Cover Sheet

EPP2

APPEAL BY ISLAND GAS LTD, PORTSIDE  ELLESMERE PORT

 APPEAL REFERENCE APP/A0665/W/18/3207952

 AIR QUALITY AND PUBLIC HEALTH

Andrew Watterson

Emeritus Professor of Health PhD CFIOSH, Fellow Collegium Ramazzini, Faculty of Health Sciences, Stirling University

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Table of Contents

  1. EVALUATING HAZARDS AND RISKS FOR AIR QUALITY
  2. THE HISTORY OF THE IGAS ELLESMERE PORT PROPOSAL RELEVANT TO PUBLIC HEALTH AIR POLLUTION ASSESSMENTS
  3. ACIDISATION AND THE ELLESMERE PORT PROPOSAL
  4. STATE OF KNOWLEDGE 2014 – 2018 RELEVANT TO ASSESSING THE IGAS PROPOSAL
  5. RESEARCH FINDINGS ON POOR AIR QUALITY RISK AND RISK MANAGEMENT INCLUDING VULNERABLE POPULATIONS RELEVANT TO ELLESMERE PORT
  6. TECHNIQUES NECESSARY TO FULLY ASSESS THE PUBLIC HEALTH THREATS, IF ANY, FROM AIR QUALITY IMPACTS OF THE PROPOSED DEVELOPMENT
  7. EXTERNAL ASSESSMENTS OF THE IGAS ELLESMERE PORT PROPOSAL
  8. CONCLUSIONS

APPENDIX 1 – Some relevant academic publications by the Author

APPENDIX 2 – Sustainable Development

APPENDIX 3  IGas Improvement Notices

INTRODUCTION

  • My name is Andrew Watterson and I am Emeritus Professor of Health PhD CFIOSH, Fellow Collegium Ramazzini , Faculty of Health Sciences, Stirling University. From 2000 – 2017 I was the Director of the Centre for Public Health & Population Health Research at Stirling University. From 2000 to date. I have been the Head of the Occupational & Environmental Health Research Group at Stirling University.
  • In this period, I was also a Visiting Professor, University of British Columbia Dept of Health Care & Epidemiology and a Visiting Professor, University of New South Wales, Sydney, Australia. I am currently Journal Editorial Board member of two journals :- Environmental Health (BMC) , and New Solutions Journal of Occupational and Environmental Health, Health (the only journal that explores the growing, changing common ground at the intersection of health, work, and the environment)
  • Previously I was Professor of Occupational and Environmental Health at De Montfort University, Leicester and Head of the Centre for Occupational Safety & Health in the Department of Mechanical Engineering at Nottingham Trent University.
  • I am a past member of the HSE Working Group on rubber dust and fumes and a past member of the HSE Chemag Working Group
  • I have provided a list of some of my relevant academic publications in Appendix 1.
  • I provide this statement as an independent researcher who has received no payments from (and does not work as a paid consultant for) any party, nor has any monetary interest in or membership of bodies or organisations involved in this case. I have been researching the gas industry since the 1980s. Since 2014 I have been the sole author/lead author on 4 peer reviewed papers dealing with unconventional gas extraction, 2 independent reports on the subject and have advised the chair of a Scottish Government enquiry looking at underground coal gasification proposals.
  • The evidence which I have prepared and provide for this appeal in this proof of evidence is true to the best of my knowledge and belief. I confirm that the opinions expressed are my true and professional opinions based on the facts I regard as relevant in connection with the appeal.

 

1 EVALUATING HAZARDS AND RISKS FOR AIR QUALITY

1.1 To evaluate hazards and risks for air quality and other public health risks from an energy or any other project like the IGas proposal in Ellesmere Port, it is necessary to be able to answer the questions set out below as fully as possible. Where data gaps exist in answers, this needs to be carefully assessed in terms of their known or likely significance for public health.

  • what hazards are present from the project source? This means all and not selected hazards
  • how might these hazards on their own and in combination affect human health?
  • what are the pathways for a population’s exposure to the hazards?
  • what risks will the identified hazards present to the local population as a whole and any vulnerable sub-populations within it?
  • at what level will risks emerge that can affect human health
  • what is the evidence base for establishing the risk level? Also , is it adequate and does it reflect the latest peer-reviewed independent research?
  • how accurate have been exposure measurements and modelling in terms of their capacity to measure the identified hazards, the size of the population known to be exposed now and in the near future and to replicate cumulative and long-term as well as immediate risks?
  • have exposures from other routes including absorption and ingestion as well as inhalation that could affect the impact of any poor air quality on local populations been considered, measured and assessed? This would include existing insults from other sources beyond traffic fumes for example

1.2 A high hazard with no exposure, and no exposure can never be guaranteed, would present little risk but in some instances very low exposures to certain hazards such as endocrine disruptors at parts per trillion and other chemicals on their own and in combination could present very high risks to communities especially the highly socio-economically disadvantaged ward that borders the site.

1.3 DEFRA’s air quality expert group on shale gas and air pollution highlighted “the current lack of knowledge regarding on-shore shale gas extraction activities and its environmental impacts in the UK context”(EP47 p9).They concluded “estimates of emissions of air quality pollutants including ozone precursors from activities associated with a single well are uncertain and are affected by many parameters (e.g. geology, regulation, and operating conditions)” (ibid p9). This is precisely why a cautious approach to protect public health should be taken to any UGE (Unconventional Gas Exploration) proposal and, where there are data gaps and omissions in project proposals, the benefit of doubt should be with local communities. They further noted: “Impacts on local and regional air quality have the potential to be substantially higher than the national level impacts, as extraction activities are likely to be highly clustered. Studies in the US have shown significant impacts on both local air quality and regional ozone formation, but similar studies have not yet been undertaken for the UK”(ibid p42). It should be noted that the techniques developed in North America will be the same or very similar techniques that will be applied in the UK with the same outcomes.

1.4 This is precisely why a cautious approach to protect public health and reduce air quality impacts should be taken to any UGE proposal and, where there are data gaps and omissions in project proposals, the benefit of doubt should be to refuse permission in order to protect local communities. Renewable sustainable non-fossil fuel energy schemes provide far lower hazards and potential risks to local and global public health from poor air quality than do gas or shale gas projects.

2 THE HISTORY OF THE IGAS ELLESMERE PORT PROPOSAL RELEVANT TO PUBLIC HEALTH AIR POLLUTION ASSESSMENTS

2.1 The first proposal byKing Sturge LLP for 2 exploratory coal bed methane boreholes in Ellesmere Port was submitted in October 2009. Since that date many documents relating to hydrocarbon extraction have been produced. They alter, clarify or amend various proposals made for site use that latterly has included reference to acidisation using hydrochloric acid and additives. Many documents have also come from the Environmental Agency (EA), Cheshire and West Chester Council and other bodies. Different bodies have made different assessments of the current IGas proposal from approval, rejection and permitting with variations from the original submissions.

2.2 The later EA assessments concluded that only fugitive emissions would occur on site, although the range of air pollutants that needed monitoring were expanded (CD2.12 and CD2.13). Assessing UGE’s potential poor air quality on the proposed site from a public health perspective is therefore complex and challenging.

2.3 Assessments should draw on the latest research information, where possible from independent peer-reviewed sources, and use accurate and appropriate data from relevant local background monitoring and other sources, recognize where data gaps could indicate risks and establish the likely population to be exposed now or during the course of any extraction. They should also use modelling that considers accurate details of the technology to be adopted, the precise chemicals to be used along with their break-down and by-products that may present an air pollution hazard and possible risks along the life cycle of a project. Without such information it becomes problematic to determine with a high degree of certainty that public health threats do not exist and risks are low or will not emerge in the middle and ‘long term’ to local populations.

2.4 This report attempts to identify the above information where it is available and of good quality in the Ellesmere Port proposal and comment on data gaps that might affect public health risk assessments, models and methodologies used. Company and company consultant reports, where available, need to be assessed for appropriateness, accuracy and completeness as does information generated by local authorities, the Environment Agency, DEFRA and other bodies.

Evidence available and necessary to assess the proposed IGas site at Ellesmere Port

2.5 The DEFRA Air Quality Expert Group on shale gas has recently noted: “the extensive shale gas extraction activities in the US mean that the global evidence base on the potential for air quality pollutant emissions is very much dominated by research and measurement undertaken on US shale gas operations. As there are no active wells in the UK, it is necessary to draw on the US evidence base, even if it is recognised that there may be substantial differences in the emissions characteristics”(EP47 p26). It is therefore critical from a public health perspective that air quality assessments in the UK of shale gas proposals like IGas’s at Ellesmere Port draw on international research and its data bases and evaluations of chemicals likely to be used on site – dusts, fumes and gases – along the lifecycle of UGE operations to inform those assessments. This is because they provide empirical evidence and not just theoretical and modelled estimates of what companies and consultants think may happen or should happen rather than what has happened.

