Unfortunately, I cannot use my Powerpoint presentation because the IT system is not working. I will skip through some of the slides quickly. As the members of the committee have hard copies of the presentation, they can follow me as I go through it. The third slide shows the scope of our work. We undertook a technical research programme. There were no political, economic or considerations in the study. There were five projects. We had two study areas, one in County Clare and the other on the Border in counties Leitrim, Sligo, Cavan and Fermanagh. Our approach was based on evidence. We used peer-reviewed data. We got information and data from regulatory bodies. We looked at the regulatory structures. We used our own experience and knowledge of the industry. We did not take any information from newspapers, social media, anecdotes or Hollywood.
Members will see the slide that sets out the structure of the five inter-linking projects in the EPA's scope of work. In projects A1, A2 and A3, we looked at the specific impacts on water, seismicity and air quality. In the fourth project, we looked at the impacts of unconventional gas exploration and extraction projects around the world, the mitigation measures taken as part of those projects and the success of those projects. In the final project, we looked at the regulatory framework in EU and Irish law and in other jurisdictions. We examined these matters in the context of the two study areas. We looked at the EU requirements and we studied what is going on in other jurisdictions. It was quite a broad project.
The next slide indicates that the consortium was led by CDM Smith and was supported by the British Geological Survey. University College Dublin and the University of Ulster were involved in the seismic activities. The consortium also included Amec Foster Wheeler, which has done a great deal of work for the European Commission on regulation and best practice in fracking. Philip Lee offered us local expertise regarding the regulations in Ireland and Northern Ireland.
I will not go through the description of the individual projects. I will move on to the slide entitled "potential impacts", which sets out how the fracking process is divided into four main stages for our purposes. Unconventional gas exploration and extraction projects typically last between 15 and 25 years. The first stage we normally look at is exploration. We split that into two parts: baseline monitoring and characterisation, which is fairly benign, and test hydraulic fracturing. As test hydraulic fracturing is new and rather different, we pulled it out as a separate entity. The second stage, which applies if it is decided to proceed with fracking, involves a great deal of activity on pad development and the development of infrastructure such as roads, water pipelines and wells. The third phase is the production stage, when all of the development goes away and the field starts to produce gas. The fourth stage involves a closure exercise. Our analysis of the impacts across these four stages was based on five reports, which we drew from an awful lot of information.
Members will see that a number of slides feature pretty tables, or not-so-pretty tables. These simple tables rate the potential impacts of the activities in each phase of the fracking process and assess whether those impacts are normal from the perspective of society. It is not unusual to be building a road or a pad, for example. It is unusual, from the perspective of society and the regulations, to be doing hydraulic fracking so it is going to be a bit of a problem. We looked at whether the regulations that apply to each activity need modifications or additions. If I had more time, I would go through the various tables to illuminate what we found. I can do that by reference to the conclusions.
The first slide dealing with conclusions follows all the tables to which I have referred. The first conclusion we came to is that fracking projects and operations involve multiple activities which have the potential to affect human health and the environment in different ways. The relative importance of these impacts varies from place to place, because these projects are very site-specific, and with time. As I have said, many of the activities are conventional in so far as they involve things that happen frequently. People build roads to allow materials to be transported and install pipelines to transfer water. Much of this activity is fairly typical of society and of behaviour across many industries and is therefore well regulated. There is a lot of regulation in place and the mitigation measures are quite well developed.
I ask members to turn to the next slide dealing with conclusions. When we looked at other jurisdictions, we found that the operational requirements and therefore the practices that are going on are quite different from country to country. That is a reflection of the fact that this is a new industry that is evolving rapidly, especially in the US. We noted that the regulatory environment in the US differs significantly from that in Europe, partly because the US authorities approach things differently and partly because ownership issues are completely different there. In the US, the resource is owned by the landowner rather than the state. This means the landowner has a much bigger incentive to get involved. That is a fairly basic difference. Many of the more damaging practices in the US would not be allowed in Ireland because of EU regulations. I refer to the use of open-wastewater lagoons, for example, or to practices like flaring and deep underground reinjection. Many of the bigger problems in the US simply would not be allowed here under EU regulations. It is quite ironic that industry best practice - the United Kingdom Onshore Oil and Gas group, for example, has developed best practice guidance in this area - addresses many of the issues that are raised by stakeholders. There is a nice body of work there that should be incorporated in the regulations if this goes ahead. The industry has set out what it is prepared to do. I suggest the public authorities can achieve a great deal of benefit from holding the industry to that.
In the next slide dealing with conclusions, we set out our view that many of these activities could proceed in Ireland without causing too much damage to the environment or to health as long as the best practices we have identified in the report are followed and current regulations are applied with a small number of additions and modifications. This needs to be complemented by adequate implementation of the regulations by the industry and enforcement of them by my friends in the EPA.
