FFAN response to the Hatch Report – Nov 2021

A summary of the ‘Hatch report’ relating to the possibility of petroleum licensing in Northern Ireland recently became available. This summary,
https://www.facebook.com/139276246741759/posts/851207292215314/ was commissioned by the Department for the Economy and delivered to that Dept in July 2021. Below is the response of FFAN [Fermanagh Fracking Awareness Network].

In the fifth paragraph, the report states ‘the scale of the potential GVA [gross value added] and the employment impacts are shown to be relatively low, even under the high development scenario’. Then in the graph at the end of the report it states that this same high development scenario is likely to have major adverse impacts on groundwater and surface pollution and abstraction, also major adverse impacts on social cohesion and community wellbeing. This is no surprise to all of the community groups who have been researching this issue for the last ten years. But shocking that these petroleum licenses are even being considered. Thus the Hatch Report has given the NI Executive the answer to the question should we allow petroleum licensing in Northern Ireland; the benefits are low and the risks are too high so the answer can only be No.

Even using this sanitised version of the oil and gas industry presented by the Hatch Report it is full of glaring omissions and commissions.
Once established the fracking will commence at a higher intensity than the report suggests as that is the only way the industry can make money. The oil and gas industry will then leave us in NI to literally clean up the mess and pay the bills.

Other points

  1. None of the authors, based on tender process documents, have any Medical or Public Health qualifications.
  2. The ‘No development scenario’ is dismissed in one sentence early on as simply a baseline. The report says this scenario will have ‘no additional social or environmental impacts on the baseline conditions’. This current baseline protects our health, air and water. It protects our agriculture, tourism and many more jobs. It is the baseline building block for our future prosperity towards a greener sustainable future. This baseline is not a brake on our potential development, but a prerequisite.
  3. The report mentions climate change and net-zero many times, yet repeatedly tries to justify setting up a fossil fuel industry from scratch, in the same year as the COP26 summit.
  4. Section 18: The petroleum licensing Act of 1964 is used in this section to justify the unjustifiable. It must be obvious by now to all parties that this policy has to be updated to reflect the climate emergency that we live in. To meet net-zero by 2050 we must have a zero-tolerance for setting up (and subsidising) a fossil fuel industry in NI. We need a new energy policy to reflect this; specifically that no petroleum licenses will be considered or granted.
  5. Section 20: The report states that the Northern Ireland [NI] assembly debated a motion on a moratorium on onshore [hydrocarbon] development until a bill was brought to ban the same. The report fails to mention that the NI Assembly did not just debate it, but unanimously passed that motion.
  6. Section 31: Lateral drills per well. The report says low intensity will be ten wells & two lateral drills per well, high intensity will be 34 wells & four lateral drills per well. This is a gross underestimate, Wells usually have 8 to12 lateral drills, often up to 16. Tamboran were planning for 60 wells in Fermanagh ~ 1km apart, each well with 12 lateral drills. The more lateral drills created, then the greater the risk of aquifer pollution, fugitive methane emissions and leaks both above and below ground.
  7. Section 40: The report says the oil and gas industry will have a negligible impact on tourism; maybe even increase some trade in restaurants. In reality, the impact on tourism will be negative, large and immediate.
  8. Section 44: Will only have a modest negative impact on the Agri-food sector. This is a highly suspect claim, the negative impact will be huge and long term
  9. Section 47: Health Impact Assessment and associated issues simply stated as not done.
  10. Section 55: States that the UGEE JRP [unconventional gas exploration & extraction joint research programme, Irish-all island group] concludes that ‘there is significant uncertainty around the following topics in particular: Groundwater aquifers could be polluted as a result of the failure or deterioration of well Integrity. These aquifers could also be polluted by the migration of pollutants and gas to the aquifer as a result of the fracking process. The long term leakage of gas after well closure’.

The Hatch report does not even consider the precautionary principle. That the NI Executive should be considering allowing a highly polluting industry into our communities and that this report is unsure of the long term damage to our air and water and thus our health, is truly shocking.