2.6 The US information relates to UGE generally but also includes studies and reports on acidisation as well as hydraulic fracturing. It is especially important in terms of real exposures for example to identify exposures not just to benzene and other VOCs (Volatile Organic Compounds) and fine particulate matter involved in acidisation but also the other chemicals, by-products and mixtures, contaminants and pollutants generated by UGE. These need to be factored in when considering buffer or set back zones, the monitoring sites, local population characteristics and sites that are likely to be part of larger industrial clusters extracting shale gas.

2.7 It is therefore necessary to take account of the latest global public health and air quality research regarding UGE hazards and risks.

2.8 This public health proof of evidence additionally touches on sustainable development principles, greenhouse gas production, renewables and climate change in so far as they are linked to questions of air quality. They reflect the inter-connectedness of the environment with social and economic factors when identifying the public health contribution to assessing key sustainable developments (see the Venn in Appendix 2 attached that illustrates this).

2.9 The challenges with regard to assessing all UGE methods used for shale gas often come with a lack of any detailed information provided about exactly what materials and technology are proposed to be used and will be used for gas extraction, what may change and what the scale of production will be over a number of years on a particular site. Failure to consider such factors from a public health perspective would not only be irresponsible but would be simply wrong. The assessments of air quality and possible effects on public health require consideration of these factors and also cumulative environmental health impacts and total exposome load.

2.10 A reductionist and fragmented assessment of multiple pathways of humans to shale gas production along with exposures to other pollutants and contaminants within a region and in the wider environment and their cumulative effects is flawed. It does not provide an adequate hazard identification and risk assessment of the hazards, risks and impacts of any form of gas production. Proper consideration of the possible public health effects of air quality impacts from the Ellesmere Port site has to be nested within this bigger picture and, as indicated above, it would be wrong to fail to do so[1]. I understand other proofs of evidence will address climate change, water pollution, mental health, socio-economic factors etc which may all contribute to public health impacts and so I do not refer in any detail or sometimes at all to these topics.

2.11 One further factor applied in the preparation of this report. This relates to the state of knowledge in making judgements about the public health effects of unconventional gas extraction. The global assessment of UGE and its impacts on public health, based on new research, has changed since some of the early reports which considered shale gas extraction would be safe if properly regulated and where industry practice was good. Even in 2015, authoritative public health researchers had identified all the following as sources of poor air quality activities and impacts associated with UGE:- transport on and off site, muds and cuttings, fluids used for acidisation or ‘fracking , generators and pumps, flowback and produced water, gas venting, gas flaring, hydrocarbon production, condensate tanks, well workovers and maintenance and pipelines[2]. It is unclear from the documentation I have seen submitted by IGas and examined by the Environment Agency as to exactly what materials and chemicals would be used or liberated either in the well testing activities or in any subsequent commercial operation at the Ellesmere Port site. Also lacking is any public health life cycle analysis of any type of UGE by the industry as a whole or by particular companies with regard to potential poor air quality. At this stage of the technology’s development, this must be viewed as a considerable gap and a major drawback in the industry’s risk assessment and risk management policies.

[1]Healy N et al (2019) Embodied energy injustices: Unveiling and politicizing the transboundary harms of fossil fuel extractivism and fossil fuel supply chains. Energy Research & Social Science 48(9): 219-234. https://doi.org/10.1016/j.erss.2018.09.016.

[2]De Jong N, Witter R, Adgate J (2015)Natural Gas Development and its Effect on Air Quality in Finkel (ed ) 2015: 61-80

3. ACIDISATION AND THE ELLESMERE PORT PROPOSAL

3.1 There appears to be some debate about the type of extraction to be used by IGas and their meaning with regard to the proposal. The company is clear that acidisation will be used to extract shale gas. Others are less clear that this does not involve ‘fracking’ in some form and will not do so in the future. This report looks at UGE with particular reference to acidisation and its links with and possible effects on air quality. Immediately there then appears to be a significant difference between what the company states will be used in the proposal and what independent and peer reviewed literature indicates could be used. This has not been clarified in the original proposal or in later reports on the project that I have seen.

3.2 US research has covered acid maintenance, matrix acidisation, and acid fracturing and found around “200 specific chemicals used in acidization, with at least 28 of them being F-graded hazardous chemicals [known carcinogens, mutagens, reproductive toxins, developmental toxins, endocrine disruptors, or high acute toxicity chemicals]. Some are used frequently in the range of 100 to 1000 kg per treatment, such as hydrofluoric acid, xylene, diethylene glycol, and ethyl benzene. Close to 90 more chemicals are identified using non-specific names as trade secrets or reported with no quantity as indeed is the case with the wellbore fluid proposed by IGas. Unlike hydraulic fracturing the chemical concentrations in acidizing are high, ranging from 6% to 18% HCL, and the waste returns can be highly acidic, in the range of pH 0-3”(Abdullah 2016) [3]. These studies drew on SCAQMD (South Coast Air Quality Monitoring District) data from 2015 linked to Notifications and Reporting Requirements for Oil and Gas Wells and Chemical Suppliers Index.

[3]Abdullah K et al. (2016) Toxicity of acidization fluids used in California oil exploration. Abdullah K et al. TOXICOLOGICAL & ENVIRONMENTAL CHEMISTRY. http://dx.doi.org/10.1080/02772248.2016.1160285

3.3 Other studies have examined the differences and overlaps between UGE methods. One found significant overlaps between the chemicals used in UGE and ‘conventional oil and gas extraction’. It also used data on air pollution and air quality to make assessments. These studies look pertinent to the IGas proposal and its assessment. The overlaps from the Stringfellow study in 2017[4]are shown below. The figures on chemicals used in initial acidising appear to be higher than those provided by IGas.

1 Matrix acidisation
Matrix Acidizing

[Source: Stringfellow 2017 p7]

[4] Stringfellow WT, Camarillo MK, Domen JK, Shonkoff SBC (2017) Comparison of chemical-use between hydraulic fracturing, acidizing, and routine oil and gas development. PLoS ONE 12(4): e0175344. https://doi.org/10.1371/journal.pone.0175344

3.4 IGas have not provided exact details of all the chemicals and materials to be used in the tests or how exactly they will be used and no public health life cycle analysis of the test proposal is available or modelled in any form. It is therefore unclear to me what chemicals IGas will be using and how their process will differ from the various US acidisation shale gas extractions or which form of acidisation will finally be used. The situation is further confused by the IGas Wellbore Fluid and Indicative Onsite Chemicals list (IGAS-EPRA-EP-WF-009) that the EA examined, and by the EA request to IGas for further information on the chemicals to be used. The latter were apparently provided, checked and ‘cleared’ by EA but are not as far as I am aware in the public domain. The former list from IGas was also headed “anticipated chemical inventory” which would seem to indicate there could be changes in the list. The application to the council states “a dilute acid, most commonly hydrochloric acid(CD2.4: 6.2.4)indicating yet further lack of certainty about what precisely the company will use.

3.5 These facts make any comprehensive modelling and assessment of poor air quality levels provided and risks from the test site necessarily incomplete. DEFRAs air quality expert group on shale gas also stressed: “Differences in the composition of the gas held within different shale fields may result in differences in the type and range of NMVOCs emitted from shale gas operations; some fields are rich in NMVOCs, whilst others contain relatively low amounts” (EP47 p40). So, the exact nature of all the chemicals to be used on site and the chemicals generated during and after production remain unclear.

4. STATE OF KNOWLEDGE 2014 – 2018 RELEVANT TO ASSESSING THE IGAS PROPOSAL

4.1 It is unusual to find company project reports or the reports of their consultants that cite, fully reference and analyse the latest research relating to UGE. This lack of transparency can be problematic because the evidence base for statements could simply be opinions and assertions or be ignorant of important new research. This appears to be the case here but may not be – for example new research may have been identified, evaluated and discounted. It is impossible to say with regard to statements made by IGas and with how their consultants’ reports have been framed, what they do and do not address and what they include and omit. In 2015, an Australian study looked at the health impacts from UGE and could neither indicate absence of adverse health effects from UGE or effects  (Werner 2015)[5]. Since that date, research on public health and air quality has gathered pace rapidly along with more health studies on shale gas extraction.

