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Fax 020 7827 5862
www.cieh.org
President
Janet Russell OBE CFCIEH
Chartered Environmental Health Practitioner
Chief Executive
Graham Jukes OBE CFCIEH
Chartered Environmental Health Practitioner


The CIEH is a registered charity
incorporated by Royal Charter
(No 290350)
7 August 2014



Dr. James Verdon, Ph.D., M.Sci, MA (Cantab),
NERC Research Fellow
School of Earth Sciences
University of Bristol
Wills Memorial Building
Queen's Road
Bristol BS8 1RJ



Dear Dr Verdon

Shale Gas and fracking: examining the evidence

Thank you for your recent letter in response to the publication of the joint CIEH and SGR
report. Your extensive comments can be broken down to 4 generic criticisms/allegations
relating to this work:

1: That the work is not impartial (which you state the report claims - which it does
not) specifically because of Gwen Harrisons association/involvement with the
Green Party and full engagement with civil society which you assert is a conflict of
interest.

2: You accuse the authors of cherry picking evidence.

3: You suggest the publication would not meet peer review standards and you
consider the work represents a shocking lack of scholarship.

4: That (because of the above criticisms /assertions) the work negatively impacts on
the standing of CIEH and its members.

I comment on those general points below and specifically in the tabulated appendix
(attached) on each point. To aid clarity I have placed your letter alongside the response
in the appendix and followed the structure and headings of your letter.

Point 1: Impartiality
There is no claim anywhere in the report that it is impartial. However, it is in line with the
CIEHs declaration of following a precautionary approach to ensure public protection. We
fully agree with the point you have made in your letter i.e. that activities within an
individuals personal life should not preclude a contribution from that individual to
professional work (where that individual has experience and/or expertise to contribute).
In that context Gwen Harrisons involvement in this work is entirely appropriate. In the
same vein your comments can not be regarded as impartial either due to your publicly
available opinions available on social media sites - but your expertise is acknowledged
nonetheless.






Point 2: Cherry-picking Evidence
Your comment is rejected as it is not based on fact. Whilst perhaps the briefing should
have not only had a references section but also a bibliography, (although this is NOT
intended to be an academic publication), there is a distinction between what was read by
the authors in the preparation of this work and what was cited. In your comments, as
identified in the attached appendix you stand guilty of the very criticism you are levelling.

Point 3: Standard of Work and Peer Review
It has not been claimed, nor was this intended to be, an academic paper written for peer
review. If you are intending your comments to be regarded as a peer review we would
regard that as inadequate, as solitary reviewers run the risk of making comments that are
in fact opinion. This work however was a collaborative project with more than one author
and moreover, others had opportunity to comment on the draft text including the CIEH
Professional Standards and Policy Committee.

Point 4: Impact on CIEH Reputation
The CIEH having considered in detail your letter and the response of the authors of the
joint report, rejects your conclusions. The CIEH stands by publication of this document
and considers it is a valuable addition to the debate surrounding this subject area. The
report is proving to be extremely helpful to those who are charged with regulating and
advising on fracking proposals.

There is no evidence that you have presented to me to substantiate a claim of breach of
the CIEH code of conduct and I regard your expressed concerns as unfounded.

Prior to publication the report was circulated internally for comment and those comments
were taken on board by the authors as indicated above. Final copy was submitted to me
and published under my authority as a document worthy of carrying the quality mark of
the CIEH.

While I reject your conclusions I am nevertheless appreciative of the time and effort you
have taken in expressing your view to us and for the opportunity afforded by this
correspondence to clarify your misinterpretations.

Yours Sincerely

Graham M Jukes OBE CFCIEH
Chief Executive

Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014


Letter from Dr James Verdon


To the board of the Chartered Institute for
Environmental Health, I am writing in
response to your recent report, Shale Gas
and Fracking: Examining the Evidence
published in tandem with Scientists for
Global Responsibility (SGR). This report
claims to provide an impartial and
evidence based review of the issues
surrounding shale gas extraction in the UK.

The authorship by professional bodies lends
weight to this evidence-based impression.
However, by any standard of scholarship
this report falls well short. Factual errors,
cherry picking of scientific literature,
omissions of key facts and scientific papers
abound throughout the report. The purpose
of this letter is to draw your attention to
these errors, and to raise my concerns
about the implications of CIEHs
endorsement of this report. I will begin by
addressing some of the major issues found
in the report. I will do so in a manner
analogous to that with which I am most
familiar, namely that of scholarly peer-
review.






Authorship
I note in passing that the lead author of the
report recently stood for election for the
Green Party. Given that Green Party has
campaigned vigourously against shale gas
development in the UK, I feel that this
represents a conflict of interest. Moreover,
judging by her own comments on twitter,
the lead author appears to have joined
protest marches against shale development
at Barton Moss. Of course, personally-held
views do not necessarily preclude a
professional author from penning an
impartial report on a subject on which they
Response by the CIEH and SGR on the
points raised by Dr James Verdon

The covering letter to which this appendix
is attached rejects the assertions made by
Dr Verdon in his opening remarks.

What follows is a dissection of the points
that he has made to ensure that readers of
the report are in no doubt as to our
assertion as to its quality and validity.

In comment on the background to the
production of the report. The report arose
out of a concern that the UK government
was championing a new fossil-fuel
technology based on narrow economic
considerations without adequate attention
to environmental and social/ health
concerns. Claims were being made by
government and industry that seemed to
have very limited evidence to support them.
A key aim of the report therefore was to
critically assess such claims, with reference
to the available peer-reviewed literature, as
well as wider sources. In addition its
publication in partnership with the
Chartered Institute of Environmental Health
provided the opportunity to merge the work
that CIEH had done to support the
knowledge base of the profession and the
CIEH members on the ground who will be
called upon to advise the local government
planning process.

Authorship
There is no claim anywhere in the report
that it is impartial. We accept that activities
within an individuals personal life should
not preclude a contribution from that
individual to professional work (where that
individual has experience and/or expertise
to contribute).

Impartial reporting on any area of policy-
relevant science and technology is difficult
to achieve. While we have made no such
claim for the impartiality of this report and
you are misquoting us on this point, we do
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

are wholly partial, or indeed have a conflict
of interest. However, given the issues
raised below, one is left with the feeling
that the SGR/CIEHs stated aim of
producing an impartial, evidence-based
report was doomed from the beginning
based on the choice of lead authorship.












































maintain that the report is robust and is in
line with the CIEHs consideration of the
precautionary principle to ensure public
protection, which is extremely relevant
when assessing the impacts of proposed
development.

In an area such as shale gas and fracking in
the UK, there are large uncertainties in key
areas and significant gaps in the evidence
base, so the scope for different
interpretations is large. It is unsurprising
therefore that an academic working on
projects associated with the oil and gas
industry would have a different
interpretation to ours.

Regulatory regime
We note that there are no criticisms of the
section of the report, Regulatory regime.
Concerns about the robustness of the
regulatory regime in the UK are a central
theme of this report, which we have
emphasised. Within our report, we have
highlighted numerous concerns and
recommendations made by a range of
stakeholders, including the Royal Society,
the European Commission, and from within
the Environment Agency. Further and direct
high level discussions between the CIEH
and the Environment Agency post
publication of this report, in particular
around the comments in paragraph 2.5
reveal an acknowledgement of the issue of
scarce resources. We have however been
advised that reprioritisation of resources to
effectively deal with the permitting
requirements of fracking proposals is
addressing this issue, in that agency.

The CIEH has voiced specific concerns
about the effect cuts in local government
resources are having in maintaining
effective regulation and the tripartite
regulatory control mechanisms currently in
place will have to be suitably coordinated to
ensure that regulation is applied
appropriately and effectively, which will be
a continuing challenge in todays financial
climate.

Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014


1. Introduction
SGR/CIEH make the following claim to
differentiate shale and conventional gas
extraction: Unlike in conventional wells,
fracking in shale requires horizontal
drilling [and] huge numbers of wells. The
implication is that conventional
hydrocarbon recovery requires neither. In
point of fact, lateral well drilling is
now commonplace in conventional
reservoirs. Indeed, the technique was
pioneered in the U.K. in the Wytch Farm
Field in the early 1990s. Equally, tight
clustering of wells is common in onshore
conventional fields, especially those of
an older vintage. 5-spot drilling patterns on
a 10, 20 or 40 acre spacing is
common in North American conventional
reservoirs, and is easily as dense as the
number of wells used to extract shale.




























Introduction
In response to Dr Verdons comments on
the first section of the introduction, the
overall point made is that the process of
extracting shale gas is very different from
conventional gas, because fluids are unable
to flow as freely as they might in more
porous rocks such as sandstone. The
Advertising Standards Agency upheld a
complaint against Cuadrilla for suggesting
otherwise, as we highlight in our report.
Our point is supported by, among many
others, the International Energy Agency in
its World Energy Outlook, which states that
unconventional gas sources are difficult to
extract because they are trapped in very
tight or low permeability rock that impedes
their flow [and thus] the scale of the
industrial operation required is much
larger than for conventional production.
This means that drilling and production
activities can be considerably more
invasive, involving a generally larger
environmental footprint
1
.

The report goes on to suggest that One
feature of the greater scale of operations
required to extract unconventional gas
[compared with conventional gas] is the
need for more wells. Whereas onshore
conventional fields might require less than
one well per ten square kilometres,
unconventional fields might need more than
one well per square kilometre. This report
does qualify this statement by saying that
It should be noted that conventional gas
fields in mature areas, such as onshore
United States or Canada, often have well
densities comparable to those of
unconventional gas. However, burgeoning
unconventional gas production today tends
to replace production that would have come
from offshore locations or countries rich in
conventional gas, such as Russia or Qatar,
in which the well densities are much
smaller. So while there are undoubtedly
cases in which conventional gas fields can

1
p18:
http://www.worldenergyoutlook.org/media/weowebsite/2012/goldenrules/weo2012_goldenrulesreport.pdf
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014






2.1. Seismicity
SGR/CIEH make the unsubstantiated
assertion that UK geology is substantially
more faulted than that of North America. In
reality, the geology across multiple shale
plays across the North American continent
is highly variable. Some shale plays are
indeed relatively undisturbed. However,
others are not. Moreover, even plays that
appear flat can contain substantial faulting.
Microseismic data reveals potential faults
structures in approximately 30% of
datasets recovered in the USA faults are
far from rare. However, only a small subset
of faults those near to their critical failure
stress might be re-activated if they are
impinged upon by a hydraulic fracturing
operation.
The SGR/CIEH comments on Cuadrillas
Preese Hall well imply that the induced
seismic activity may have impinged on
wellbore integrity. The reality is that
casing deformation was limited to the lower
part of the production casing string
the part of the wellbore in which holes
have already been punched to allow gas
to flow. It is irrelevant to talk of well
integrity in a part of the well casing that is
intentionally left open to produce gas.
Shallow groundwater sources are
protected by different, shallower casing
strings. There has been no suggestion
that these strings were damaged by
seismicity, nor that wellbore integrity has
been compromised.
More generally, the Preese Hall seismic
events, at magnitude 2.3 and 1.5, are
relatively small, even by UK standards. The
UK experiences over 50 such events
each year, and typically experiences one
magnitude 4 earthquake every 1.5
years, which is almost 1,000 times larger
than the Preese Hall events. In
addressing whether seismicity poses a risk
to wellbore integrity, the authors
might have been better exercised by
have well densities comparable to those of
unconventional gas fields, it is clear that, as
a general rule, this is not the case, and it is
misleading to suggest otherwise.

Seismicity
Instead of asserting that UK geology is
substantially more faulted that that of North
America, as Dr Verdon suggests, we use
the rather more measured statement that
Britain tends [emphasis added] to have
more complex and fractured geology [than
the US]. Of course there are parts of the
US with very complex geology, but that
particular statement was intended as a
general one. We go on to be more specific
by highlighting that the Fylde, home to the
UKs only fracked shale gas well, is known
to be faulted, and that the BGS has warned
against fracking in faulted areas.

We fully acknowledge Dr Verdons
assertions that the UK experiences many
(small) earthquakes each year, and that the
magnitudes of the Lancashire ones were
relatively low (hence our statement that
While fracking activities triggered the
earthquakes, they may have occurred
naturally at a later date and, given their
relatively low magnitude, it is unlikely that
similar events would cause significant
damage to properties and infrastructure.
However, the fact remains that the two
earthquakes in Lancashire were triggered
when the UKs only shale gas well to date
was fracked, and that these earthquakes
damaged the wellbore so severely that the
well had to be abandoned. We do not
imply that this damage impinged on
wellbore integrity in this case. We merely
highlight that such incidents, which damage
a wellbore to that extent, have the potential
to result in integrity failure. We
acknowledge in the report that data are
lacking in this area, with the implication
that further work needs to be done to
establish whether or not this represents a
potential problem.



Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

considering whether these regular
occurrences have posed wellbore integrity
issues for the 2,000 onshore, and over
10,000 offshore, wells that have drilled in
the UK.

2.2. Water and ground contamination
SGR/CIEH cherry-pick the study by Jackson
et al. (2013) in their discussion of
groundwater contamination. Such cherry-
picking gives the misleading impression that
this is the only study performed in the
region, when it is in fact only one of many.
Moreover, SGR/CIEH neglect to discuss the
myriad issues raised over this paper, for
example the limited number of water wells
sampled (140), the non-randomness of the
sampling process, and the lack of a baseline
for comparison. There have in fact been
numerous studies of groundwater in the
Pennsylvania region and further afield. For
example:
Molofsky et al. (2013), who studied over
1,700 wells in Pennslyvania, with some that
included baseline conditions, and found no
correlation between methane and shale gas
wells (and found correlation instead with
topography, implying a natural methane
source).
A study of 230 water wells made by the
Centre for Rural Pennslyvania, which found
no impacts from shale drilling.
A baseline study made by the USGS in
undrilled parts of Sullivan County, PA,
which recorded similar levels of naturally
occurring methane to those found by
Jackson et al. (2013).
A second baseline study made by the
USGS across the Pennsylvania-New
York border, which again recorded similar
levels of naturally occurring methane to
those found by Jackson et al. (2013).
The study performed by Warner et al.
(2013) - the same Duke University
team as Jackson et al. (2013) over the
Fayetteville shale, Arkansas, which found
no impact from drilling.
The fact that all of these studies have been
neglected represents a serious omission
from the report. Similarly, the failure by
SGR/CIEH to examine in any detail the raw






Water and ground contamination
Dr Verdons suggestion that we have
cherry-picked one study and given the
misleading impression that this is the only
study performed in the region does not
acknowledge the context within which this
study was referenced. There are, of
course, examples of studies which have
found no evidence of contamination, as Dr
Verdon rightly points out. We referenced
the Jackson study (and others) as examples
of ones which found evidence of methane
contamination, in order simply to counter
claims by Cuadrilla (and many others within
the industry) that no such evidence exists.
We make no suggestion, either implicit or
explicit, that the studies we referred to are
the only ones in the region. We go on to
say very clearly that local environmental
impacts may be less severe in the UK than
in the US, due to more stringent (though
still inadequate) regulations, and that the
reality is likely to lie somewhere between
what proponents claim and opponents
fear. We believe this to represent a fair
and balanced assessment of the situation,
which is largely unknown for the UK.


















Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

statistics of PA DEP infringements leads
them to make misleading statements
regarding well integrity. Considine et al.
(2012) did so, and found that of over 3,500
shale gas wells drilled in Pennsylvania, only
2 had caused stray gas migration into
shallow groundwater, which represents a
failure rate of 0.06%. In both cases, repairs
were made to the offending well, and water
quality remediated. These findings mirror
those made by the Groundwater Protection
Council (2011), who studied tens of
thousands of wells in Ohio and Texas,
finding well failure rates of less
than 0.1%.

2.3. Water use and waste water
In their discussion of water consumption,
SGR/CIEH make the claim that wells
are generally fracked several times over
their lifetime. This is erroneous. Almost
all shale wells are only ever fracked once.
With respect to water consumption, the
reader would surely be better informed
if the authors were to consider water
consumption over the full life-cycle of shale
gas extraction, and in comparison with
other forms of energy generation. Such
studies exist in the literature, but have
been neglected by SGR/CIEH. For example,
Clark et al. (2013) find that shale gas use in
the power sector represents only an
incremental increase in water consumption
compared to conventional gas. Similarly,
Scanlon et al. (2013) found that shale gas
consumed substantially less water than coal
in electricity generation, and that the switch
from coal to shale gas played an important
role in adapting to recent droughts in
Texas. The memorandum of understanding
signed between Water UK and the UK
Onshore Operators Group (UKOOG) is also
surely of significance to this discussion.
With respect to the NORM content of
flowback water, SGR/CIEH neglect recent
work by Almond et al. (2014), who
examined this issue in detail, and found
that in no scenario was the 1%
exceedence exposure greater than 1mSv
the allowable annual exposure allowed for
in the UK, and that the radioactive flux
















Water use and waste water
We concede that instead of stating that
wells are generally fracked several times
over their lifetime we should have said
wells are sometimes fracked several times
over their lifetime. Dr Verdon suggests
that Almost all shale wells are only ever
fracked once. We would be interested to
see any data Dr Verdon has on the refrack
rate among shale gas wells drilled to date
which supports his assertion.
That fracking is water-intensive is
undisputed. The extent to which this
represents a problem, however, is the
subject of much discussion, which is a very
long way from achieving consensus. It was
beyond the scope of our report to carry out
a detailed analysis of the evidence on water
consumption, and we therefore did not
make any claims of our own on this matter.
Instead we simply presented the views of
Water UK (the water trade body) and the
Chartered Institute of Water and
Environmental Management (CIWEM).
These bodies, respectively, have warned
that Where water is in short supply there
may not be enough available from public
water supplies or the environment to meet
the requirements for hydraulic fracturing
and Climate change scenarios predict less
water availability in the future so whether
this level of water use is appropriate in the
long term to source energy requires further
research.

Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

of per energy produced was lower for shale
gas than for conventional oil and gas
production, nuclear power production and
electricity generated through burning
coal.



























2.4. Local air quality
In the section on air quality, SGR/CIEH
present no data pertaining to air quality
during shale development, and are only
able to make unsubstantiated assertions.
However, such data is available: for
example Bunch et al. (2014) examined
extensive air quality measurements made
over the Barnett Shale, and did not
find levels of air pollution that would cause
concern. Similar surveys in Pennsylvania
made by the PA DEP (2010) "did not
identify concentrations of any compound
that would likely trigger air-related health
issues associated with Marcellus Shale
drilling activities", and overall emissions
inventories show a reduction in air pollution
as power generation has switched from coal
to shale gas (PA DEP air emissions
We would also point out that making
comparisons between life-cycle
assessments of different fuel sources, as
presented by Dr Verdon, can obscure the
problems arising from high levels of water
use on a specific site.
With regard to Dr Verdons comment on the
NORM content of flowback, we have made
no judgement as to whether or not these
levels are acceptable (indeed have made no
specific mention of NORM). We simply
state that fracking fluid returning to the
surface is now classed as radioactive waste
(following the introduction of new European
legislation in 2011), and is thus likely to
require off-site treatment and disposal. Our
point is not that the levels of radioactivity
are particularly high, and therefore harmful
(which Dr Verdons response seems to
imply), but simply that the high volume of
waste water classified as radioactive and
therefore probably (though not definitely)
requiring offsite disposal is likely to place
a burden on waste water treatment
infrastructure.
Dr Verdon does not dispute the high
number of daily vehicle movements
required to transport water and waste
water to and from the site a primary
concern for those living close to fracking
sites.

Local air quality
The intent of this section, as with other
aspects of the briefing, was to provide
context and overview. We would assume
that Dr Verdon would not dispute that there
are in fact 3 potential sources of air
pollution from fracking operations as we
have outlined, namely impacts arising from
underground activities; on site operations;
and vehicular movements to and from the
site.
Regarding Dr Verdons claim that this
section contains unsubstantiated
assertions we would not concur with this
opinion. He will note the use of words like
can and may within the text. We are
confident that the vast majority of scientists
would not disagree with any of these
qualified statements for example the
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

inventory, 2011). Given that such data is
available, I find it disappointing that
SGR/CIEH did not make use of it.












































fracking process within the well itself which
may release a range of airborne
contaminants or local air pollutants from
fracking can include volatile organic
compounds (VOCs), particulate matter
(PM2.5 and PM10) and nitrogen oxides
(NOx).
We are aware of studies elsewhere, most
notably the US, including those sources Dr
Verdon cites in his correspondence which
offer evidence suggesting no major issues
with the specific pollutants assessed in
those studies. However, we are also aware
of other work suggesting that despite a
growing body of evidence, a number of
data gaps persist. Most importantly, there is
a need for more epidemiological studies to
assess associations between risk factors,
such as air (and water) pollution and health
outcomes among populations living in close
proximity to shale gas operations.
2

With regards to the Bunch et al study, this
work focused on Volatile Organic
Compounds (VOCs). As such the scope of
the work, whilst extensive in terms of the
measurements made, nonetheless did not
cover pollutants of current concern within a
UK context and in particular those typically
associated with traffic and other uses of
internal combustion engines i.e. particulate
matter (PM) and NO2. We would suggest
that Dr Verdons claim regarding the Bunch
et al study that the work did not find levels
of air pollution that would cause concern is
somewhat misleading as it does not qualify
the statement. More accurately this work
did not find levels of VOCs that would cause
concern. However, as outlined in the
preceeding paragraph there is other, more
recent work, suggesting that further work is
needed across a wide range of air
pollutants.
Dr Verdon will also undoubtedly be aware
that for the UK, air pollutants such as
PM2.5, PM10 and NOx (particularly NO2)
remain a concern. He will be aware, as
cited in the text, that the Commons

2
http://www.researchgate.net/publication/261741800_Environmental_Public_Health_Dimensions_of_Shale_a
nd_Tight_Gas_Development
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014


























3. Climate change
The most notable omission in this section is
the findings of the IPCC made in the recent
Fifth Assessment Report. In this report, the
IPCC state that in mitigation scenarios
reaching about 450 ppm CO2eq
concentrations by 2100, natural gas power
generation without CCS acts as a bridge
technology, with deployment increasing
before peaking and falling to below current
levels by 2050 and declining further in the
second half of the century. The IPCC have
made it clear that they see natural gas
extracted from shale as a key component of
greenhouse gas mitigation strategies from
now until 2050.
In their assessment of the impact of shale
development on renewable investment,
SGR/CIEH neglect the potential positive
impacts of abundant natural gas on
deployment of renewables. A report by the
Brattle Group (2013) found a strong
complementary relationship between
Environmental Audit Committee is currently
conducting an inquiry (following on from its
2011 Report). In February 2014 the EU
Commission issued the UK Government
with a Letter of formal notice for breaching
nitrogen dioxide (NO2) limit values in 16 of
43 zones across the country
3
. NO2 is a
pollutant typically closely associated with
the use of vehicles and specifically internal
combustion engines. Whilst we
acknowledge that the problem is
particularly acute in urban areas, it is
unclear at present how widespread
introduction of fracking across the UK
would impact on this specific pollutant and
indeed others associated with increased
vehicular movement.
With regards to the potential for shale gas
to reduce overall air pollution within the UK,
we accept that future possibility. However
to achieve this will be dependent on a wide
range of factors. Leaving aside traffic
emissions, key amongst will be a switch
away from/phase out of coal.

Climate change
Concerns about the role of shale gas in
undermining action on climate change were
a central thrust of the report. We first
address Dr Verdons specific comments and
then make some broader comments.

Firstly, his statements regarding the IPCC
are selective and misleading.

The fact that the IPCC Fifth Assessment
Report (AR5) states that natural gas power
technology is a bridge technology does not
necessarily imply that shale gas will play
any significant role in curbing GHG
emissions. Indeed, we note that the median
scenarios presented in AR5 for stabilising
atmospheric concentrations between
430ppm and 530ppm indicate that total
carbon emissions from all natural gas
sources would be about 100 GtC (Figure
6.15, Chapter 6). This is about the same
size as the carbon locked up in the worlds

3
http://europa.eu/rapid/press-release_IP-14-154_en.htm
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

renewables and natural gas, because the
flexibility of natural gas provided backup to
intermittent renewables in a way that coal
and nuclear power cannot. This relationship
is evidenced by the fact that Texas, a
leading state in terms of shale gas
development, is also leading the way with
respect to renewable, and especially wind,
energy.








































current reserves of conventional gas (Figure
7.2, Chapter 7). Hence, burning any of the
reserves of unconventional gas (including
shale gas), without Carbon Capture and
Storage (CCS) technologies, would likely
take emissions beyond that level. And it is
important to note that these scenarios also
require unabated coal use to virtually halt
now. If this does not happen (which is, of
course, highly unlikely), the necessary
restrictions on natural gas use will be even
greater. We note that the uncertainties in
these scenarios are significant, but with
reserves of unconventional gas being
considerably larger than those of
conventional gas, the potential for us to far
exceed internationally agreed targets
through exploiting these reserves is very
real.

Dr Verdons statement The IPCC have
made it clear that they see natural gas
extracted from shale as a key component of
greenhouse gas mitigation strategies from
now until 2050 is also, not a balanced
interpretation of the relevant chapters of
AR5. The IPCC presents a wide range of
technology and policy options and discusses
their implementation in a range of
scenarios. Many interpretations of these
options and scenarios are possible.
Nowhere is shale gas described as a key
component.

Dr Verdon highlights the complementary
nature of some renewables with natural gas
sources in the electricity supply sector.
However, other gas sources are available,
such as biogas and synthetic gas
(processed from biomass) to which a
transition could be made. A report by the
National Grid suggested that 5-18% of UK
gas could come from biogas by 2020
4
. With
much stronger measures on energy
conservation in homes, offices and industry,
this proportion could be significantly
increased.

The central argument of the section,

4
National Grid (2009). The potential for Renewable Gas in the UK. http://www.nationalgrid.com
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014























4. Socio-economic issues
While the impact of shale development on
gas prices is disputed, SGR/CIEH
neglect a key aspect of the potential
economic impact, which is the impact on
the wider economy, and to the exchequer.
It is expected that the need to import gas
will cost the UK economy over 15 billion
p.a.. This is money lost to the UK economy,
paying no tax and creating no jobs.
Domestic shale development ensures that
this revenue stream remains in the UK.
SGR/CIEH compare jobs created in both
shale and renewable energy industries.
This is a false comparison there is no
reason why we cannot encourage
investment in both of these industries.
SGR/CIEH claim that shale development will
have a negative impact on tourism, but
provide no evidence to back up this claim.
In fact, a recent study by Oxford
Economics (2013) has shown that, the 2009
though, is worth repeating: while shale gas
may replace coal locally, overall coal (and
other fossil fuel) use is increasing. In the
absence of a global cap on emissions, the
use of shale gas will be as well as, not
instead of, coal, thereby resulting in an
overall increase in emissions. This is a
widely understood conclusion, which was
even made by the UK government itself
5
.
Proven reserves of fossil fuels are already
around five times larger than those which
can be burnt and still give us a relatively
high chance of keeping below the
internationally agreed 2C global
temperature increase. Exploiting new fossil
fuel sources is likely to make it much harder
to keep below this target, even if
technologies like CCS can be rolled out on a
large scale. This is the central thrust of the
warning by the Committee on Climate
Change that we quoted.

Socio-economic issues
Dr Verdons point about money lost to the
UK economy due to gas imports can equally
be made as an argument for accelerated
investment and expansion of: energy
conservation measures (especially in
homes); biogas; electric heating; solar hot
water panels; and a wide range of other
renewable energy technologies. We discuss
this further below.

On the issue of investment being
encouraged in both shale gas and
renewable industries, we note, for example,
the current governments championing of
shale gas, while announcing its intention to
impose major restrictions on onshore wind
farms. We also note its poor treatment in
recent years of the solar photovoltaics
industry and the domestic energy efficiency
industry
6
.


5
MacKay, D.J.C and Stone, T.J. (2013) Potential greenhouse gas emissions associated with shale gas extraction
and use. A report for DECC. Available at: https://www.gov.uk/government/publications/potential-greenhouse-
gas-emissions-associated-with-shale-gasproduction-and-use.
6
See, for example: Webber P (2014). DECC creates more chaos in the energy efficiency sector.
http://www.sgr.org.uk/resources/decc-creates-more-chaos-energy-efficiency-sector
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

recession aside, tourism in Pennsylvania
has increased substantially in recent years,
at the same time as the Marcellus shale has
been under development.














6. Can we manage without shale gas?
In this section, SGR/CIEH neglect the many
different uses we have for natural gas.
Specifically, they focus on the use of
natural gas in electricity generation, which
accounts for only about 1/3rd of our
consumption, the rest being used in
domestic heating and cooking, and in
industrial processes. SGR/CIEH make no
attempt to examine how we might manage
without shale gas in these sectors, which
leaves a gaping hole in their analysis.
Even in their discussion of the electricity
sector, SGR/CIEH focus solely on the price
comparison between fossil fuels and
renewables. The fact that renewables are
becoming cheaper is to be welcomed.
However, the decreasing cost of
renewables has little bearing on whether
renewables alone will be able to meet
the needs of the UK consumer, both in
terms of overall demand, and in meeting
that demand as and when the consumer
requires it (i.e. without intermittency).
This question, rather than price alone, is
the pertinent one with regards the issue of
whether or not we need shale (or any
Regarding possible negative effects on
tourism, we note the lack of academic
research on this issue in the UK to date.
However, our communication with people in
Lancashire (SGR is based in Lancashire)
provides some anecdotal evidence that local
businesses have serious concerns. We
agree that we could have been more
specific in explaining our sources in our
report. However, we are not convinced that
the report Dr Verdon refers to on tourism in
Pennsylvania provides relevant evidence,
given that there are major social, economic
and environmental differences between that
state and the UK, and the report does not
explicitly investigate potential effects of
fracking.

Can we manage without shale gas?
This is a very broad area, which brings in
numerous issues, so our short analysis only
sought to scratch the surface.

We realise that we only briefly mentioned
energy conservation as a key way of
reducing dependence on natural gas
sources and, on reflection, we should have
been more explicit in describing such
measures. