APPEAL BY ISLAND GAS LTD, PORTSIDE ELLESMERE PORT
APPEAL REFERENCE APP/A0665/W/18/3207952
PROOF OF EVIDENCE of Professor Kevin Anderson (PhD, CEng, FIMechE)
Chair of Energy and Climate Change, School of Mechanical, Aerospace and Civil Engineering
University of Manchester
Deputy Director of the Tyndall Centre for climate change research
10 December 2018
1. Introduction……………………………………………………………………………………………………. 3
2. Headline Conclusions……………………………………………………………………………………… 6
3. General Issues……………………………………………………………………………………………….. 13
Shale gas is a high-carbon energy source……………………………………………………………………………………………………………… 13
The CCC Report……………………………………………………………………………………………….. 13
Disaggregating emissions to regions and even sectors………………………………… 15
Fugitive Emissions……………………………………………………………………………………………. 16
Energy security – ‘supply’ or ‘services’?………………………………………………………….. 17
Shale gas and medium to long term [in]security……………………………………………… 18
4. Carbon Impactof the Proposed Development……………………………………………… 19
Appendix 1 – Letters from Clare Perry of 15 October 2018 and 8 November 2018 and speech of Michael Gove on 26 November 2018…………………………………………………… 21
1.1 My name is Professor Kevin Anderson. I have examined issues around energy and climate change within the Tyndall Centre (the UK’s leading interdisciplinary and academic climate change research centre) since 2001. Prior to moving to academia in the mid-1990s I worked for a decade as an engineer, principally in the petrochemical industry.
1.2 I am the co-author on a range of reports appraising the climate change and environmental impacts of shale gas, and have undertaken a quantitative assessment of the ‘exported’ emissions embodied in coal displaced, in part, by shale gas in the USA. I was commissioned by the European Parliament Petitions Committee to review the ‘low carbon’ credentials of unconventional natural gas and have acted as a peer reviewer for the Department of Energy and Climate Change report on the same topic. I am regularly asked to present on the implications of shale gas for climate change targets and obligations to, for example, various Parliamentary groups and Political Parties, through to the Scottish and Irish Governments, the European Commission and large financial institutions.
1.3 Over many years I provided scientific evidence to the Welsh Government’s ‘climate change commission’ (CCCW), that subsequently has been used to inform the commission’s guidance to the Welsh Government. In addition to this formal role, I periodically give written and oral evidence to the Environmental Audit Committee and the Energy and Climate Change Committee, and provide ad hocadvice to BEIS, DEFRA, the UK Committee on Climate Change (CCC), and the EU Commission and Parliament. I regularly am asked to present at the annual Party conferences, give seminars to “All-Party Groups” and engage across a breadth of industry stakeholders, NGOs and wider civil society groups. Over the past two years I have held the Zennström professorship at Uppsala University (Sweden). My role there has required me to engage extensively with the development of carbon budgets and climate policies for Sweden’s Läns and Kommuner (local and regional governments) as well as in the drafting of Sweden’s 2018 Climate Change Law (national legislation). In 2017 I was the lead author on a report into Natural Gas and Climate Change; based on this I subsequently engaged widely across the EU member states and the Commission, advising on how the Paris Agreement placed major constraints on gas use and development within the EU. This work has led on to my providing advice to the Commission on their provisional proposals for an EU carbon budget framework.
1.4 I attended both weeks of the Paris COP21 event as a scientific ‘observer’, presenting at a range of formal side events and engaging widely with other scientists, policy makers and media. This has continued through to, and includes, COP24 from 3-14 December 2018. At COP21, several scientific colleagues and I carefully scrutinised the evolving drafts of the Paris text, making clear and public assessments during packed press conferences. I was commissioned by Nature to provide a personal evaluation of the final text of the Paris Agreement.
1.5 I am providing evidence at the behest of Frack Free Ellesmere Port and Upton. In so doing I am acting as an independent expert offering my (pro-bono) services based on my academic and industrial experience. 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.