[5]Werner, A.K.;Wink, S.;Watt, K.; Jagals, P (2015) Environmental Health Impacts of Unconventional Natural Gas Development: A Review of the Current Strength of Evidence. Sci. Total Environ. 501, 1127–1141

4.2 Several factors require consideration from a public health perspective that are relevant to the planning application. These relate to what the latest air quality research tells us about the public health hazards and risks with specific particulates of various sizes likely to be generated by such a commercial project. They also need to consider the extent to which such factors will add to the wider load in the community’s environment and have been factored in and measured accurately rather than simply ‘modelled’. The cumulative environmental health impact and the ‘exposome’ are important techniques now being used for assessing existing baseline air quality and considering future likely pollution from multiple sources. In addition the adequacy of existing control standards for specific pollutants, the ability and capacity of industry to operate good practice on controlling poor air quality and the effectiveness of regulators to check failures in industry practice all form part of a thorough public health assessment. Equally important is the capacity to predict the pollutants and contaminants that will occur in any UGE operation based not just on company/industry information but on independent sources.

4.3 The table below shows the range of chemicals that for example may be used in shale gas extraction and could contribute to allergies and asthma through poor air quality. Some will be produced by the IGas test site activity. The table highlights the importance of using risk profiles involving several substances rather than single predictors (Agache 2018)[6].These are the multiple insults that cannot be taken in isolation.

Biomarker Linked exposure(s) Linked

pathway

Susceptibility

measured

PAHs PAHs, diesel DNA damage Increased FeNO (Fractions of NO in exhaled air)
PAH metabolites PAH Altered receptor signalling IgE effects
Exhaled carbon monoxide Cigarette smoke Airway inflammation Asthma, allergic rhinitis
Phthalate metabolites Phthalates Endocrine disruption Asthma symptoms . Increased FeNO
Fractions of NO in exhaled air (FeNO) Allergens, viruses, BPA, phthalates Accelerated lung function decline, asthma exacerbations

[6]Agache I, Miller R, Gern J et al (2018 Emerging concepts and challenges in implementing the exposome paradigm in allergic diseases and asthma. Allergy. Ist published: 04 December 2018 https://doi.org/10.1111/all.13690

4.4 In the USA, the need to ensure an effective spatial analysis of populations at risk from UGE was developed along with ways to effectively integrate air quality into any UGE assessments and the identification and measurement of a range of PAHs [7][8][9]. It is not possible in the UK to identify exactly how, if at all, air quality consultants on UGE projects have taken on board the latest research and factor in new evidence to their assessments. This is because rarely if at all is their independent evidence base referenced to explain what they used, what they included and what they excluded beyond government protocols.

[7]Meng Q (2015) Spatial analysis of environment and population at risk of natural gas fracking in the state of Pennsylvania, USA. Sci Total Environ. 2015 May 15;515-516:198-206. doi: 10.1016/j.scitotenv.2015.02.030

[8]Meng Q (2016) The impacts of fracking on the environment: A total environmental study paradigm. Science of the Total Environment 580 (2017) 953–957

[9]Paulik LB, Donald CE, Smith BW, Tidwell LG, Hobbie KA et al (2016) Emissions of polycyclic aromatic hydrocarbons from natural gas extraction into air. Environ Sci Technol 50(14):7921–9

4.5 Directly relevant to the Ellesmere Port application it is necessary to establish the proximity, size and nature of the populations in the application area because that information is needed to assess those at risk from poor air quality along with what the population may be exposed to. In 2016, another US study found a significant association based on hospital admissions data between shale gas development and hospitalisations for pneumonia among older people that was consistent with higher levels of air pollution resulting from UGE[10]. In 2018 a community-level study in Pennsylvania found UGE exposure metrics were associated with increased odds of paediatric asthma related hospitalisation among young children and adolescents linked to poor air quality[11].

[10]Peng L et al ( 2018) The health implications of unconventional natural gas development in Pennsylvania. Health Economics . August. DOI: 10.1002/hec.3649

[11]Willis M et al (2018) Unconventional natural gas development & pediatric asthma hospitalizations in Pennsylvania. Environmental Research 166: 402–408 https://doi.org/10.1016/j.envres.2018.06.022

4.6 In 2018, an extensive review of the literature on UGE was published, led by UK researchers. They focused on the pathways of exposure. They found numerous international papers that identified UGE as an air quality pathway[12]. The papers reviewed ranged across different monitoring techniques, different settings, different densities of UGE activity and some covered air measurements before and during UGE. The majority of the accessible research is based on US research as this is where the bulk of ‘open’ commercial activity is underway and as there has been no large-scale commercial operation within the UK. It is therefore critical to draw on both the monitoring and health studies done there especially in recent years. These are usually empirical studies and not models or theoretical studies that consultants and others often have to rely on in the UK as is the case with several of the Ellesmere Port reports. The empirical reports and peer reviewed research publications, such as those from Saunders and others, should be considered as important if not more important in weighing the evidence of shale gas impacts as the theoretical and modelled UK material.

[12]Saunders, P.J.; McCoy, D.; Goldstein, R.; Saunders, A.T.; Munroe, A (2016). A review of the public health impacts of unconventional natural gas development. Environ. Geochem. Health 1–57

4.7 The relevance of research findings from other countries to the UK can be disputed for various reasons including geology and geography, population density and other factors. Sometimes, it is argued, risk may be over-estimated and at other times risk may be under-estimated. However, the UK UGE industry, governments and sometimes regulators often make a case for using the USA especially Pennsylvania as an exemplar of good practice. INEOS and other companies have done so at many public meetings on shale gas because they argue the US companies have learnt from bad practice during the early development of UGE and have now done most research. For that reason, a significant number of the following studies come from the USA and especially Pennsylvania and Colorado, Texas, Wyoming and Ohio where UGE is relatively widespread. Some of these studies indicate few problems and stress industry good practice and effective regulation leading to little if any public health problems. Others do not and many highlight a lack of data and middle and long-term studies[13][14][15]. More recent studies have examined links between childhood cancers and residential proximity to oil and gas developments[16]. If best practice comes from the US, such studies indicate there are still major problems at a local and regional level as well as adverse global impacts.

[13]Finkel, ML editor (2015). The Human and Environmental Impact of Fracking: How Fracturing Shale for Gas Affects Us and Our World. Praeger: Santa Barbara, CA, USA. ISBN 978-1-4408-3259-8

[14]Institute of Medicine of the National Academies, Board on Population Health and Public Health Practice (2014). Health Impact Assessment of Shale Gas Extraction: Workshop Summary; National Academies Press: Washington, DC, USA

[15]Jemielita, T.; Gerton, G.L.; Neidell, M.; Chillrud, S.; Yan, B.; Stute, M.; Howarth, M.; Saberi, P.; Fausti, N.; Penning, T.M (2015) Unconventional Gas and Oil Drilling is Associated with Increased Hospital Utilization Rates. PLoS ONE 10, e0131093

[16]McKenzie, L.M.; Allshouse,W.B.; Byers, T.E.; Bedrick, E.J.; Serdar, B.; Adgate, J.L (2017) Childhood hematologic cancer and residential proximity to oil and gas development. PLoS ONE 12, e0170423

4.8 Air quality impacts and UGE links have been studied and reviewed since the early UK government reports on public health. These are peer reviewed studies from Europe and the US[17][18]. Particular pollutants such as endocrine disruptors and other chemicals used and liberated in UGE present a range of air borne and water contamination hazards with risks that have not yet been fully quantified. Some reviews have been conducted of air impacts of natural gas processing[19]. Even in terms of very low-level exposures the risks may nevertheless be considerable especially for particular groups such as workers, women and children[20][21](and see Law in Finkel footnote 13).

[17]New York State Department of Health. Public Health Review of High Volume Hydraulic Fracturing for Shale Gas Development (2014)

[18]Health Protection Scotland. A Health Impact Assessment of Unconventional Oil and Gas in Scotland (2 Volumes). Glasgow, 2016.

[19]Moore CW, Zielinska B, Petron G, Jackson RB (2014) Air impacts of increased natural gas acquisition, processing, and use: a critical review. Environ Sci Technol 48(15):8349–59.

