N.B. Commission on Hydraulic Fracturing
Marysville Place
P. O. Box 6000
Fredericton, N.B. E3B 5H2
Dear Commission Panel Members:
The Sustainable Energy Group (SEG) was established in 2004 as a nonprofit organization for the purpose of raising public awareness about renewable and environmentally sustainable options in energy production, distribution and use. SEG has responded to previous invitations, including Government Innovation Week in 2015; Responsible Environmental Management of Oil and Gas public consultation headed by Louis LaPierre in 2012; NB Energy Policy Commission in 2011; Day 2 Point Lepreau Hearing in 2011, and other relevant energy related initiatives over the years.
SEG supports the submission made by the NB Anti-Shale Gas Alliance to this commission and is adding further considerations that may or may not have been addressed to date.
Climate Change
In 2014 Sir Robert Watson and a team of thirty climate experts laid out a step-by-step action plan on how to meet the global warming limit. Meeting the target of keeping global temperature from rising above 2C by 2050 is still possible, according to the leading climate and energy experts that authored the report Tackling the Challenge of Climate Change. The report was presented at the special UN climate summit in New York in September 2014, called by Secretary-General Ban Ki-moon. It concluded that staying under 2C needs “immediate, urgent action” at the highest levels of governments. Link: Tackling the Challenge of Climate Change (AOSIS) (PDF)
Watson, a former scientific advisor to the UK government, rejects any suggestion that 2C is an inappropriate target, saying it “plays into the hands of climate deniers” and would be a step backward from the urgent action that’s needed. “Waiting until 2025 or 2030 to bend the CO2 emissions curve will be too late to meet the 2C target,” he said.
Watson pointed out that the steps needed to achieve 2C are not “rocket science: They include increased energy efficiency in all sectors – building retrofits alone can achieve 70-90% in energy reductions – and an effective price on carbon that reflects the enormous health and environmental costs of fossil fuels. Massive increases in wind, solar photo voltaics (PV) and other renewable technologies are crucial.
Watson worries that time is rapidly running out, and yet “people aren’t scared enough” to force governments to act. The number of influential people calling for action on climate is, however, growing steadily.
For example, Mark Carney, the former Governor of the Bank of Canada who now is the Governor of the Bank of England, said in a 2014 World Bank seminar “The vast majority of reserves are unburnable,” if the world is to avoid catastrophic climate change. He called them “stranded assets,” meaning they are seemingly valuable to investors, but will ultimately not be exploitable.
Thinking of hydrocarbon deposits as stranded assets has gained prominence in recent years. Climate science indicates that if the world is to cut carbon dioxide (CO2) and methane (CH4) emissions enough to avoid disastrous global warming, much of the world’s already discovered oil and natural gas reserves must remain underground. The GHG emission with natural gas is methane, which could have a major impact on emissions in New Brunswick, if shale gas development is adopted.
Speaking to an audience of corporate interests and pension fund investors, Carney referred to a “tragedy of horizons” – the market failure by which actors, including investors, energy companies, and governments are not looking far enough ahead to the coming environmental problems, even though they can be clearly foreseen. Link (expired November 2018).
Almost half of the world’s most powerful corporations are in the fossil fuel sector. They have extraordinary influence on government policies. Robert Watson calls this influence “a form of corruption” preventing the necessary action on climate. In countries like the US, Australia and Canada, industry leads and government follows.
Environmental author, Naomi Klein in her latest book, This Changes Everything, writes “Our economic system and our planetary system are now at war. …What the climate needs to avoid collapse is a contraction in humanity’s use of resources; what our economic model demands to avoid collapse is unfettered expansion. Only one of those sets of rules can be changed, and it’s not the laws of nature.”
Update on the U.S. Environmental Protection Agency Report on Fracking
During the last week of October, 2015, the EPA’s Scientific Advisory Board review panel — a group of scientists, engineers and industry representatives — converged on the Washington Plaza Hotel for meetings. On short notice, and to the surprise of EPA and the assembled panel, residents of Pennsylvania, Wyoming and Texas who have refused to be silenced by the industry also showed up, putting names and faces to the thousands of people harmed by fracking. One by one, Ray Kemble and Craig Stevens from Dimock, Pennsylvania, Ron Gulla from Hickory, Pennsylvania, John Fenton from Pavillion, Wyoming and Steve Lipsky from Parker County, Texas told their stories. Each was forced to condense five to ten years of anguish over the industry’s rapaciousness and over their government’s neglect into just five minutes.
The EPA had long abandoned its investigations in Dimock, Pavillion and Parker County, Texas, leaving the communities with contaminated water. And inexplicably, the EPA had excluded their “high-profile” cases of contamination from the assessment. One by one they demanded that the EPA include the truth about what happened in their communities in the assessment. Their testimonies struck a chord with the panelists. And this chord resonated with the absurdity of the Administration’s topline claim that the impacts are not “widespread, systemic.”
