Energy  

Can Fracking ever be successfully regulated in Ireland so as to provide an environmentally, socially and economically safe source of indigenous energy?

Given the serious environmental problems caused by the extraction of Shale Gas in the USA, it is important that we pose questions about the ability of the Authorities to create and police the set of regulations that need to be applied to the entire extraction process  of ‘Shale Gas’ on the Island of Ireland.

There are three phases to the exploitation of Shale Gas in Ireland.

1. The first phase is the application to and issuing Onshore Licensing  Options, which are meant to produce information. By late 2012 or early 2013, an the assessment of the  petroleum resource potential for the area must be provided along with costed plans for further exploration or exploitation.   This phase will not include fracking but may include ‘shallow geological sampling’ (drilling to 200 metres).  We question why this phase does not require Planning Permission and the usual EIA’s etc.   
2. The second stage is the application for an Exploration License, which does involve drilling  and may involve test fracking.  We take it will require Planning Permission for each drilling site – which will according to Minister Rabbitte,  require an Environmental Impact Assessment.
3. The Third Stage is the exploitation stage, which will not only require a number of wells and associated fracking infrastructure but also a system of gathering pipelines and infrastructure to deliver the gas to the grid.  All of which will require Planning Permission.

The current licences are for phase one and we therefore have 12 to 18 months in which to ensure that a full and rigorous set of regulations is put in place before there is any drilling or fracking under exploration licences. The process of creating these regulations  must include full public participation and must take into account a realistic view of the authorities’ ability to police the regulations. We also need to determine if there are specific requirements in  the Environmental Impact Assessment.

We should follow the State of New York and ensure that no licences for fracking (exploration or exploitation) are issued until the state adequately examines all the risks and ensures that appropriate, enforceable safeguards are in place.  A good place for Ireland to start would be the examination to be undertaken by the State of New York and the safeguards it derives. 

The threats to the environment from leaking gas and the chemicals used in fracking are real.  The people are entitled the information on this and to participation in the decision making to ensure that any exploration  or extraction of Shale Gas is environmentally, socially and economically safe.  

If we cannot show that the safety of the people and the environment can be safeguarded, then fracking should be banned.

Meanwhile, we are calling on Minister Pat Rabbitte to:

1. Organise public consultation to explain the current situation.
2. Follow The State of New York and issue no licences for Fracking unless/until he can ensure that enforceable safeguards are in place.
3. To be able to assure the people  that if fracking to be undertaken in this island, that he has in position the regulations and enforcement powers to ensure that it will be carried outwithout environmental, social or economic harm.

1. What is our a medium to long term exit strategy from gas?
2. What effect will local Shale Gas have on Irish Energy  Security?
3. What effect will local Shale Gas have on economics of Renewable Energy?
4. Each licence should be treated as a 'Project' - to ensure it is treated 'holistically' and that  the interfaces between CER, EPA & ABP are properly accounted for.
5. Do we need to develop  specific questions that must be answered in an EIS/EIA in an application to frack?  Transparency - we need to know that the right questions are being asked/answered.
6. How will the Government assure us that it is keeping abreast with Fracking Regulations/Debate in Europe & US?
7. In order to be aware of what could be at risk from HF with chemicals,  the government should establish an assessment group to assess the risks associated with HF with or without chemicals.  The group could visit the States and see HF sites, speak to developers, EPA inspectors, the Dept of Environmental Conservation of NY State Government, speak to environmental NGOs, speak to landowners and communities.  The group should be comprised of the following:
   1. CER health and safety
   2. Dept. of Energy
   3. Dept of Environment
   4. EPA
   5. Dept of Agriculture
   6. Environmental NGO / An Taisce
   7. Community Representative
8. We need to understand its effects on the water systems of the Country?
   
   1. Where the water for the pressurized process come from?
   2. The proximity of the Shannon - already a major source of water in the Country and under suggestion as a source of water for Dublin.
   3. Chemical laden water injected deep underground - it  is an extremelly difficult, not to mention risky, process to frack without leaking polluted water in to aquifers and surface water systems.
   4. Even at higher pressure and without added chemicals - what else could fracking bring up from below - Radon and other radioactive gases? - Volatile Organics such as Benzene?
9. We also need a plan from Bord Gais as to how they will develop the natural gas grid to deal with the movement of gas in the future.
10. The option holders must provide 'an integrated assessment of the petroleum resource potential of the area together with strategies, scoping economics and costed plans for further exploration / exploitation'.  Who wil this information be available to?  Who will decide if it is commercially viable to go ahead?

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