Dr Carroll O’Dolan. MRCGP. MICGP.
Health spokesperson for FFAN
[Fermanagh Fracking Awareness Network].

Northern Ireland politicians must support ban on oil and gas licenses or lose votes

Concerned community groups are stating the extreme urgency for NI politicians to ensure and guarantee a ban on oil and gas licenses in Northern Ireland [NI] or they will lose our votes. During this momentous month when the COP26 climate change conference is being held in Glasgow our own politicians are planning to undermine the very fabric of meaningful change. The NI Department of Economy [DfE] is presently in the final stages of bringing their petroleum policy to the NI assembly. This policy does not include the obvious and very necessary option of banning petroleum [oil and gas] licenses in Northern Ireland. Instead they are planning to issue licenses to two oil and gas [O&G] companies. Can you believe it?! But it is happening right now, under our very noses. We the people, for the people, can and must stop it! How? By our votes. We must tell the politicians that they will only keep our votes if they insist on a policy option that bans oil and gas petroleum licenses permanently from Northern Ireland. Our MLAs must then vote and pass this ban on petroleum licensing.

Remember that, due to our geology in NI, a petroleum license equals fracking; as there is no other commercial way to extract the natural gas here. O&G companies may say they will not use fracking during their exploration phase, but they have to use it during the extraction phase in order to make the process profitable. Methane is and remains a fossil fuel, it is not a “green” gas or a “clean” gas or a “transition fuel”. Methane (= natural gas) is 86 times more potent as a GHG [greenhouse gas] at damaging the climate than carbon dioxide/CO2. Any hydrogen produced by the O&G industry with the help of natural gas is fossil fuel hydrogen, and thus ‘dirty hydrogen’. Green hydrogen is not on their agenda. The latest IPCC report [Intergovernmental Panel on Climate Change Aug 2021] is the most up to date and definitive research document relating to climate change and fossil fuels. That report states that we are already in a ‘code red for humanity’ and that the burning of fossil fuels must stop as quickly as possible. The DfE is not using the IPCC report, if they were then they would have to accept a ban on petroleum licensing is the only rational option.

Many other countries are faced with the huge difficulty of winding down their O&G industry and trying to create new jobs for these workers. Northern Ireland is in the bizarre situation of trying to start up from scratch an O&G industry in the middle of the climate emergency! If the petroleum licenses are granted now, it is already foreseeable that in a few years’ time the NI Executive will have to try to limit/ curtail the O&G industry in order to achieve binding net-zero carbon targets. In such circumstances it is very likely the companies will cost the NI taxpayer billions of pounds in compensation by suing (and winning!) for loss of prospective earnings. That means you and I could end up paying the O&G companies and their shareholders, rather than our taxes going to fund our schools, hospitals and the future of our children and grandchildren.

The O&G industry is neither wanted nor needed in NI. They will ruin our very profitable agri-food and tourism business. Fracking has been shown in hundreds of high-quality research studies to be extremely damaging to both human health and animal health.

People often wonder how one individual can help prevent catastrophic climate change when such big players are involved. But democracy does matter and begins at home, here in NI. So let us use our votes wisely for the political parties that genuinely want to help us. Make it known to your MLAs that you are not willing to vote for a party that is planning to issue petroleum licenses.

We can ensure that COP26 is a success by starting right here and now in Northern Ireland. Vote for change, vote for a sustainable NI, vote for political parties that will ban these oil and gas petroleum licenses.

Thank you.

BFF [Belcoo Frack Free]
Farmers for Action
FFAN [Fermanagh Fracking Awareness Network]
FoE NI [Friends of the Earth]
LAMP [Letterbreen and Mullaghdun Partnership]
Love Leitrim
YACNI [Youth Climate Association]

Press statement in advance of Stormont debate

Over this past decade our particular communities have experienced first hand various attempts at oil and gas exploration in Northern Ireland, and the government sector’s system-wide inability to cope with its complexity. Now that the UK is signed up to the Paris Agreement and has made a net-zero carbon commitment, it is time to suspend, not just review, fossil fuel development.