We are of the view that an unsatisfactory risk status is still attached to three impacts. We could not say that mitigation measures would work in these contexts. I have listed the three impacts in question on one of the slides. We believe there may be a risk of groundwater pollution from failed boreholes, of groundwater pollution caused by gas migrating through the cracks created during fracking, and of emissions after the closure of the wells. We did not have enough evidence to say that problems would not arise in these areas. In our view, there is still a problem. I will go through the three risks individually. When we say there is a risk of groundwater pollution from failed borehole integrity, we are referring to the possibility of the pumped materials going down leaking into the aquifers. It is also possible that the returning gas or the production waters - the deep waters that naturally come out of rocks and are usually highly polluted - could leak out as well. If the well fails, there is a problem.
When one engages in fracking, one creates cracks. Fracking releases gas into the well. Potentially, those cracks could be a route for migration of gas and polluted water. There is quite a debate about how long those cracks might be. The industry will say they are 10 m or 20 m in length, but a great deal of data points to the possibility that they are over 200 m in length. We think they might extend to 300 m in extreme conditions. We know from the statistical analysis we use that they could theoretically extend to 500 m if long cracks can go vertically from the oil-bearing strata to the aquifers. If these cracks extend to the aquifers, the possibility of gas and pollutant migration presents itself. That is worse if there are existing faults that link in with the natural cracks as a sort of double-whammy.
The third unsatisfactory risk is the possibility of post-closure gas emissions. Things should be straightforward when all the gas is out and the well is capped, but that is not the case. There are international examples of leaks from conventional and unconventional wells. In principle, the design of these elements should be straightforward. It should be easy enough to do, but leaks can happen. We cannot say it is not a risk. The levels of gas emissions from a well are typically low, but if there are gas emissions from a number of wells over a long period of time, those levels can be significant.
They are the three issues that we really highlight as being problems. We suggest they should be addressed by anyone who wants to do hydraulic fracturing. They can be addressed, to some extent, by baseline monitoring. If we had baseline monitoring of water and seismicity for the two study areas, we could say with a lot more certainty how likely it is that gas and pollutants will migrate from the wells to the aquifers.
Similarly if there is going to be any seismic activity, seismic surveys will be done before anything happens to provide us with better knowledge of the sub-surface geology and hydrogeology. The structure of the geology and hydrogeology, which is the way water moves around, is fundamental to two of these issues. If the data are there ahead of time, there is a reasonable chance of being able to say whether we think it is a problem but that cannot be done without the data. In a sense, we will not know the long-term gas emissions because they are long term. There are ongoing studies but it will take a long time to find out. If countries want to proceed with this, there is no reason why the design cannot be well specified and well implemented. The testing of the closing procedure could be done and then linked to long-term monitoring. We would recommend a bonding issue so if there are problems the operators pay rather than the Government. They are the three activities the Government could move forward on to make it a more satisfactory industry.
The last issue is the regulatory environment. Many regulations have come out of the EU. They are widespread and are quite applicable to these types of operations but there are some deficiencies and ambiguities on which clarification is needed. One is the mining waste directive which the EU is clarifying. There are issues associated with the reuse of wastewater. Wastewater is not supposed to be re-injected. The argument is that the water that has been injected down and comes back as part of the fracking process is wastewater. If it was to be reused, there would be a much lower demand for water and the water resource, which is a concern. That is an issue we felt need clarification. It is not clear in the environmental impact assessment directive what scale of projects that should be applied to. In Denmark, they have taken a view that all fracking projects, whether only for exploration or not, have an environmental impact assessment. Similarly, it is not really clear at what scale the strategic environmental assessment, SEA, should be. If one was doing an exploration well or a few wells, one probably would not do it but if one was going to do the whole of the northern carboniferous basin throughout Leitrim and Fermanagh, then an SEA is needed. The application of SEAs needs to be clarified. Extraction licensing in Ireland needs to be strengthened because there is such significant water demand in this industry. The European Commission has developed recommendations for this industry and it attempts to cover the gaps in the existing regulations. It is quite good and covers most of those gaps. We think it should be included in guidance. Similarly, the best practice coming out of industry should be included in guidance. With those two together, with the existing legislation, the Government can go a long way to controlling this industry quite well.
We were asked to look at what role health impact assessments might have. They are not well developed in Ireland. Hydraulic fracturing is a new industry. Those two things do not go together very well. There is not much data. We thought the best approach would be to incorporate health impact assessments within the EIA as a best practice requirement for this industry.
I am pleased to take any questions the committee has.
