality at and around the site. In addition, at what point does the monitoring cease? Is this when the site is decommissioned? Evidence suggests that fracking sites continue to emit toxic gases for years after they are decommissioned due to degradation of the bore pipes, the bore cap and also through the emission of gases via newly opened fractured pathways to the surface through the movement of the rock below.
5. Concerns about the pollution produced by the HGVs going to/from the fracking site arise because the proposed route goes past communities which would be affected by the reduction in air quality due to the increase in traffic and diesel fumes. This will only be exacerbated by the HGVs servicing the planned housing and industrial development adjacent to the Formby by-pass.
6. To date, there has been no information as to the exact chemicals that will be used in the   fracking process at Great Altcar. It is not acceptable to have a generic waste type view and this lack of data leaves the application flawed.
7. Local residents and businesses are concerned at the toxic nature of the loads in some of the vehicles entering and leaving the proposed fracking well site. Aurora will have to import large quantities of the acids and silica sand they will need for hydraulic fracturing of the shale. If they locate the gas, they will almost certainly use tankers to convey it away. Furthermore, some 60% of the millions of litres of fracking fluid injected into wells will flowback to the surface, and will need safe disposal by tanker. The flowback will have absorbed chemical elements in the shale, and will inevitably prove to be flammable, toxic, carcinogenic, and partly radioactive.
8. There is an obvious risk of a road traffic accident and spillage of one of these cargoes. There are many businesses sited in the retail park on both the north and south sides of the B5195 Altcar Road running between the traffic light junction on the A565 near Tesco’s and the bridge over the Downholland Brook. It is estimated also that about 2,000 of Formby’s 9,500 homes are located within an 800-metre-wide corridor immediately adjacent to the west side of the A565 by-pass. This number will increase shortly as construction work has also just started on the 300 new homes located near the Liverpool Road roundabout junction on the by-pass. Clearly the use of the New Causeway as an alternative/fall back route for fracking traffic would alleviate these concerns.

APPENDIX 1

Figure 17.1

APPENDIX 2

Regional Section around Formby

Geoseismic Cross Section near old Formby oilfield

APPENDIX 3

Natural oil seepage in drainage ditches near old Formby oilfield