In the interests of protecting public health and the environment from the polluting impacts of this industry, meeting our climate change obligations, and so that other communities don’t have to experience the same stress and disruption that we have, we have come together to call for the Assembly to:

“acknowledge its responsibility to protect public health and the environment and call on the Executive to instigate an immediate moratorium on petroleum licencing for all exploration for, drilling for and extraction of hydrocarbons until legislation is brought forward that bans all exploration for, drilling for and extraction of hydrocarbons in Northern Ireland.”

The motion builds on the 2015 Strategic Planning Policy Statement presumption against the exploitation of unconventional hydrocarbon extraction in Northern Ireland introduced by Mark H Durkan, and recognises the moratoria, in various forms, on fracking in England, Scotland and Wales and the ban on fracking in the Republic of Ireland.


Statement issued on behalf of Belcoo Frack Free, LAMP Fermanagh, Protect Our North Coast, Stop The Drill Campaign, Ballinlea Residents Group, Friends of Woodburn Forest, Fermanagh Fracking Awareness Network, Love Leitrim and Safety Before LNG.

Fracking may rear its ugly head again

Fracking is still being considered by the NI executive and our health is again at stake. Currently the Minister for the Economy is involved in a strategic review of petroleum licensing in Northern Ireland. If the review decides to allow licensing to go ahead this means that Fracking in Fermanagh may again rear its ugly head.  Fracking goes by many names including unconventional hydrocarbon extraction. And to make matters worse the FODC is proposing to ‘water down’ the wording in the draft local development plan [LDP] that protects us against fracking.

The current wording [MIN04 on page 127] states “The council will not permit unconventional hydrocarbon extraction until it is proved that there would be no adverse effects on the environment or public health”. The council now wants to change the second half of this sentence to ‘until there is robust evidence on all associated impacts on the environment and human health’. This is obviously a much weaker protection and leaves open the unacceptable possibility that the council can then try to regulate these ‘associated impacts’. Public health must be clearly written into our LDP when it comes to fracking.

There is a short consultation process, finishing on 11 Sept, where FODC residents can comment on these proposed changes to the draft LDP. Please send in your comment/ submission objecting to this change of wording and help protect our health, our families and the environment. For a template to send to FODC before Friday 11. Sept 2020 see below.

Template submission on proposed changes to FODC LDP [Local Development Plan]

Template submission on proposed changes to FODC LDP [Local Development Plan]

Comment on proposed changes to Local Development Plan 2030

Email  to FODC at: [email protected]

Subject:  proposed changes to the Fermanagh & Omagh District Council [FODC] Local Development Plan [LDP] 2030 Draft plan [published in October 2018]. The proposed changes to the LDP were published in July 2020.

Specifically I object to the proposed change to the Mineral section [MIN 04]

Currently in the 2018 LDP draft it states on page 127 ‘The local council will not permit unconventional hydrocarbon extraction until it is proved that there would be no adverse effects on the environment or public health’. The proposed change is to alter the above sentence to ‘The local council will not permit unconventional hydrocarbon extraction until there is robust evidence on all associated impacts on the environment and human health’.

Unconventional hydrocarbon extraction [UHE] goes under many names including fracking.

I object to any changes of MIN 04 [2018] for the following reasons.

1. The term ‘robust evidence on all associated impacts’ leaves open the possibility that despite the evidence of negative impacts on human health and the environment the FODC may still decide to allow UHE. This is possible as the change in wording allows the fracking industry and/or FODC to argue that regulation ‘of the associated impacts’ is possible. Very strong evidence from the USA has shown time and again that regulation of fracking does not work and people’s health deteriorates. I insist the original sentence remains unaltered. Public Health is central to any long term plan for our communities and must be explicitly included in the LDP with regards to UHE.