1.6 All views contained within this statement are attributable to the author and do not necessarily reflect those of researchers within the wider Tyndall Centre or the University of Manchester.
2. Headline Conclusions
2.1 IGas has not calculated the GHG impact of its own proposal.In IGas’s letter of 22 November 2018 they confirmed that the GHG emission figures requested by FFEP&U were not calculated for the planning application and were not requested by the Council and that IGas does not have the information (EP23). Consequently, and in light of UK Government’s rising concern over issues of climate change (see letters from Clare Perry of 15 October 2018 and 8 November 2018 and speech of Michael Gove on 26 November 2018, Appendix 1), that IGas are proposing fossil fuel exploration without even knowing what its GHG impact will be is imprudent, at best. But when considered alongside the CCC’s express conclusion that “it should not be taken as a given that emissions from exploration will be low, especially for any extended well tests.”(CD 8.1, p47), IGas’s failure to assess its own GHG impact is negligent, all the more so for a company operating in an industry so reliant on robust analysis, measurement and compliance.
2.2 Through the Climate Change Act (CD 7.2), the UK has committed to reduce emissions by at least80% of 1990 levels by 2050. This is achieved through Carbon Budgets, which are set out as follows on the website of the Committee on Climate Change (CCC) (EP41) from which an extract appears below:
Table 1 UK Carbon Budgets as defined by the Climate Change Act
2.3 The UK met the first carbon budget and the CCC has assessed that the UK is on track to meet and outperform the second and third budgets. But the CCC has concluded the UK is not on track to meet either the fourth or fifth carbon budgets (respectively, 2023-2027 and 2028-2032).
2.4 In its Fourth Carbon Budget Review (Part 2) in December 2013, the CCC demonstrated how the average emissions of all of the UK electricity generation need to be in the region of 50gCO2/kWh by 2030 (EP41). Put simply, the 50gCO2/kWh limit relates to the total of all emissions released in a particular year, divided by the total quantity of electricity generated by all power stations in that same year; this provides a clear average level of emissions for all power stations. It is this average that the CCC conclude is necessary by 2030 if the UK is to be on the right track to the deliver on its carbon budgets.
2.5 The CCC has a duty to advise the government under the Infrastructure Act 2015 concerning the compatibility of exploiting domestic onshore petroleum, including shale gas, with UK carbon budgets and the 2050 emissions reduction target under the Climate Change Act 2008. The CCC did this in March 2016 in The Compatibility of Onshore Petroleum in Meeting the UK’s Carbon Budget report(CD 8.1, “the CCC Report”). It concluded that exploiting shale gas on a significant scale “is not compatible with UK climate targetsunless three tests are met” (pg 7, emphasis added). I note that this talked about exploitation by fracking, but in GHG emissions terms, exploitation of shale gas by acidisation is likely to have very similar impacts. I will address the three tests in my evidence below. Suffice it to say that none of those tests has yet been met.
2.6 More recently, the International Panel on Climate Change report (SR.1.5) has been published (EP10). The invitation to the IPCC to produce this Special Report was contained in the decision of the 21st COP, which adopted the Paris Agreement (pg 6). The IPCC is recognised by the UK Government as the international authority on climate change. It carries out its work with the help of thousands of climate scientists from around the world, including from the UK, with the MET Office’s Hadley Centre being one of the principal sources of scientific input to the IPCC’s Working Group 1 (on climate science).
2.7 The IPCC Report (EP10)considered what is required to limit global warming to 1.5°C and to 2°C, and what is required to limit the “overshoot” of those reduction targets. In essence, the Report concluded that, in order to achieve a limit of 1.5°C with limited overshoot requires rapid and far-reaching transitions in energy and other systems, much more rapidly than had previously been required. In particular a deep reduction in emissions of methane is required (pg 14). Global CO2 emissions must begin declining immediately if we are to have a chance of achieving a 1.5°C with limited overshoot & without recourse to future ‘negative emissions’ (EP10 plot P1 p.16); this implies still more challenging declines for the UK and other wealthier OECD nations.
