- NB: CHEM Trust’s focus is on the toxic effects of pollutants, and so these recommendations don’t consider fracking’s effects on climate change and its potential to cause earthquakes.
In CHEM Trust’s view there should be an EU-wide moratorium on fracking until all our recommendations are in place.
- The European Commission’s January 2014 recommendations on fracking need to be turned into legislation. Without effective and legally binding legislation designed to deal with fracking, then people and wildlife in the EU are not going to be properly protected.
- All fracking operations, including exploration, should be covered by Environmental Impact Assessments.
- It is clear that faulty wells are a major pollution risk, therefore the quality of well construction and safety standards must be strongly regulated and enforced.
- The toxic and possibly radioactive waste from fracking will require careful disposal and should be addressed specifically in EU regulations. In particular, underground disposal of wastewaters (e.g. through re-injection) should be banned.
- Companies undertaking fracking should have to deposit bonds sufficient to cover any future compensation claims and to pay for clean up at the end of the life of the well. A failure to have sufficient resources in restoration bonds for the clean up of opencast coal mines is now creating a major social and environmental crisis in Scotland.
- There must be full public disclosure of all the chemicals used, with adequate data on their hazard profiles, and clear, publicly available, assessment?of all the potential health and environmental effects. There should be no opportunity for industry to withhold chemical identities based on claimed commercial confidentiality.
- Manufacturers and distributers of chemicals must produce and communicate human and environmental exposure scenarios for fracking substances. These ?exposure scenarios should be publicly available, and must make clear what are the assumptions made in calculating adequate control, for example, with respect to the storage and fate of flowback.
- In addition, the analysis of chemical risks relating to fracking (including exposure scenarios) should consider the impacts of leakage from the well and the above ground piping, storage and transport, as these are clearly foreseeable risks.
- Under the supervision of a regulator, operators of fracking wells should undertake extensive air, land and water monitoring in the vicinity of their sites prior to, during and after the operation. This is to ensure that clear baselines are set and any subsequent pollution is apparent.
- There should be detailed and ongoing inspection of operations by independent experts in geology and ground water protection, to ensure safe well construction and proper disposal of all chemicals, including contaminated water, muds and other wastes.
- There must be systems in place to identify emerging chronic or acute health effects in workers, residents, livestock and wildlife.
- Even when wells are exhausted and sealed, they remain a threat to ground waters and must be monitored. Operators need to commit resources to ensure that any future problems are identified and can be remediated.
- The regulation and monitoring of a large number of fracking wells will be a challenge for regulators. There must be sufficient staff and resources to do this job effectively. This is a particular concern in the UK, where the staffing of regulators such as the EA has been reducing in recent years.
- It is also vital that regulators have sufficient expertise in the full range of issues relevant to fracking, including, for example, the safety of wells.
- The vulnerability of ground waters to pollution from fracking should be recognised and there should be no operations in groundwater source protection zones.
- There should be no fracking on, near, or underneath, key wildlife sites, including Natura 2000 sites (both Special Areas of Conservation (SACs) and Special Protection Areas (SPAs), and in the UK, National Parks and Sites of Special Scientific Interest (SSSIs).
- Local communities should be involved in any decisions on fracking in their area; see the Friends of the Earth position on fracking for more information on this and other issues.
- Regulators must forbid fracking where there is insufficient water available for the fracking operation, or if extracting this water will negatively affect wildlife or people.