2. In the ‘Summary of Issue/ Justification’ box for the above proposed change to the FODC LDP wording it states ‘to reflect SPPS’. The SPPS [Strategic Planning Policy Statement for Northern Ireland published in 2015] is an important document and states that the SPPS should ‘be taken into account’ when local plans are drawn up. This does not mean that the FODC are not allowed to choose its own slightly different wording where appropriate. Indeed in the introduction to the SPPS document the Minister stated the vision of the SPPS was simple; to improve well-being for the people, no compromising on environmental standards and creating places where communities can flourish now and into the future. If Public Health is not explicitly written into the FODC LDP then the SPPS will not fulfil the goals as set out above by the Minister.

3. There is a huge increase in high quality peer reviewed evidence, year on year, of the definitive harm to Public health and the environment that unconventional hydrocarbon extraction causes. Thus statements of even two years ago let alone five years ago have been superseded by the evidence. See www.concernedhealthny.org/compendium compiled by USA physicians relating to the extensive harm to both Public Health and the environment due to UHE. A court ruling in the UK last year [the Dove Judgement www.frackfreeunited.co.uk/fracking-unlawful] states that National and Local Government departments can and must adapt their plans to take account of current evidence of Public health harm and/ or climate damage even if their new adaptations appear to contradict existing planning policies. To put it simply: if the evidence changes and becomes more definitive then plans [including the FODC LDP] should reflect these changes, irrespective of what older, out-of-date Government documents say.

Name: ……………………………….

Date:   ……………….

Email address: ………………………….

Address:  …………………………………………………………………

Fracking and health – professionals speak out

On 28th January at the Killyhevlin Hotel, Enniskillen, the Fermanagh Fracking Awareness Network were delighted to host a presentation by Dr Eilish Cleary, Chief Medical Officer for Health, New Brunswick, Canada. As explained in our post of 11th December, Dr. Cleary has recently produced a report about the public health implications of shale gas development using fracking. Dr Cleary was on a family holiday to Ireland and very kindly agreed to speak about her report to medical professionals, elected representatives, and concerned residents in and around Fermanagh.

FFAN

The large audience was welcomed by Dr. Carroll O’Dolan, the chair of FFAN, who thanked all who had been involved in making the event possible, especially Dr. Cleary herself and the owners and staff of the Killyhevlin Hotel. Carroll then introduced the first speaker, Gary McFarlane.

Gary was appointed as the Director for the Chartered Institute of Environmental
Health (CIEH) in Northern Ireland in late 2001 The CIEH is a national, professional, charitable organisation whose mission is to maintain, enhance and promote improvements in public health through knowledge, understanding and campaigning. As director he is involved in contributing to the development of healthy public policy, reestablishing the critical links between environment and health within the context of sustainable development and public health. Gary is also currently the co-chair of the Public Health Alliance, is a board member of Sustainable Northern Ireland and Northern Ireland Environment Link. He chairs the advisory board to the environmental
health undergraduate programme at the University of Ulster and has been appointed to the Safe Food Scientific Advisory Committee.

He spoke eloquently of his vision of health, as not simply the absence of disease but as a state of complete well-being; social, and emotional, as well as physical and psychological. Within this context, the lack of research into the health and environmental implications of fracking and shale gas exploitation is deeply worrying. The Environmental Protection Agency in the United States is at last now beginning to investigate the effects of fracking on groundwater, but it is also essential to consider its effect on soil and its indirect effects on tourism, agriculture etc. Only such a complete investigation can give anything like a full picture of the real results of fracking for human health.

The view of the Chartered Institute of Environmental Health is that the precautionary principle should be the foundation of policy in this, as in other areas. As such, any proposals for shale gas development should be carefully analysed not only by means of an Environmental Impact Assessment but also with a Health Impact Assessment. Furthermore, such a study should look particularly at the effects of the industry upon health inequalities and upon those in our society who are already the most vulnerable.