[20]Colborn T, Kwiatkowski C, Schultz K, and Bachran M (2012) Natural gas operations from a public health perspective. Hum Ecol Risk Assess, 17(5):1039-56

[21]Law, A.; Hays, J.; Shonkoff, S.; Finkel, M (2014) Public Health England’s draft report on shale gas extraction. BMJ 2014, 348, 2728

4.9 UK air quality modelling has shown potential human health impacts just of emissions linked to UGE and researchers have concluded VOC and NOx emissions need to be highly controlled[22]. This then raises the question of industry practice, regulation and enforcement with regard to UGE controls and standards. Studies of air and water pollutants found most often near UGE sites in the US have identified a range of toxic chemicals and air quality issues[23]. Air concentrations of volatile compounds near oil and gas production facilities have been flagged[24](Macey et al 2014). Human exposure to unconventional natural gas development has been noted with periodic high exposure to chemical mixtures in ambient air[25]. Other studies have looked at particular air pollutants from UGE facilities and winter haze around UGE sites[26](see also Paulik Footnote 9 above). Associations between unconventional natural gas development in the Marcellus shale and asthma exacerbation have been found[27]. Neurodevelopmental and neurological effects of chemicals associated with UGE and their potential effects on infants and children have been described in a study of five air and water pollutants linked to UGE [28]. The authors concluded: ”Given the profound sensitivity of the developing brain and central nervous system, it is reasonable to conclude that young children who experience frequent exposure to these pollutants are at particularly high risk for chronic neurological diseases”.

[22]Archibald A et al (2018) Potential impacts of emissions associated with fracking on UK air quality & human health. Air Quality, Atmosphere and Health. DOI: 10.1007/s11869-018-0570-8

[23]Litovitz A, Curtright A, Abramzon S, Burger N, Samaras C (2013) Estimation of regional air-quality damages from Marcellus Shale natural gas extraction in Pennsylvania. Environ Res Lett 8(1):014017

[24]Macey GP, Breech R, Chernaik M, Cox C, Larson D et al (2014) Air concentrations of volatile compounds near oil and gas production: a community-based exploratory study. Environ Health 13:82

[25]Brown DR, Lewis C, Weinberger BI (2015) Human exposure to unconventional natural gas development: a public health demonstration of periodic high exposure to chemical mixtures in ambient air. J Environ Sci Health Part A 50(5):460–72

[26]Evanoski-Cole, A.R.; Gebhart, K.A.; Sive, B.C.; Zhou, Y.; Capps, S.L.; Day, D.E.; Prenni, A.J.; Schurman, M.I.; Sullivan, A.P.; Li, Y.; et al (2017) Composition and sources of winter haze in the Bakken oil and gas extraction region. Atmos. Environ. 156, 77–87

[27]Rasmussen, S.G.; Ogburn, E.L.; McCormack, M.; Casey, J.A.; Bandeen-Roche, K.; Mercer, D.G (2016) Association between unconventional natural gas development in the Marcellus shale and asthma exacerbations. JAMA Int. Med. 176, 1334–1343

[28]Webb E et al (2018) Neurodevelopmental and neurological effects of chemicals associated with unconventional oil and natural gas operations and their potential effects on infants and children. Rev Environ Health. 33(1). DOI: https://doi.org/10.1515/reveh-2017-0008 online.

4.10 Diesel pollution from UGE site transport and operations has been flagged as an issue for workers and communities[29]. One recent UK study suggests exposure to diesel engine exhaust emissions from UGE equipment could present a significant risk to people working on UGE sites over extended time periods[30](Eliani 2018). Failure to identify all sources of diesel exposure for the exposed population would be a serious omission from a public health perspective.

[29]Boyle MD, Payne-Sturges DC, Sangaramoorthy T et al (2016) Hazard Ranking Methodology for Assessing Health Impacts of Unconventional Natural Gas Development and Production: The Maryland Case Study. PLoS One. 11(1):e0145368. Published 2016 Jan 4. doi:10.1371/journal.pone.0145368

[30]Eliani E et al (2018) Measurement of diesel combustion-related air pollution downwind of an experimental unconventional natural gas operations site. Atmospheric Environment. September. 30-40

5. RESEARCH FINDINGS ON POOR AIR QUALITY RISK AND RISK MANAGEMENT INCLUDING VULNERABLE POPULATIONS RELEVANT TO ELLESMERE PORT

5.1 In a study of shale gas extraction in Texas, Pennsylvania and Colorado, researchers exploring air pollution and other risks concluded “setbacks may not be sufficient to reduce potential threats to human health in areas where hydraulic fracturing occurs. It is more likely that a combination of reasonable setbacks with controls for other sources of pollution associated with the process will be required”(Haley EP01p1323). They further noted “unfortunately, there is no defined setback distance that assures safety” (ibid p1330). An even later US air pollution UGE study from 2018 of working wells found that even though the setback distance policy in their state – Pennsylvania of 500 ft. or 152.4 m might be effective in some cases, exposure limit exceedance occurred frequently at this distance with higher than average emission rates and/or greater number of wells per well pad[31]. In the UK assessments of PM5have been neglected in air quality studies on UGE unlike this study.

[31]Banan Z et al (2018) Gas well setback policy evaluation in Pennsylvania Marcellus Shale region regarding fine particulate emissions. 68(9): 988-1000. DOI: 10.1080/10962247.2018.1462866. August

5.2 The particular impact of the environment including poor air quality on vulnerable populations especially the very young, pregnant women, older people and those in poor health has been consistently flagged by bodies like the WHO including its Europe Office over many decades along with the need to improve air quality[32](WHO 1990). According to Dr Bustreo of the WHO, “air pollution continues take a toll on the health of the most vulnerable populations – women, children and the older adults. For people to be healthy, they must breathe clean air from their first breath to their last.”[33]

[32]WHO Europe Office (1990) Environment and Health: The European Charter. Copenhagen

[33]WHO ( 2016) WHO releases country estimates on air pollution exposure and health impact http://www.who.int/news-room/detail/27-09-2016-who-releases-country-estimates-on-air-pollution-exposure-and-health-impact

5.3 In this context the evidence that some wards like Rossmore and Ellesmere Port around the projected industrial area have levels of bad or very bad health significantly higher than the English average merits attention (EP04, EP21).The Ellesmere Port SMR for respiratory disease is 70% higher than England’s as a whole. This should be a factor linked to efforts to improve air quality not maintain or reduce its quality further. For all Cheshire West and Chester, it is reported that ‘children generate around 250 admissions per year for lower respiratory tract infections. The rate of 390 admissions per 100,000 under 19s is significantly higher than England’ (EP27).

5.4 The Ellesmere Port Air Quality Action Plan for 2007 noted the national objective for NO2at the facade of residential properties was 40μg/m3. We now have an even greater understanding of the major risks to public health in England presented by poor air quality from a range of sources including the oil and gas industries. The 2007 plan itself recognised it would be unlikely any single measure would prove effective in reducing poor air quality but multiple actions across several sectors would be needed. The 2017 (EP25)Air Quality report from Cheshire West and Chester Council focus primarily on NOxand SO2with some monitoring results for PM10s and benzene linked to oil refinery and other industrial sites. The lack of data on PM5 levels in the area is also of concern. Interms of possible poor air quality risks for public health from UGE, there would be a number of other chemicals beyond benzene and particulate matter beyond PM10s of concern. Also, research continues to indicate as discussed earlier in this report that exceptionally low levels of air borne pollutants and contaminants from UGE on their own and in combination with other substances can have adverse health effects.

5.5 Additional industrial developments, even for a very short period of time, can add unnecessarily in however large or small a way to the air pollution burden of the area for no benefit to public health. They can impact especially on local communities where health profiles are poor. This is because for example ‘’subjects with chronic respiratory diseases such as chronic obstructive pulmonary disease (COPD) and asthma are especially vulnerable to the detrimental effects of air pollutants[34] UK NHS also recognise air pollution as a trigger for asthma[35]. So, if air quality declines daily over for example 4 months, then populations like those above could be adversely affected and especially those close by as later sections identify (See also Willis: Footnote 11 above).