2.8 The IPCC Report (EP10) also sets out very clearly that the human impacts of 2°C warming are far more serious than those of 1.5°C warming. It also showed that warming from “anthropogenic emissions” – i.e. emissions caused by human beings – “will persist for centuries to millennia and will continue to cause further long-term changes in the climate system” (pg 7). So every release of GHG emissions is important and impactful.
2.9 Importantly, the IPCC Report (EP10) also notes that whilst emissions from the pre-industrial period to the present will persist for a very long time, they alone are unlikely to cause global warming of 1.5°C. This reinforces the requirement for early action, with the IPCC Report emphasising how immediate and far-reaching steps need to be taken to limit current and future emissions.
2.10 The UK, having ratified the Paris Agreement (PA) (EP46) through the auspices of the EU, is a signatory to the Agreement’s commitments to pursue reductions in emissions commensurate with holding the global temperature rise to no more than 1.5°C. In the absence of planetary-scale negative emissions technologies removing carbon dioxide directly from the atmosphere in decades to come, the IPCC Report notes (EP1016) global emissions need to be 93% below their 2010 level by 2050. Research I have undertaken, in collaboration with Manchester City Council, Greater Manchester Combined Authority, and BEIS, amongst others, puts the UK 2030 mitigation at around 80% (c.f. 2015) and full decarbonisation by 2035-40. This analysis is for 2°C, and so notably much less onerous than for 1.5°C. My provisional judgement is that the reduction levels we calculated for 2°C would need to be brought forward by at least five years.
2.11 Put simply, the UK’s Paris 1.5°C commitment, informed by the 2018 IPCC 1.5°C Special Report, puts such tight constraints on the UK’s available carbon budget that, under any reasonable criteria, new hydrocarbon developments are very difficult indeed to reconcile with the UK’s contribution to limiting warming to 1.5°C. This conclusion only reinforces what colleagues and I have derived from a scientific and mathematical interpretation of the UKs’ 2°C commitments.
2.12 Turning to impacts, three headline conclusions are evident from the 1.5°C Special Report:
2.12.1 The impacts on ecosystems are notably worse for 2°C than 1.5°C. (for example, at 1.5 °C global coral reefs are expected to decline by 70-90%, but be completely destroyed at 2°C).
2.12.2 There is a significant increase of additional feedbacks exacerbating the level of warming (for example, at 2°C, a further 1.5 to 2.5 million km2of permafrost is anticipated to thaw, with significant additional methane emissions).
2.12.3 At 2°C an additional 420 million people will be adversely impacted by climate change than estimated for 1.5°C.
2.13 The purpose of Climate Change Act 2008 was to reduce emissions to avoid global suites of climate impacts. It requires the latest scientific evidence to be taken into account. National Planning Policy requires the planning system to “contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience” (2 para 148). The UK Government has ratified the Paris Agreement. All of this weighs heavily against shale gas exploration.
2.14 The UK Government has recognised the importance of the IPCC Report. On 15 October 2018, in light of the IPCC Report, the Minister for Energy and Clean Growth, Claire Perry MP, asked the CCC to advise on what the UK’s legal obligation under the Paris Agreement means for UK policy and whether the UK’s domestic obligations need to be tightened to meet our international commitments. She later clarified on 8 November that this includes advice on the current carbon budgets.
2.15 In light of the IPCC Report, this is not surprising. The CCC has given its existing advice relating specifically to the ‘80% reduction by 2050’ requirement as defined in the CC Act 2008; the CCC has not yet either analysed nor given advice to Government on the UK’s mitigation obligations under the Paris Agreement. The global, and hence the UK, carbon budget for the Paris “well below 2°C” and “pursue … 1.5°C” framing of climate change are much smaller than those assumed by the CCC in their existing “80% by 2050” analysis.