Dr Eilish Cleary, the main speaker of the evening, addressed the audience next. If there was one message, she said, that they should take away with them, it was the importance of asking questions. It is only by asking the right questions, and being determined to find answers, that we can keep ourselves and our communities safe and healthy.

Her presentation was divided into three parts: the first looking at the functions and principles of public health, the second at the shale gas industry and the third at the report which she, together with colleagues, produced in New Brunswick.

Public health as a discipline covers a wide range of functions including measuring and monitoring the health of individuals within society, preventing disease and injury, preparing emergency responses, and protecting the health of the public from the many hazards which assail it. The prerequisites for good health have been identified as peace, shelter, education, food, income, a stable eco-system, sustainable resources, social justice and equity. If any of these are lacking, it becomes difficult or impossible for an individual or a community to achieve or maintain a truly healthy life. In common with other disciplines, public health recognises the ‘three-legged stool’ model of sustainability, that it depends upon environmental, social and economic factors, and that unless all these areas are nurtured, a society cannot be said to be sustainable.

In a complex world, much of public health work is necessarily concerned with risk management. When faced with potential or actual damage, disease or injury, there is a range of responses that may be taken. Earliest, most effective and least expensive is prevention, making sure that the damage does not occur in the first place. If this is not carried out, then less effective and more expensive paths must be taken; mitigation, response or recovery and remediation.

Within this context, Dr Cleary then went on to consider the risks to human health which are posed by shale gas development. There are several pathways by which humans can be exposed to contamination caused by the industry, principally inhalation (breathing in toxic substances), dermal contact (through the skin), ingestion (eating or drinking contaminated food or drink) and maternal (the exposure of an unborn child to contamination while in its mother’s womb). Each of these pathways can bring people into contact with different types of contamination. For example, machinery and vehicles involved in shale gas activities produce several different types of toxic emissions including particulate matter, carbon monoxide and nitric oxides.
The effects of the various types of contamination on health are wide-ranging, including reproductive, dermal (skin), and haemologic (blood) disorders. Full details of the pathways, types of potential contamination and their effects can be found in Dr. Cleary’s report here.

Faced with this type of problem, Dr. Cleary suggested that the conventional way of looking at the situation is fundamentally flawed. This traditional approach tends to begin with the industry and its processes, then considering its effect on the environment and finally upon public health. Suppose we instead began with the requirements for a healthy population, those factors identified earlier as including peace, social justice, a stable eco-system and sustainable resources? Then proposals for industrial activity could be more accurately assessed according to whether they contributed to, or destroyed, those fundamental building blocks of health.

Sadly, we are a long way from such an approach today. The situation that Dr Cleary was faced with in New Brunswick was that the government had already made the decision to go ahead with shale gas extraction. The question that she was faced with, therefore, was not whether or not such activities should be carried out – that one had already been answered by others – but what measures could push the situation in the direction of being a net benefit, rather than a loss, for the health of New Brunswick’s people.

Given both the constraints of this situation and the lack of research and evidence available, it was not possible for the New Brunswick report to be a complete overview of all the public health impacts threatened by shale gas development. Instead, it was more a survey of what is currently known upon the subject, and, perhaps more importantly, what is not known. There are a disturbing number of data gaps including the health status of affected populations, details of their exposure, information about the toxicity of chemicals used in the extraction processes and those contained in waste products, health impact assessments, forecasting and analysis of the cumulative and lifestyle impacts of the industry’s activities and their consequences. One of the most significant achievements of Dr. Cleary’s report is in identifying these gigantic holes in what is currently known about shale gas and human health.

A particular problem related to shale gas extraction is that the industry typically begins in any location on a very small scale but that development thereafter is extremely rapid. This speed of growth, and the inevitable implications for the health of local people, requires proper planning before the first development; it is not sufficient to rely upon ad hoc measures as the activity increases.