[34]Jiang XQ et al (2016) Air pollution and chronic airway diseases: what should people know and do?  J Thorac Dis. 2016 Jan; 8(1): E31–E40. doi: [10.3978/j.issn.2072-1439.2015.11.50]

[35]https://www.nhs.uk/conditions/asthma/causes/

5.6 Without accurate data about the extent and cumulative effect not just of one or a small number of UGE wells but other sources of poor air quality in a locality and region, it is difficult to assess what buffer zones could be needed to limit immediate and short-term impacts of poor air quality on local populations. In states like Pennsylvania there is still confusion after several years of UGE and disagreement about what are safe distances to protect residents from exceeding established limits. Current standards have been viewed as inadequate (see also Banan: Footnote 31 above). Some US studies have called for additional setbacks where vulnerable groups are found, including schools, day care centres, and hospitals. They also agreed that setback distances should always be greater than ¼ mile (402m) and some argued for 2 mile set back zones[36]. In Australia, 2km buffer zones around unconventional gas sites exist because of poor air quality risks[37]

[36]Lewis C, Greiner L, Brown D (2018) Setback distances for unconventional oil and gas development: Delphi study results. PLOS One. August 16

[37] https://data.gov.au/dataset/8e9b4d01-bba2-4741-9ffd-aed0484eb14a

5.7 The position in Ellesmere Port also seems to be somewhat confused. The populations likely to be affected have changed over time as has their proximity to the site. Environment Agency documents appear to cover only residences at 700m.

5.8 However, since those documents were produced, a new estate has been built apparently 320m away from the site, of which the Environment Agency was unaware of.The OOG Flare Screening tool for EPR BB3708GN.DST (EP29) from the EA’s Air Quality Modelling and Assessment Unit only identifies resident receptors at 566, 742 and 745 meters from the site. Again, these discrepancies about population location and related risk assessments acknowledged in the documents are a serious cause for concern. If the potential additional exposures that could occur to those working around the site but not in it – even closer than the residents – are factored in, there is even greater cause for concern.

6. TECHNIQUES NECESSARY TO FULLY ASSESS THE PUBLIC HEALTH THREATS, IF ANY, FROM AIR QUALITY IMPACTS OF THE PROPOSED DEVELOPMENT

6.1 Cumulative health impacts[38](Solomon et al 2016) are needed for UGE and other industries and should therefore be assessed and applied to projects like those in Ellesmere Port. However, little is available on these projects or on the public health life cycle analyses (LCAs) of the industry that need to connect with them. This is despite calls for their application along with chemical usage and risk assessment work[39](Walser et al 2017) and from the English government shale gas air quality expert group (EP47). This group flagged that “in order to enable evaluation of the impact on local air quality, a full well lifecycle analysis is required for a range of pollutants relevant for a range of issues including health, and agricultural and natural ecosystems(EP47:11).Such an analysis has not been provided by IGas or any of its air quality consultants in the papers that I have seen nor has it been mooted. This is a major shortcoming.

[38]Solomon, G.M.; Morello-Frosch, R.; Zeise, L.; Faust, J.B (2016) Cumulative Environmental Impacts: Science and Policy to Protect Communities. Annu. Rev. Public Health. 37, 83–96

[39]Walser T et al (2017) Combination of life cycle assessment, risk assessment and human biomonitoring to improve regulatory decisions and policy making for chemicals. Environmental Impact Assessment Review. 65: 56-163

6.2 A Spanish pilot LCA has flagged how limited data are on the industry and stressed the need for a precautionary policy[40]. Other research that included poor air quality considerations noted the UK lack of precaution in UGE activities with regard to public health[41][42][43][44].

[41]Reap, E (2015) The risk of hydraulic fracturing on public health in the UK and the UK’s fracking legislation. Environ. Sci. Eur. 2015, 27, 27

[42]Watterson A and Dinan W (2015) Health Impact Assessments, Regulation, and the Unconventional Gas Industry in the UK: Exploiting Resources, Ideology, and Expertise? New Solutions Journal of Environmental and Occupational Health policy

[43]Watterson A and Dinan W (2017) The UK Dash for Gas: rapid evidence assessments on health impact assessments for fracking . New Solut. 2017 May;27(1):68-91. doi: 10.1177/1048291117698175

[44]Watterson A and Dinan W (2018) Public Health and Unconventional Oil and Gas Extraction Including Fracking: Global Lessons from a Scottish Government Review. IJERPH. ijerph-251997. March

6.3 Without a proper public health life cycle analysis of UGE, it is not possible for the industry to claim the safety of the technology as a whole. In 2014, 2 US research papers mapped out the nature of activities needed to assess UGE air pollution and the range of pollutants at that time which needed to be monitored. The table below, drawing on that research, shows more detail.

2 Air Pollution and Well Stages
Air Pollution and Well Stages

[Source: NRDC 2014]

6.4 The exposome concept developed in 2005 looks at total environmental exposures during a life time to a range of external insults (Walser: Footnote 39 above). This too is highly relevant to poor air quality impact assessments of UGE in heavily industrialized areas like Ellesmere Port close to populations especially where vulnerable groups such as pregnant women, the sick and the old are present in significant numbers.

6.5 Other public health considerations of relevance to this proposal that do not appear to have been built into the assessments of air quality impacts include sustainability dimensions that may impact on the physical health of the local and global populations. When assessing the health impacts of any project, it is expected the following would be included “at least three distinct types of evidence or intelligence: quantitative data to profile the relevant populations; findings from research on the impacts of similar interventions; and consultation with stakeholders”[45]. The use of findings from similar interventions globally would seem inadequate or missing in Ellesmere Port and in the past quantitative data of good quality over an appropriate period of time from the industry have all too often been lacking or simply unavailable. This is because no similar UK projects have occurred or been running long enough and evaluated independently.

[45]Tannahill A and Douglas M (2012) Ethics-based decision-making and health impact assessment. Health Promot Int 2012; 29: 98–108.

6.6 Communities have concerns about the social licence to frack or acidize, or the absence of a social licence. One of their concerns is the potential or perceived threat to public health from air pollution linked to the need for adequate health impact assessments of projects and proper consultation. These community concerns are reflected in and echoed by standard guidance to health impact assessors in the Gothenburg consensus paper. This identified four values governing health impact assessments over and above ‘promoting the maximum health of the population’ which includes addressing air pollution (WHO Regional Office for Europe, 1999). The International Association for Impact Assessment (IAIA) (International Association for Impact Assessment, 2006) identified key values as ‘guiding principles’ for assessments (i) democracy; (ii) equity; (iii) sustainable development; (iv) ethical use of evidence; (v) comprehensive approach to health. “HIA is most fundamentally concerned with the principles ‘do good and do not harm’”. The Ellesmere Port communities’ concerns with regard to a lack of consultation and health impacts are mirrored by such statements.

6.7 IGas currently provides a web entry[46]on air pollution which states “”fracking offers very little risk of air pollution as no pollutants are typically released into the air during this process. Any methane released is captured on-site and used to generate electricity, which is then released to the grid for public use”. On shale gas and emission levels they state: “the introduction of shale gas into the UK’s energy mix can have a positive effect on our current emission levels”. In the light of current knowledge, such statements are questionable at a number of levels.

[46]https://www.igasplc.com/what-we-do/extracting-gas-responsibly/air-pollution

6.8 The latest independent peer reviewed evidence cited earlier in this report indicates clearly that UGE does create poor air quality. Bodies such as the WHO[47]have been unequivocal about the toll taken of public health by greenhouse gases through poor air quality which includes fossil fuels such as shale gas. Leading environmental and medical experts have flagged shale gas as a major threat to public health through air pollution linked to climate change[48](Staddon and Depledge 2015). UK medical colleges have further called for disinvestment in fossil fuels which include shale gas because of the public health damage they do[49]. The adverse public health effects of such air quality impacts apply to local communities and global populations. It is therefore difficult to identify how either test drilling, flaring or other onsite activities producing inevitable air quality impacts will contribute in any way to local public health or fit with any council’s sustainable development objectives.

[47]http://www.who.int/news-room/fact-sheets/detail/climate-change-and-health

[48]Staddon PL and Depledge ML (2015). Fracking cannot be reconciled with climate change mitigation policies. Environ Sci Technol 49: 8269–8270

[49]-in-fossil-fuel-companies.aspx .http://www.rcgp.org.uk/about-us/news/2018/july/rcgp-to-stop-investing-in-fossil-fuel-companies.aspx

7. EXTERNAL ASSESSMENTS OF THE IGAS ELLESMERE PORT PROPOSAL

Environment Agency Assessment

7.1 The Environment Agency permitting decisions variation document from November 2017 included requirements for further monitoring and noted omissions and errors within previous IGas documentation and table errors (CD2.13).EA found that monitoring needed to be added for the following: oxides of nitrogen, carbon monoxide, total VOCs, and methane linked to various technical requirements so that the operator could demonstrate compliance with EU requirements on flare gas feed flow rates and onshore oil and gas guidance. Again, this indicates that the previous risk assessments were lacking in necessary information.