In a cathartic moment, toward the end of the second day, one of the panelists offered up a rewrite of the study’s major findings that captured all of these sentiments, and the panelists erupted in applause. It is safe to say the Obama Administration was not expecting rapturous applause from the panel in support of turning the top line finding on its head. The panelists are also recommending that, at the very least, the EPA provide explicit summaries of what happened in Dimock, Pavillion, and Parker County. Link: http://www.foodandwaterwatch.org/insight/how-wheels-fell-epa%E2%80%99s-fracking-study#.Vjir9qWIbT4.email
Update on Methane (CH4) Leakage from Shale Gas Operations
There seems to be wide agreement that the best scientific information should help guide decisions on shale gas. Robert Howarth of Cornell University Department of Ecology and Environmental Biology has just published a report that clearly meets this standard: “Methane Emissions and Climatic Warming Risk from Hydraulic Fracturing and Shale Gas Development: Implications for Policy.”
The Howarth report documents a new level of accuracy in measuring methane leakage from shale gas operations. By way of contrast, the recent Fraser Institute Bulletin, Managing the Risks of Hydraulic Fracturing (PDF), does not reference this advance in research, nor does it include methane leakage in its list of five risk factors, although it is briefly mentioned in the section on air pollution.
According to Howarth, new and more accurate measuring techniques indicate methane leakage from shale gas operations is much larger than previously assessed. This is important information for understanding the climate warming risk of shale gas development and the control of greenhouse gas emissions overall.
The difference between the Fraser Bulletin and the Howarth report on methane leakage is instructive. The former gives a general 3% leakage figure that dates from earlier research, some of which is based on industry data, and then simply says, “… the risk can largely be solved by existing, cost-effective technologies.” The Bulletin offers no evidence to substantiate this latter claim.
The Howarth report, however, documents current leakage in various geographic zones of shale gas development and explains the impact of these emissions on the risk of increasing climate change. In major shale gas test areas, new measurements show methane leakage from 9.5% to 12% at the drilling and extracting sites.
There is also general agreement that it is normal for another 2.5% leakage to occur “downstream” during storage and delivery to customers. Howarth concludes that methane leakage from shale gas operations is a critical factor in the human contribution to climate change.
Although climate change risk is a global condition, it is also directly relevant to NB. The NB government is committed to a Climate Action Plan that reduces greenhouse gas emissions. In addition, the government of NB is committed to the greenhouse gas reduction targets that were agreed to at a recent conference of Atlantic provincial premiers and New England state governors. Under current industry conditions, expanding shale gas extraction in NB will increase the province’s contribution to greenhouse gas emissions and the risk of climate change.
We might ask, can’t industry stop the methane leakage? Apparently not, or they would have done so since methane is their product and leakage means loss of revenue and profit.
Currently, NB has around 50 active and inactive natural gas wells. According to current projections, at least 2000 wells would be initially required to exploit NB’s shale gas potential; beyond that, additional wells would have to be continually drilled and fracked to compensate for the rapid depletion that is normal for new shale gas wells. The more wells, the greater the volume of methane leakage. As wells age they tend to leak more and more methane. Studies are now showing that abandoned wells, even when “sealed,” often continue to leak methane. Link (expired November 2018).
Methane is 100 times more effective at trapping solar heat than carbon dioxide, but it dissipates in the atmosphere within twelve years. This means that cutting down and preventing methane emissions will have a rapid effect in helping to hold down global warming.
Climate action policies generally focus on reducing carbon dioxide because our economy produces so much of it. But CO2 remains in the atmosphere for hundreds of years so mitigation will be a long slow process. Action on CO2 is, of course, important but, according to Howarth, stopping the increase in methane emissions by foregoing shale gas development addresses climate change mitigation in an even more critical way.
We understand that the NB Commission on Hydraulic Fracturing must deal with complex and sometimes inconsistent information, but the Howarth report on the science of methane emissions from shale gas operations at least provides clarity on the greenhouse gas and climate change issue at this time.
A Note on Natural Gas as a Bridge Fuel
Natural gas when burned emits the lowest amount of carbon dioxide of all fossil fuels. On the strength of this fact, natural gas is being promoted as a “bridge fuel” that will help reduce carbon emissions during the time it takes for renewable energy to get ramped up to full potential.
Scientific research, however, is now showing that natural gas, under current circumstances, is not a bridge fuel. Research findings documented in the Howarth report cited above show that methane leakage from hydraulic fracturing operations wipes out the advantage of natural gas as a cleaner burning fossil fuel.
Under current industry conditions, the use of natural gas is no better than other fossil fuels, and, according to Howarth, possibly worse depending on the rate of methane leakage associated with its production, storage, and transport.
The policy implication of this research for controlling greenhouse gases and climate change, is that the development of natural gas production from hydraulic fracturing should be stopped.