In line with the general pattern of absent information, there is little clear data from locations where shale gas extraction is already underway. There are, however, certain common themes which emerge from the evidence available. These are: physical accidents occurring on and off-site, air and water quality problems, a loss of community cohesion, the boomtown effect and mental health issues. It is important to note the breadth of these problems and that the difficulties related to shale gas exploitation are emphatically not only those of chemical toxicity.

To date, public health experts and officials have been largely absent from the discussions about fracking and therefore unable to present their concerns. These, in addition to the direct impacts, would include the inequitable distribution of risk and reward in the industry, and the potential risks to economic well-being, to governments, to the environment as well as those to public health. The life-cycle of the shale gas industry is not yet clear; there are widely varying estimates as to the length of time for which a well would be viable but it is likely to be short in the context of a community’s experience and the well-being of future generations.

Mistakes in this industry can be very large and very costly and it is therefore not enough simply to have rules which regulate its activities. Dr. Cleary’s recommendations to her government therefore included the setting up of various consultative and overseeing projects and groups, a genuine dialogue between communities, governments, academics and the industry, an effective role for local government, the public reporting of data and a balanced distribution of the risks and rewards.

She closed by emphasising that final decisions have to be made by the communities who would have to live with shale gas exploitation and its consequences.

Questions were invited from the audience and these were numerous and detailed, including issues of water contamination, the length of time needed before public health effects would be assessed, the unlikelihood of claims that fracking could be carried out ‘without chemicals’ and the implications of the industry’s exemption, in the United States, from key environmental legislation.

A statement was read on behalf of Dr. Geralyn McCarron, a GP originally from Fermanagh and now working in Australia, who has witnessed the severe health problems created by the shale gas industry in Queensland. Her statement was featured in our last post and is available here.

Further questions concerned the proposed study by the Irish Environmental Protection Agency into the feasibility and consequences of fracking in Ireland, and the absence from its draft terms of reference of any health impact assessment, the possibility of pilot projects, the need for, and general absence of baseline studies and the fact that, to date, the New Brunswick government have not implemented any of Dr. Cleary’s recommendations. There was some criticism of Dr. Cleary for her clear position, stated at the outset, that she would not enter into the political debate as to the general advisability of otherwise of shale gas exploitation, but that her role, as she saw it, was the provision of information.

Some criticism was also made of FFAN for discussing issues of regulation rather than simply calling for an outright ban on fracking. FFAN’s position is that shale gas exploitation using fracking is a dangerous and unnecessary activity which should not go ahead in Fermanagh or elsewhere. In order to achieve this end it is vital to inform the public and other decision-makers of all the issues and potential effects of the industry. Ultimately it is the responsibility of local people to decide whether or not they want fracking in Fermanagh. If they do not, each individual needs to speak out clearly to ensure that his or her voice is heard by those elected to represent us.

Finally, closing remarks were given by Dr John Graham, who is a retired public health physician who has moved back to Fermanagh having grown up there and trained at Queen’s. He was a health service chief executive in Germany and the Middle East and worked as a medical policy director in Whitehall. He commissioned a major international epidemiological research programme to investigate Gulf War Syndrome and worked in Washington DC for the White House in collaboration with the Institute of Medicine.

John drew upon his own experience in relation to Gulf War Syndrome to emphasise the vital importance of obtaining firm evidence before irrevocable decisions are made and in particular the necessity for the Irish EPA and any other reporting body to include health impact assessments in their analysis.

The evening was a valuable opportunity for people in Fermanagh and beyond, especially those concerned with public health, to discover more about the potential side-effects of shale gas development. In particular, Dr. Cleary’s presentation encouraged the audience to become more aware of the gaps in our current knowledge and the need for comprehensive analysis of medical, environmental, social and economic factors before potentially disastrous decisions are made. FFAN are grateful to Dr. Cleary for giving up her valuable personal time, while on holiday, to speak on this subject, to the other speakers, the Killyhevlin Hotel and to all who attended the event.