2.16 I mention this because, if the UK is to meet its Paris temperature and equity commitments, there will need to be a reduction in the UK’s domestic carbon budgets. It is highly likely that the CCC’s requirements set out in the CCC Report (CD 8.6) will be more generous than those forthcoming from the CCC in response to the Minister’s request.
2.17 IGas seeks to ignore or downplay all of these matters. But they cannot be ignored in making planning decisions. The GHG emissions caused by the proposed development will persist for a very long time in the atmosphere. They will impact on the ability of the UK to achieve the radical reductions needed to avoid the extremely serious impacts of warming above 1.5°C.
2.18 Even though IGas propose a short development – from start to finish around 18 weeks – and even though it is just exploration, the release of the GHG that it will cause is neither mathematically nor symbolically compatible with the UK’s ratification of the Paris Agreement.
3. General Issues
Shale gas is a high-carbon energy source
3.1 It is often reported that natural gas has lower emissions per unit of energy than coal. Although the carbon content varies between them, and between production methods, it would be erroneous to regard any fossil fuel as “low carbon”. Fossil fuels are by their nature high carbon energy sources with natural gas (almost identical to shale gas) comprising 75% carbon by mass, and consequently emitting large quantities of carbon dioxide once combusted. The Council’s Local Plan (Part One) is correct when it recognises this. It states: “Fuel derived from hydrocarbons is neither renewable or low carbon.”(CD 5.1paragraph 8.67 p.99).
The CCC Report
3.2 In its letter to FFEP&U on 5 November 2018, IGas stated that the CCC advises that GHG emissions from the exploration phase are generally small. This is only a partial quote from the CCC’s Report, which actually goes on to say the opposite (CD 8.149):
“Exploration emissions are generally small, relating to transporting the seismic equipment and drilling the exploration well. Small volumes of gas may be generated during the development of the well, most of which is likely, at a minimum, to be burned in a flare. There is, however, little information available on emissions associated with exploration. Most studies analysing the GHG emissions from exploiting onshore petroleum either ignore this phase or assume the emissions are negligible. It should not be taken as a given that emissions from exploration will be low, especially for any extended well tests.Appropriate mitigation techniques should be employed where practical.”(emphasis added, footnotes removed)
3.3 The CCC Report sets out three tests that need to be met beforeshale gas exploitation is compatible with UK’s current domestic climate targets. (i.e. not those associated with the Paris Agreement) They are:
Test 1: Well development, production and decommissioning emissions must be strictly limited.Emissions must be tightly regulated and closely monitored in order to ensure rapid action to address leaks. A range of technologies and techniques to limit methane emissions should be required, including ‘reduced emissions completions’ (also known as ‘green completions’) and liquid unloading mitigation technologies (e.g. plunger lift systems) should these be needed;
Test 2: Consumption – gas consumption must remain in line with carbon budgets requirements.UK unabated fossil energy consumption must be reduced over time within levels we have previously advised to be consistent with the carbon budgets. This means that UK shale gas production must displace imported gas rather than increasing domestic consumption.
Test 3: Accommodating shale gas production emissions within carbon budgets. Additional production emissions from shale gas wells will need to be offset through reductions elsewhere in the UK economy, such that overall effort to reduce emissions is sufficient to meet carbon budgets.
3.4 The Third Test reflects the requirements of the Paris Agreement in referring to the obligation to hold the increase in global temperature to well below 2°C and to pursue efforts to limit to 1.5°C (pg.10). The Paris Agreement is also paraphrased in the CCC’s recognition that global warming potential (GWP100) “does not directly measure the effect of emissions on end-of-century global temperature, which is how international climate limits are framed”, and the explanation that the effect of today’s methane emissions will be more significant “closer to the point of peak temperature”.
3.5 Perhaps even more immediately important here, and building on the CCC’s conclusion that the UK looks set to miss both its fourth and fifth carbon budgets, is that there is clearly going to very little scope for offsetting shale-related emissions in other sectors. Add to this the high likelihood that the CCC will recommend tightening the UK’s domestic carbon budgets to align with Paris, suggests there will be vanishingly few opportunities for offsetting, and consequently the CCC’s Third test will not be met.
