The Oil and Gas Industry Want Unlimited Industrialisation of North Yorkshire
This post is part of a series about oil and gas industry responses (pdf) to the consultation on the Joint Minerals and Waste Plan (JMWP) for North Yorkshire which was held last year. The previous post on the prospect of oil and gas drilling and fracking near your home can be found here.
As well as making comments opposing restrictions on their right to drill and frack near peoples homes, oil and gas companies also had a lot to say in the consultation about the possibility of restricting the density of oil and gas development in North Yorkshire. The issue of dense industrialisation of gas fields is particularly important in the case of fracking, as shale gas fields have seen very large numbers of gas wells drilled and fracked. The Ecoflight photos in this post show a gas field in Wyoming and give an indication of just how dense development for gas production can be, if left unchecked.
According to policy M17 of the draft JMWP, “well pad density and/or the number of individual wells within a PEDL area will be limited to ensure that unacceptable cumulative impact does not arise.” The limit of well pads and oil or gas wells is not defined in the policy itself, but the justification for the policy goes on to say that, “it is considered unlikely that proposals which would lead to a total development density, including operational and restored sites, of more than 10 well pads per 100km2 PEDL area (pro-rata for PEDLs of less than 100km2) would be compatible with the purpose of this element of the Policy.”
While 10 wellpads in a 10km by 10km license block would in itself constitute a major industrialisation of the countryside the oil and gas industry rejects the suggestion that there should be no more development than this.
Egdon Resources (UK) commented, “there is no justification for setting a well pad density or arbitrary limit to the number of individual wells within a PEDL area. Whilst an assessment of the cumulative effects of planned and existing developments within the immediate vicinity of a proposed hydrocarbon development may be justified to ensure that cumulative impacts are taken into account, there is no justification to restrict or refuse a proposed development simply because it is in close proximity to other existing, planned or unrestored well pads.” They went on to say, “there is no justification or evidence to demonstrate that a development density of more than 10 well pads per 100 sq. km would result in any material adverse impacts.”
INEOS Upstream said, “this paragraph deals with proposed well pad development density. The geographical spacing, scale and type of development in addition to the topographical and surface characteristics of an area should be considered in the assessment of a proposal and the density of development in a particular area. It should not be based on PEDL boundary or an arbitrary figure for well density that does not reflect the nature of an applicant’s proposals or the ability of the environment to accommodate it appropriately.”
Third Energy and industry group UKOOG said, “Assumptions on pad density should not be used to derive policy until such times as exploration has been undertaken. There can be no limit set until more is known about the geology. The Plan can be revised once the potential resource is better understood in the light of exploration. It should be noted that licence blocks are typically 10km by 10km but a Petroleum Exploration and Development Licence may comprise a number of blocks or only part of a block. Therefore, establishing a total density of 10 well pads per 100km2 is considered inappropriate as there is no arbitrary PEDL size.”
Third Energy and Zetland Group said, “It is not appropriate to set pad density limits. The para is over complicated and unnecessary. Hydrocarbon developments are often temporary, low impact developments and some areas may well have capacity to accommodate numerically more than others. At production phase, hydrocarbon development can be unobtrusive as evidenced by the existing gas production sites within the Vale of Pickering.”
The oil and gas companies that responded to the consultation in December made clear that they do not want to be restricted to having ten well pads in a 10km by 10km license area. This is in line with information which came to light in 2016, when INEOS released an Invitation to Tender (pdf) for a seismic survey contractor. This document showed a production scenario with up to 30 well pads with up to 396 gas wells per license area. When this information was revealed by Frack Free Ryedale INEOS rowed back from these enormous figures. However their response to the consultation shows that they still want the option of extremely dense industrialisation.
In January oil and gas industry group UKOOG released a visualisation of future shale gas development. This visualisation was criticised for only showing three well pads in each 10km by 1okm area and thereby understating the impact the shale gas industry would have if allowed to proceed. UKOOG’s appeal in the consultation in December last year that there should be no limit on well pad density at the current time lends weight to these criticisms.
One possible reason for these companies’ insistence that there should be no limit on the number and density of well pads, is that they are likely to need large numbers of well pads to fully exploit the unconventional gas, such as shale gas that they are interested in. A recent paper based on research part funded by INEOS, Chevron, Total, Centrica and GDF Suez, concludes that 10km by 10km license blocks will on average be able to accommodate 26 well pads. This is possible only with a setback distance from buildings, including houses, as low as 152 metres. Despite the extremely intensive development that would be brought by having an average of 26 well pads in a license area, the authors of the study point out that not all the shale gas available would be produced, even at this level of development. They conclude, “the carrying capacity of the land surface, as predicted by this approach, would limit the technically recoverable gas reserves for the Bowland Basin from the predicted 8.5 × 1011 m3 to only 2.21 × 1011 m3.”
While the industry presents their future as preserving the countryside, with only three well pads per 10km by 10km area, they argue to be allowed more than ten well pads in the same area. At the same time researchers they funded point out that even 26 well pads in the same area is not enough to produce all the gas they were hoping for. It is now clear that if fracking is allowed to proceed in the way the industry wants the North Yorkshire landscape will be severely harmed by this new heavy industry spreading unchecked across the county. It’s more vital than ever that we continue to oppose fracking. Please see our events calendar for information of events you can take part in.