7.2 These also include omissions about residential use flagged by the Environmental Protection Team from Cheshire West and Chester linked to questions about receptor siting (21is the response). When such information is lacking, it is difficult to establish how it is possible to assess fully the chemicals used without access to all their documentation. However, technical data sheets from some manufacturers who refer to the need to consult them in their Safety Data sheets are not publicly available at the moment. The EA indicated in point 14 that it had asked for additional information on chemical additives which clearly indicates all the necessary information had not been made available prior to 21stSeptember 2017. Nor is the question of isocyanates in products fully addressed in these brief responses – although they may be elsewhere and not visible to the communities who have enquired about this additional information

7.3 Under item 4 it is unclear how flaring pollution and risks from impurities can be ‘considered negligible’ if no one knows what exactly will be used and liberated, what needed monitoring exactly and how, and what might be the shale composition and contaminants. US ATSDR assessments for example of chemicals such as n-hexane present evidence-based causes for concern. There is also no discussion of the weaknesses as well as the strengths of using benzene as a proxy for all PAHs/VOC’s. This approach may be easier, quicker and cheaper for the companies to deal with but it does not provide a full picture of airborne contamination. The view that in the whole process PM10s and PM 2.5s would not produce ‘significant emissions’ – a phrase not defined – is difficult to sustain without a proper public health LCA of the proposed well activity.

7.4 The EA view stress as a matter for other relevant bodies in public health but not poor air quality. The reasons for either not pursuing a response from the director of public health for the area on poor air quality, the failure of the director to respond to an EA consultation request or the non-inclusion by EA of any response they did send means there is a major gap in the evaluation of this proposal. The public health department was reportedly not officially consulted because, in the Council process only the Council Biodiversity team / Natural England / HSE / Council Highways / EA were considered “statutory consultees”.

7.5 With regard to UGE and acidisation, in the USA, the distinction between the various extraction methods has not been viewed by independent researchers as a valid reason for discarding risk assessments of a wider range of air pollutants. This does not appear to have happened in this case with regard to BTEX and NORM risk assessments in waste management plans as well as other activities.

7.6 The Environment Agency assessment of the IGas permit application for well testing activities on the site (13) was not a public health impact assessment nor did it consider a wider environmental health impact assessment of the proposal.It did include suggestions for additional information needed prior to any decision being taken on the proposal but considered the proposal low risk from an air quality perspective. However, there are again a number of caveats that merit attention. These include:-

7.6.1 Shrouded ground flares were considered BAT for managing waste gas generally but flaring proposed was viewed as acceptable.

7.6.2 No monitoring of specific VOCs was required only totals

7.6.3 An issue remained with regard to links between gas feed lines feeding the flares and the gas line from the fluid storage tanks linked to potential gas and vapour releases

7.6.4 Although PECs were considered ‘generally below the relevant air quality standards and critical loads for human health’, some PECs were predicted in excess of critical loads due to pre-existing contributions background contributions linked to the ‘association with’ other industrial receptors located within very close proximity to the site rather than the proposed flaring

7.6.5 The site surrounding the proposed project was viewed as ‘comparatively built up’ but it is built up, with many workers on other sites in very close proximity  and many new houses relatively close to the test site. Several of these developments have occurred since the EA assessment.

7.6.6 The modelling uncertainties associated with such short distances were ‘high’ although exposure, it is speculated, will be low in practice. The EA approach to the proposal at the time was reasonable but with the changes noted above, it is appropriate to re-assess populations and places now impacted by the proposed site.

7.7 All points above reveal significant concerns about poor air quality and their public health effects. In particular, a number of points relate to the Council strategy of sustainable development. The site surrounds are already built up and there were already PECs exceeding critical loads. The proposal will not lessen loads but will almost certainly add to them. It is therefore difficult to establish how such a development can be viewed in any way as a contribution to improving local air quality in the Ellesmere Port area from the hydrocarbon activity itself or from diesels on-site and off-site including transport (See Footnotes 13 and 30 above) .

 IGas commissioned consultant monitoring of the site and estimated background exposures

7.8 Golders prepared various detailed reports and supplementary reports on air quality round the site. The closest residential sensitive receptors to the Site they considered were two consented developments 10/02062/OUT (a mixed-use scheme of employment and residential uses south of the M53) and 12/04369/OUT (a mixed-use scheme located east of Rossmore Road East Consented development). The report notes
“As visualised by the contour maps (Drawings 1 – 6, Appendix A), PECs for all assessed substances are well below the respective Air Quality Standards (AQS) within both consented developments during the proposed DST using a shrouded flare (PWWT flare) and the EWT using an enclosed ground flare (Biogas flare). Potential Air Quality Impacts on Other Sensitive Receptors As visualised by the contour maps (Drawings 1 – 6, Appendix A), PECs for all assessed substances are below the respective Air Quality Standards (AQS) at all sensitive receptors during the proposed DST and EWT flare operations Predicted Environmental Concentrations (PEC) in relation to sensitive receptors and the two consented developments”.

7.9 The gaps in our capacity to assess accurately the possible exposures from the Ellesmere Port proposal are illustrated by the carcinogen benzene. There is an inability to assess short term benzene impacts because there is no short-term AQS for this chemical to provide a benchmark – other chemicals released without a short-term AQS are reportedly ethylbenzene, toluene and xylene. Assumptions have to be made about where maximum exposures will occur and at what level and exposure levels have always been lowered and never raised. In the 1980s HSE argued there was no need to lower the benzene TLV below 10ppm, US OSHA in 1977 proposed 1ppm and adopted it in 1987. Benzene risk assessment models, which attempt to extrapolate risk from high exposure to low exposure scenarios, may under-estimate the level of true risk at low level exposures. Benzene crosses the human placenta and is found in human breast milk. Children and infants may be more susceptible to substances like benzene than adults. A possible relation exists between parental occupational and environmental exposure to benzene and elevated risk of leukemia and birth defects among their offspring exists. NIOSH and US researchers called for lower exposure limit of 0.1 ppm levels in the 2000s and NIOSH now considers there are no safe levels for exposure to a carcinogen. Research on benzene and other fossil fuel ‘products’ have led to radically changed risk assessments by public health researchers as they have done for diesel exhaust emissions listed by IARC as a Class 1 human carcinogen some time ago.

7.10 In an assessment of multiple threats to child health from fossil fuel combustion linked to impacts of poor air quality and climate change, one leading US public health physician who looked at a range of chemicals including benzene came to the following stark conclusion.

“The data summarized here show that by sharply reducing our dependence on fossil fuels we would achieve highly significant health and economic benefits for our children and their future. These benefits would occur immediately and also play out over the life course and potentially across generations”[50]

[50]Perera FP(2017) Multiple threats to child health from fossil fuel combustion: impacts of air pollution and climate change. Environ Health Perspect 125:141–148; http://dx.doi. org/10.1289/EHP299

7.11 The US experience with UGE air quality modelling when it came to their application in the field were that estimates tended to be under-estimates, exposures tended to be higher in certain circumstances and populations affected larger along with inadequacies in buffer zones and no expert consensus on what were safe and unsafe distances.

7.12 It is understood by most parties that the UK UGE industry will always periodically fail to meet regulatory standards. The issue is to what extent this will occur over the short, medium and long-term, with what effect and how good will regulatory surveillance be over the industry if and when it expands its activities in England, and what is its capacity. This is relevant to assessments of flaring and to well and other failures that may present poor air quality risks to the local population. UGE industry compliance with public health controls in the US has been flawed. In the UK, IGas has already received 2 HSE improvement notices over escapes of water from injection well (Appendix 3).It does not follow that there will be problems with IGas flaring and related flare flow rates or well integrity. However, the possibility that there could be should be built into planning considerations linked to actual and not theoretical estimates of populations that could be affected.

7.13 The Golder Associates consultant’s supplementary report on poor air quality for IGas notes “The flare is currently in operation and permitted at Broadford Bridge-1 Well Test in the Weald Basin for Kimmeridge Oil & Gas. However insufficient well flow has prevented efficiency performance data being captured at that site, and no data appears to exist to support the EP1 application”. So again, there is a lack of empirical evidence of flaring at high flow rates where more problems could emerge. The onshore conventional gas industry has experienced significant problems with flaring in large scale enterprises and it is highly unlikely many smaller scale enterprises will escape this problem.