Disaggregating emissions to regions and even sectors
3.6 Whilst carbon budgets are typically considered at a global or national level, there are increasing examples of methods and analyses that disaggregate this emissions to devolved administrations, regions and even sectors, including by the UK Government.DECC has produced a nationally consistent set of carbon dioxide emissions estimates at Local Authority level (EP45). Clearly, BEIS considers that estimates at Local Authority level are an appropriate metric to use to allow Local Authorities to track their GHG emissions trends over time and to measure progress against any targets they have (EP45 6)
3.7 There are a number of other examples. The Welsh government, Greater Manchester Mayor and Manchester City Council have commissioned projects to estimate the carbon budget and mitigation rates within their respective geographical boundaries. Manchester City Council has now formally accepted a city-level carbon budget, and is developing its mitigation strategies accordingly. More widely, many European and some US cities have used the GRIP methodology to understand the options available to reduce their emissions in line with national headline commitments disaggregated to the city level. In Sweden, over the half of all the Läns (regional governments) are in the process of estimating their geographical and Paris-compliant carbon budgets.
3.8 This approach supports local authorities, such as Cheshire West and Chester, being aware of the level of emissions within their geographical area and taking steps to reduce those emissions.
3.9 The CCC Report expressed concern about fugitive methane emissions from onshore oil and gas wells (CD 8.1see Box 4.1 pg 47). The most recent research shows that methane has been rising rapidly in the atmosphere over the past decade. There remains considerable uncertainty as to the exact cause of this rise, but it does correlate reasonably with the increase of shale gas production in the US. Ultimately, it will likely prove to stem from a mix of sources, ranging from warming wetlands to hydrocarbon production. However, a paper currently in review, and based on a proposed a top-down method, suggests that “shale gas production in North America over the past decade may be the single largest cause for the global increase in atmospheric methane”.If the paper successfully navigates the review process, and other work supports its conclusions, then this will have major implications for any evidence-based development of UK shale gas, all the more given that the CCC’s Test 3 increasingly looks impossible to pass. (EP43)– Howarth paper pg 2).
Energy security – ‘supply’ or ‘services’?
3.10 The issue of energy security is open to considerable interpretation and ultimately not amenable to simple quantitative conclusions.
3.11 In practice, virtually all users of electricity are uninterested in the security of energy supply – the typical default framing of energy security. In contrast, what users desire is security ofthe services afforded them by energy; it is the services that matter directly and energy supply indirectly. This apparently nuanced distinction opens up a much wider framing of “energy security” and what constitutes appropriate approaches for addressing it.
3.12 Most energy services in the UK, whether it is travelling from A to B (or even specifically car travel), having a comfortable home temperature and humidity, enjoying a televisions programme, or chilling a beer – all are typically done using highly inefficientThe mean car on the UK street has emissions of over 160gCO2/km, yet across all categories (excluding high power SUVs) there are over 200 model variants of standard-engine cars (i.e. not electric or hybrid) with emissions of under 100gCO2/km being sold at little to no price premium. The UK housing stock has a typical Energy Performance Certificate rating of D or below – yet retrofitting could see this rise to at least a B rating – with new passive house designs being zero energy. Televisions and IT equipment have huge variations in energy consumption for essentially the same level of service, – a situation that holds for refrigerators where an A rated design of the same size consumes in the region of 80% more energy than an A+++ alternative; again at very little price penalty.
3.13 If energy ‘service’ security is seen as a pivotal issue, then the most cost effective and long lasting means of improving it is to reduce the energy required to provide the service. There are many analyses that demonstrate factors of 4 or more improvements in mean efficiency levels at often zero or negative cost. However, what is often missing from such analyses is “Jevons’ paradox” – or as it more commonly referred to in the energy realm – rebound. This is where money ‘saved’ through energy efficiency is then spent on further energy services. Amongst those living in fuel poverty this is a progressive response that is, at least in the short-term, to be welcomed. But amongst those already energy-rich this increases energy demand and undermines some of the security benefits of energy efficiency. Consequently, if energy service security is a genuine concern, a suite of carefully designed polices are required to ensure the gains intended are realized and that perverse outcomes are avoided, or at least mitigated.
