We would like to thank all signatories to our open letter that asked the Government to replace the current moratorium on high volume hydraulic fracturing with a ban on all well stimulation for oil and gas exploration and production.
Mr Kwarteng’s letter doesn’t respond to the issues carefully detailed in our letter to him. The documents cited within his response have been referenced in our in-depth legal brief that was attached in our letter. This brief is based on months of research into the regulatory framework, co-authored and signed off by leading environmental firm, Harrison Grant.
The response is a polite but firm refusal and a dismissal of our concerns. Specifically on acidisation, it is true that the Environment Agency regulates this area, but the EA has failed to clarify the boundaries between well maintenance techniques and acid stimulation – a fracking-like technique. As it stands, permits and exclusions are granted based on the oil and gas firms’ stated intent, which results in insufficient restrictions, reporting and monitoring to guard against acid stimulation taking place under the guise of well maintenance. The EA’s regulatory position remains opaque, with no clarity whatsoever over where the boundary between unacceptably dangerous acid stimulation and routine well maintenance lies.
Confusion also remains with respect to which operations require hydraulic fracture plans, while the ministerial statement on the moratorium on fracking referred to by Mr Kwarteng refers to hydraulic fracture plans as well as to hydraulic fracture consents – two different regulatory consents that apply to operations of different scope. This highlights the many inconsistencies in the legal and regulatory framework for hydraulic fracturing and the need for an expanded ban for all well stimulation treatments.
We also believe that investment in the post-covid recovery should be in line with climate change targets and therefore on green energy, not domestic oil and gas, involving acid stimulation or otherwise. Given the drop in demand, it would be an easy win for the Government to look proactive on climate change by switching their focus to renewables.