Open letter to the Government: Stimulation of oil and gas wells - reforms required
(Update: the letter was published online on 2 Nov 2019, following the Government's announcement of a partial moratorium on fracking. It will be sent to the new Government, along with a full list of signatories, when the relevant heads of departments are confirmed.)


Rt Hon Andrea Leadsom MP
Department for Business Energy and Industrial Strategy
1 Victoria Street
London
SW1H 0ET

Rt Hon Theresa Villiers MP
Department for Environment Food and Rural Affairs
Seacole Building
2 Marsham Street
London
SW1P 4DF

Rt Hon Robert Jenrick MP
Ministry of Housing Communities and Local Government
2 Marsham Street
London
SW1P 4DF
United Kingdom

Copy to:
Dr Andy Samuel, Chief Executive, Oil and Gas Authority
Sir James Bevan, Chief Executive, Environment Agency
Sarah Albon, Chief Executive, Health and Safety Executive

2 November 2019 (published online)


Dear Ms Leadsom, Ms Villiers and Mr Jenrick
Stimulation of oil and gas wells: reforms required
We, the undersigned individuals and organisations, are writing to you to request legal and policy reform on the issue of the stimulation of oil and gas wells, including acid stimulation.

The climate change and other environmental concerns surrounding high volume hydraulic fracturing are well known. We share these concerns and consequently support a ban on such activities.

However, the focus of this letter is on the less publicised issue of well stimulation using acid and other techniques to enhance the productivity of onshore oil and gas wells.
Climate change, environmental and health impacts
Many of the acids and other chemicals used in well stimulation are potentially hazardous for the environment and human health and, while there are few UK studies examining the risks and impacts of their use, studies conducted abroad suggest that many of the risks and concerns surrounding hydraulic fracturing are the same as for acid stimulation, namely induced seismicity, air and noise pollution, groundwater contamination and industrialisation of the countryside.

Furthermore, the climate change implications are equally as problematic for all forms of well stimulation, and include the release of methane (a highly potent greenhouse gas) and the release of carbon dioxide during the consumption of the oil or gas extracted.
Legal loopholes and poor regulation
Despite these impacts, many of the legal and regulatory constraints that apply to hydraulic fracturing do not apply to acid stimulation or are ambiguous as to whether they apply. This is because:

i) the controls introduced by s.50 of the Infrastructure Act 2015 and the 2016 Regulations governing protected areas only apply to fracturing involving large volumes of fluid;

ii) the Oil and Gas Authority, responsible for managing the risks of induced seismicity in particular by requiring a hydraulic fracture plan (HFP), do not clearly define when an HFP is required and has given evidence to the Committee on Housing, Communities and Local Government that conflicts with its own guidance;

iii) the Environment Agency, which oversees the environmental permitting regime, has failed to clarify the boundaries between acid stimulation and well maintenance techniques, thereby risking acid stimulation taking place under the guise of maintenance techniques with insufficient restrictions, reporting and monitoring in place to guard against this;

iv) site inspections that are mandatory for high-volume fracturing are not required for other forms of well stimulation and the Health and Safety Executive’s agreement with the EA for meetings and the inspection of “hydraulic fracturing” sites does not define what activities are included in this regime;

v) although the minerals section of the National Planning Policy Guidance contains a definition of hydraulic fracturing that is broader than the Infrastructure Act 2015, it lacks clarity and is still too narrow.

These issues are detailed at length in the enclosed briefing of Brockham Oil Watch (BOW).
Legal and regulatory reform
In light of the above we call on the government to:

1. Ban all well stimulation for oil and gas exploration and production.

In the interim, to:

2. Amend the definition in the Infrastructure Act 2015 to include all well stimulation treatments which may enhance the productivity of oil and gas wells by increasing the permeability of the target rock.

3. Require all regulators of the oil and gas industry to apply the above definition consistently across the regulatory regime to ensure that requirements applicable to high-volume hydraulic fracturing apply to all onshore well stimulation treatments.

4. Amend the Minerals NPPG to:

a. replace “hydraulic fracturing” with “well stimulation”, including at para.129 and amend the definition at para.129 in line with the proposed Petroleum 1998 Act definition; and

b. clarify that para.130 is only one form of well stimulation technique.

For a full list of recommendations see BOW’s enclosed briefing paper.

We look forward to receiving your response to our concerns and recommendations at the earliest opportunity.


Yours sincerely




[Encl. https://brockhamoilwell.files.wordpress.com/2019/11/acid-stimulation-fracking-by-stealth_rev14-2.pdf]

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