3.14 Despite rebound issues, the potential for improving energy service security through efficiency improvements combined with sophisticated umbrella policies is very significant – and far more cost effective than simply increasing energy supply.
Shale gas and medium to long term [in]security
3.15 Shale gas development in the UK is probably the most publicly contested source of energy – certainly it is on a par with nuclear, at least in terms of local opposition. This itself only adds to ‘insecurity’ of supply. Will it proceed or will it not; will it proceed here but not there; will it face ongoing public opposition. In a highly populated nation (England has a population density over three times that of China), extracting gas via a process that requires an enormous patchwork of industrial infrastructure (in contrast to say Wytch Farm in Dorset) will inevitably face opposition. Regardless of the cogency and legitimacy of such opposition, it will always play against issues of security of energy supply.
4. Carbon Impact of the Proposed Development
4.1 It is undeniable that the proposed development will cause GHG emissions. Those emissions will be released during its construction, operation and decommissioning.
4.2 IGas should have calculated the GHG emissions for the proposed development so that its impact could be known. That calculation should have included provision for fugitive emissions, cold venting, flaring, ancillary plant, transport, and construction, decommissioning and restoration. Since IGas has failed to undertake these calculations, the true extent of the GHG impact of the proposed development is unknown.
4.3 Given IGas is a commercial company it is only reasonable to view its proposal as an integral part of its broader intention of becoming a major UK producer of shale gas. This view is borne out by the fact that IGas seeks to justify the proposed exploration works using arguments about natural gas supply, energy security, government support for the shale industry, the economic impact of the production phase and national economic impact, all of which relate to production at scale and the creation of a UK shale gas industry [Appeal StatementCD 4.1paragraphs 7.8; 7.30; 9.13; 9.20-21; 9.27; 9.38; 9.40; 9..44; 10.10; 12.4]. As a simple matter of logic, the exploration phase does not actually provide any of these benefits. Those benefits (some of which are contested anyway – see above) could only logically be relied on if the IGas proposal was for production. If the “benefits” of production are going to be used to justify the exploration stage, then it follows that the impacts of production should also be applied. The GHG impacts of shale gas productions are likely to be significant. As the CCC Report showed, they are not compatible with the UK’s climate targets (even at 2°C) until the three tests are met. With the CCC concluding that the UK is set to miss both its fourth and fifth carbon budgets, it looks highly unlikely that meeting the third test is possible.
4.4 From a near-term emissions perspective, it would be unwise to proceed with the exploratory proposal as its unknown level of emissions would reduce still further the small 2°C carbon budget (and even smaller 1.5°C carbon budget) available to the remainder of the UK generally or Cheshire West and Chester more specifically. In the medium to longer term the evidence leads to a more concrete conclusion. Locking the UK into several decades of high-carbon fossil-fuel use is increasingly at odds with the UK’s existing domestic carbon budgets (i.e. fails Test 3), and is categorically incompatible with the UK’s commitments under the Paris Agreement.
Professor of Energy and Climate Change
School of Mechanical, Aerospace & Civil Engineering
University of Manchester
PA- Amrita Sidhu, firstname.lastname@example.org; tel: +44(0)161 306 3700
Uppsala University, Sweden.
Deputy Director of the
Appendix 1 – Letters from Clare Perry of 15 October 2018 and 8 November 2018 and speech of Michael Gove on 26 November 2018
 This is just a simple molecular weight calculation for CH4 , C=12, H4=4; so 8 out of 12 = 75%. And when combustion occurs the C reacts with O2 to become CO2. This calculation does ignore the very small % of VOCs etc.