This is discouraging news for those who have been arguing that, among other benefits, an expanding shale gas industry in NB would actually contribute to greenhouse gas reduction and global warming mitigation. Within the context of current research information, this argument can no longer be made.
The good news, however, is that the fossil fuel bridge to a clean energy future will likely be much shorter than previously expected. Within the last several years the cost of renewables have plummeted and the scaling up of renewable energy systems is moving with dramatic speed.
Economics is turning the tide. According to Christiana Figueres, head of the upcoming Climate Summit in Paris, 2.6 trillion dollars has already been invested in renewable energy and much more is on the way. Link: Can Paris talks produce a climate change deal that sticks? (PBS NewsHour)
Investors are paying heed to Mark Carney who has repeatedly warned that fossil fuels are fast becoming stranded assets, and that smart money should look elsewhere for investment security.
Understanding the situation historically, our economy has been developed and is largely running on fossil fuels – coal, oil, and natural gas. Plotting our energy transition into the future, we see the use of these fossil fuels as steadily diminishing and renewables gaining in capacity and system flexibility.
This period of diminishing fossil fuel use is the “bridge.” In this context, all fossil fuels are “bridge fuels.” The question is, what is the balance and how long will the “bridge” be before it tapers off into a fully developed renewable energy landscape. Action on limiting greenhouse gas emissions and implementing fully developed climate change policies will aim to make the “bridge” as short as possible. In the light of current research, this means no more shale gas development.
Seven Conditions to be Addressed Before any Further Consideration of Unconventional Oil and Shale Gas Development in New Brunswick
The Sustainable Energy Group requests a continued moratorium on unconventional oil and natural gas development in the Province of New Brunswick and that the following conditions be fully addressed before any further consideration of hydrocarbon development.
- Implement the “30 recommendations that the Chief Medical Officer of Health believes are necessary to address the key findings and to protect or enhance population health through appropriate management of the shale gas industry.”
- Addressing Climate Change
a) Publicly commit to and meet the two concurrent Climate Change Action Plans that the previous premier and the present premier have signed, along with the Eastern Provinces premiers and the New England state governors to:
• “Reduce GHG emissions by 10 percent below 1990 levels by 2020.”
• “Reduce GHG emissions by 75 to 85 percent below 2001 levels by 2050.”
b) Publicly commit to and meet any national and international climate change mitigation agreements made on greenhouse gas emissions to meet the 2-degree limit on global temperature rise this century. - Set targets and create programs for increasing renewable energy infrastructure, green building construction, and energy efficient retrofitting of existing buildings in order to accelerate the shift to a clean energy economy and maximize job creation potential of clean energy development.
- Secure binding liability agreements and bonds with all relevant parties for recovering costs arising due to infrastructure and environmental damage from all shale gas activities.
- Comply with the existing Clean Water Act, Water Classification Program and Watershed Designation Order.
- Produce (a) an economic cost/benefit analysis and (b) an environmental risk assessment.
a) A comprehensive cost/benefit analysis must be conducted to determine the overall economic impact on the province. This analysis must include an objective third party assessment of the economic benefits of hydrocarbon development for the people of New Brunswick plotted against an assessment of all costs related to property values, agriculture, forestry and all other land uses, recreation and tourism, roads and bridges, health and health care, policing and the criminal justice system, environmental damage mitigation and remediation.
b) A comprehensive risk assessment must include the level of endangerment to environmental quality, habitat integrity, public health and safety, public and private infrastructure and climate stability. The risk analysis must be conducted by an objective third-party agency, and, along with the cost/benefit analysis, be made fully available for public review. - The duty to consult and accommodate all the concerns and interests of First Nations in New Brunswick.
Conclusion
There is no guarantee that the results from the highly anticipated UN Climate Change Summit in Paris will be substantially different this time than they were at previous summits. However, the sense of urgency with the ever-growing concern of billions of people around the world may finally overpower the boundless determination of the interested parties for the status quo. Regardless of the summit outcome, climate deniers have lost, and now the world must quickly figure out how to successfully adjust to the new reality that fossil fuels will play a diminishing role in the economy and in daily use.
New Brunswick is ideally positioned to take advantage of the emerging low carbon economy while saving itself the numerous known risks that would come with hydraulic fracturing. The choice between the benefits derived from developing clean energy to that of developing shale gas is now abundantly clear. Lifting the moratorium on shale gas development is highly problematic. It may never be a rational policy choice within the scope of the factors and conditions that must be taken into account. Meanwhile, there is nothing to prevent clean energy development. Incentives can quickly be put into place by government to create jobs retrofitting homes and buildings to silver efficiency standards, and to stimulate activity in community energy projects and renewable energy development throughout the province. The right time to make this happen has arrived.
Submitted on behalf of the Woodstock Sustainable Energy Group,
Samuel Arnold and Keith Helmuth