7.14 The IGas consultants correctly provide several caveats, note a number of limitations and identify some exclusions and estimations in their air quality supplementary report. They conclude none of these things indicate a serious problem with the proposal. From a public health perspective, all of these factors continue to raise causes for concern. The Ellesmere Port Development Board Strategic Plan in 2011 (EP19)identified the areas as one for residential development, the current project’s estimates of populations at risk of potential exposure and hence public health risk is likely to be significantly amended.

7.15 Environment Agency OOG screening tool application to the IGas flaring project noted the following with regard to :-

‘”There are one or more human receptors within 200m. There are high modelling uncertainties within this distance. At human health receptors the PEC of at least one pollutant is greater than 70% of an EQS” (EP29).

IGas’s Statement of Case and the Smith Grant Consultants Report

7.16 The IGas appeal against the Council assessment of their planning application specifically notes the Council’s view that one consideration was it did not meet the Council’s Strategic objective 1 on sustainable development (CD4.1 para 4.17).Based on the current state of peer-reviewed and independent public health knowledge described earlier in this report about the UGE industry’s contribution to global climate change and poor air quality, the council’s decision has a strong evidence base that is difficult to rebut. This knowledge is based on additional research not available to UK or English agencies and regulators in 2013 and 2014 when many UGE risk assessments and policies were drawn up.

7.17 The IGas proposal relates to exploring the possibility of UGE development on the site. It does not allow or facilitate development that makes the best opportunities for renewable energy use and generation that reduce or remove poor air quality in piloting and commercial activity: it can only add to air quality burdens. In Appendix 2 2.2.36 it is acknowledged by the company that “the use of flares during DST and EWT represent a source of emissions to air. The emissions are combustion products, with limited potential for emission of un-combusted methane if vented during emergency or start-up of equipment”(CD4.1 Appendix 2 2.2.36). Whilst the PECs recorded for a select group of chemicals were ‘below relevant air quality standards’ in the modelled pilot assessment, they would add, and add even more in commercial production, to the poor air quality burden in an already heavily industrialised area. It is therefore not possible to describe the project as a sustainable and renewable activity.

7.18 There is an additional problem of using the absence of evidence as evidence of absence, as the IGas Statement of Case appears to do, with regard to the health and well-being of residents being protected (Council Policy SOC 5 &1 Appendix 2 2.2.51). The poor air quality risks of such a project linked to its contribution to climate change would indicate public health threats based on research evidence and provide the Council with additional substantial grounds to disallow it. To simply state as IGas do that no relevant technical consultees raised objection to the appeals process does not indicate the project does ensure residents’ health and well-being especially if no directors/consultants/advisors on public health were consulted. There is no reference to ‘public health’ in this IGas statement and just one to environmental health.

7.19 By definition any UGE activity must produce fossil fuels for whatever use and any commercial production will add to global climate change threats, air quality challenges and hence adversely affect public health. This is a binary position. Hence the council’s public health and sustainability concerns have substantial validity and appear quite clear and in line with the state of knowledge. There appears to be nothing in the IGas appeal documents that deal effectively with these public health objections to their proposal. Nor is there any information provided in the body of the document or its appendices to explain and support the company’s argument, in the context of air quality and public health, that the ”benefits of the proposed development are clear and self-evident”(CD4.1: 4). This appears to be an unsupported opinion.

7.20 IGas correctly acknowledges itself that “the proposed development is not renewable or low carbon energy generation and gas exploration and production does inevitably have a carbon change impact”(CD4.1: 10.12).The project is described as ‘extremely short-term’ over 18 weeks but this does not negate the fact that, through poor air quality, it will contribute to carbon impact and climate change and any later large-scale commercial production on this site would have even greater impacts locally and globally. The IGas section here provides no evidence about alternative renewable energy generation and sustainability strategies and their capacity to cut poor air quality and adverse carbon change unlike UGE impacts. The traffic and transport section of the IGas statement also make no specific reference to poor air quality from diesel vehicles(CD4.1: 11.39-11.42).

7.21 The air quality impact assessment undertaken by IGas (CD2.4 Appendix 11) notes a ‘particular focus on ‘impacts to air from the incineration by flaring of natural gas’. As the table in 6.3 p23 has shown, even in 2014, the poor air quality sources of UGE were of course far more extensive. The existing well site relating to this project was granted planning permission in 2010. Since that time far more research has been conducted on UGE air quality impacts and the range of air pollutants from UGE that communities may be exposed to along with their adverse effect on climate change.

7.22 To assess air quality impacts properly it is necessary to know exactly what chemicals and materials are or will be used in the process from beginning to end. IGas have apparently been unable to specify what will be used on site but refer to “natural gas”, which clearly is not “untreated gas”. There are few references to the contaminants that it contains and how they will be managed. Additionally, the wellbore fluid specification is incomplete with its references to “Product has not been tested. Potentially irritating or sensitizing to respiratory system”and so on(9). Whilst the test drilling may determine some of the materials to be used and liberated, it means that a full assessment of the poor air quality hazards and related risks is not currently possible and a number of the conclusions drawn by IGas and their consultants on air quality could be viewed as highly hypothetical and speculative. It is difficult to support the IGas view that appropriate ‘best practice’ (CD4.1 11.62- -11.72)– as opposed to good practice or accepted practice – methodologies have been used with provision and evaluation of this additional information

7.23 The IGas Statement of Case provides details of its air quality modelling approach drawing on established protocols and DEFRA and EA permitting guidance and linked to human sensitive and ecological receptors in industrial and residential areas (CD4.1 11.62- -11.72). The exact basis for and discussion of site selection of receptors and points for and information sources on wind direction for the atmospheric dispersion model are not fully provided here or further justified but they may be available elsewhere in the company’s documentation.

7.24 The expert air quality report by Smith Grant Consultants (SGC) on behalf of IGas (CD4.1 Appendix 6)for their appeal gives much useful detail on the AQIA modelling, additional analysis, consultee responses and additional considerations and observations on the initial Golder report prepared for IGas. It does not reproduce the modelling exercise nor can it address the problems created by the lack of information about the exact process and full range of chemicals that may be used in the test drilling along with all by-products.

7.25 As the 2 tables earlier in the report indicate, it is possible for UGE sites to generate more air pollutants than are listed by IGas and both its consultants’ reports on air quality. Without comprehensive disclosure of all substances by IGas that could be used in the proposed test drills, it is not possible to be sure the monitoring is capable of picking up all the air pollutants. The issue of PECs exceeding respective critical loads due to pre-existing background deposition (for example Appendix 6 2.1.6 p5) and the significance of having a test site in such a location – and the possibility of a commercial operation following – that would add to that load is not discussed. These are important considerations that may go beyond the methodologies of AQIA

7.26 It does identify certain limitations pertinent to the planning regime linked to the need to look at the scale of changes in pollutants. Again, calculations about small scale single site test developments may sometimes miss possible new developments in an area which can affect public health through poor air quality. The SGC report noted the Golder report did not “discuss or consider other potential aerial emissions that may be generated by the Proposed Development such as vehicle exhaust emissions, non-road mobile machinery (NRMM) or dust” ( Appendix 6 2.1.1 p5).Whilst SGC did not consider such sources as ‘likely to be significant’, that is not evidence that they will not be. Again, I cannot identify that all the air quality assessments factored in this project.

7.27 The meteorological modelling by Golder drew on data from Liverpool Airport which is apparently the closest and 5km east of the proposed test site and has been used for other air quality assessments. SGC noted there will be local variations in conditions but these data were considered appropriate (Appendix 6 3.1.3 p10). However, there is no further discussion of the significance of selecting the airport, other alternatives sites that may have been available including past meteorological data gathered from erectable masts or other industrial sites and any drawbacks attached to the meteorological site selected and its data set. In the USA, an air pollution study of one UGE well used a set of meteorological data monitored at ten different stations across the region to input their model ( See Banan: Footnote 31 above).

7.28 The receptors selected by Golder are noted by SGC with the closest residential property receptor being 560m from the site but the criteria used for their selection is not noted. However, SGC comment that “the nearest receptors to a stack or source of pollution are not always those that experience the highest pollutant concentrations due to aspects such as the prevailing meteorological conditions, building influences and terrain influences. In this instance there are also existing residential properties located on Lydden Road 585m to the South South East and Rossfield Road North 650m to the south. These were not included within the model as specified receptor points” (Appendix 6 3.3.3 p11). This was an important oversight, especially alongside the fact that later 2 consented mixed use developments were identified that included residential use closer to the site than the existing properties’ receptors (Appendix 6 3.3.4 p12). Although Golder then made additional contour plots, there will be concerns about the location of the receptors, the later plotting undertaken and the modelling data thus generated.

7.29 As SGC observed with regard to the 2 sites above “….from the information presented it is not possible to determine the predicted PCs at these locations” in what could be considered a major public health shortcoming of these types of AQIAs .

7.30 SGC make additional observations about the possibility of either over or under-estimating background pollutant concentrations in the area and the annualised background data generated from one month in 2017 should be treated with caution although they thought the information was reasonable and accurate.

7.31 The IGas statement of case which contains appendices from consultants dated July 2018 makes no specific reference in the main body of the report to any air quality impacts from diesel due to site operations – either with diesel from plant and machinery or from transport into and out of the site. There are 2 brief references in the 202-page document to diesel linked to road traffic from other sources but not from the IGas proposal. The route for vehicles into the site passes numerous workplaces and there are residential properties to the SE of the road chosen. From the maps available it would appear that this route is outside the 2018 AQM area No 1 for Ellesmere Port. The consultants’ reports examine potential vehicle and plant emissions but also do not refer specifically to diesel exhaust emissions. In addition, there appears to be no reference anywhere in the IGas statement of case to the diesel generating station mentioned in 7.26 above. Yet all these activities will be contributors to poorer air quality with possibly adverse public health effects from the test site (see 5.5 above).

7.32 It should be noted that SGC do identify an additional 4 sites near to the proposed IG site where power will be or could be generated in the future (IGas statement of Case 4.4.1 and 4.4.2 ). These relate to an electricity generating plant and 3 gas generators that will apparently be capable of producing 53.2 mw of power. SGC consider these plants are not expected to create any short-term  or long-term health hazards taking into account the location of human receptors and other factors. “Potential short-term impacts at either human health or ecological receptors are highly  unlikely therefore to be cumulative due to a combination of the separation distances of the plants and differing operational periods”. There are a number of difficulties about this assessment. It is not clear that all human receptors from new developments have now been factored in to the assessment and modelling. Nor is it clear if locations for new developments were monitored. Nor does it appear to consider the air quality impacts  of the construction of such sites and their operation in terms of additional diesel exhaust emissions and dust. In this context of plant construction, operation and related transport, possible PM10 and  PM2.5 exposures are not mentioned. Finally, there appears to be no consideration of the effects short-term exposures may have on residents and workers vulnerable to air pollution within the area  – those with asthma and other respiratory conditions that can be triggered by such exposures– from such sources (see 5.5 of my report above).

8. CONCLUSIONS

8.1 The government’s policy in favour of shale gas development does not support developments that will have a negative public health impact. The balancing act between some forms of economic development and maintaining or improving public health has shifted significantly since 2010. This is based on good scientific evidence in favour of public health and reducing global climate change impacts through poor air quality and greenhouse gases that impact on every locality. From a public health and air quality impact perspective, the IGas proposal does not appear to demonstrate sustainable development (CD4.1 Appendix 2 3.3.18 p33)but rather the opposite.

8.2 Hence it is prudent and cautious not to approve additional industrial developments that will add unnecessarily, in large or small ways, to the poor air quality burden of an area for no benefit to public health while contributing to global and local climate change. We know there will be negative impacts from diesel vehicles and there is toxicological and some epidemiological evidence about the known and possible adverse effects from other air pollutants linked to shale gas extraction.

8.3 The following public health considerations relating to poor air quality are relevant to the Ellesmere Port application and possible ill-health effects for the local population. They raise serious and major questions about the following:-

8.3.1 the lack of a full and up to date assessment of air quality impact of diesel vehicles when the development will necessitate a high number of vehicle movements

8.3.2 the lack of information about the range of chemicals to be used or produced in the well test

8.3.3 gaps in data available and potential under-estimates of possible exposures

8.3.4 the lack of a public health life cycle analysis of the test site along the lines of that advocated by DEFRAs Air Quality Expert Group on Shale Gas. This goes significantly beyond dust, on road and on-site exhaust listed in the SGC report

8.3.5 the initial omissions of information about chemicals to be used or liberated, populations to be exposed and potential exposures in or near the project

8.3.6 the additional information available about the links between poor air quality and ill-health now available

8.3.7 the global and national re-assessments of sustainability linked to climate change and poor air quality

8.3.8 the damage done by fossil fuels in terms of climate change and the importance of renewables in cutting poor air quality and hence reducing morbidity and mortality in all populations, be they local or beyond.

8.4 In terms of the specific questions posed at the start of this report, not all the shale gas project hazards were initially identified or have been fully now. The effects of these hazards combined, and with other hazards in the area, has not been fully factored in to risk assessments of human health linked to multiple pathways to the population around the site. The size and vulnerability of that population has not been fully considered. The capacity to assess the risks of negative air quality impacts to human health is limited and incomplete. The human receptor siting and measuring have been problematic. The evidence base for establishing the risk level is incomplete. The proposal does not reflect the latest peer-reviewed independent research.

APPENDIX 1 – Some relevant academic publications by the Author

  1. Watterson A. editor (2003) Public Health in Practice. Palgrave Macmillan, Basingstoke
  2. Watterson A (2013,2009, 2006, 2003 and 2001 editions) Contributor to Munkman’s Employers Liability ed Bennett D. 16th ed. Elsevier, London pp788-799
  3. Watterson A. Toxicology in the working environment in Rose J. (ed)(1998) Environmental Toxicology: Current Developments. Gordon & Breach Science, Amsterdam,pp225-252
  4. Watterson A (1993) Occupational Health in the UK Gas Industry’. in Platt S, Thomas H, Scott S. and Williams G. in Locating Health. (1993) Avebury Press. London, pp172-194.

Peer reviewed papers

  1. Watterson A and Dinan W (2018) Public Health and Unconventional Oil and Gas Extraction: Global Lessons from a Scottish Government Review. IJERPH. ijerph-251997.
  2. Watterson A Dinan W (2017) The UK Dash for Gas: rapid evidence assessments on health impact assessments. New Solutions. 2017 May;27(1):68-91. doi: 10.1177/1048291117698175.
  3. Watterson A (2016)(editorial) Occupational Safety and Related Impacts on Health and the Environment. Int. J. Environ. Res. Public Health 2016, 13(10), 988; doi:10.3390/ijerph13100988-5
  4. Watterson A and Dinan W (2015) Health Impact Assessments, Regulation, and the Unconventional Gas Industry in the UK: Exploiting Resources, Ideology, and Expertise? New Solutions Journal of Environmental and Occupational Health policy
  5. Brophy J, Keith M, Watterson A, Park R, Gilbertson M, Maticka-Tyndale E, Beck M, Abu-Zahra H et al (2012) Breast cancer risk in relation to occupations with exposure to carcinogens and endocrine disruptors: a Canadian case–control study. Environmental Health 11:87
  6. Van Larebeke N, Sasco A, Brophy J, Keith M, Gilbertson M, Watterson A (2008) Sex Ratio Changes as Sentinel Health Events of Endocrine Disruption. Int Journal of Occupational & Environmental Health

APPENDIX 2 – Sustainable Development

Judging the sustainability of effects is central to the principle of Sustainable Development. Sustainable Development is often defined as “Development that meets the needs of the present, without compromising the ability of future generations to meet their own needs.” (Brundtland Report 1987). However, this can be quite vague, and a firmer foundation can be provided by the following definition:

“Sustainable Development is the balancingof the social, economic and environmental needs of the present with the social, economic and environmental needs of the future.”

And the needs to have a development can, in essence, be a balance of its effects.

This is shown in Figure 1: Sustainable Development.

Figure 1: Sustainable Development

Sustainable Development

Johann Dréo (2006)

Following the definition and diagram above, each effect can be categorised as social, economic and environmental (effects can also be categorised as positive, negative, significant or minor, and this categorisation can be subjective). Depending on whether the effect is negative or positive, where the:

  • Social and environmental effects overlap, it is bearable / unbearable
  • Social and economic effects overlap, it is equitable / unequitable
  • Economic and environmental effects overlap, it is viable / unviable
  • Social, environmental and economic effects overlap, it is sustainable / unsustainable

To come to a judgement on the sustainability of a development, the effects caused in the present, must be balanced with the effects caused in the future.

APPENDIX 3  IGas Improvement Notices

app 3 1 Igas improvement notice part 1

app 3 2 Igas improvement notice part 2

App 3 Drill or Drop I gas escape water pt1.png

App 3 Drill or Drop I gas escape water pt2.png

App 3 Drill or Drop I gas escape water pt3.png

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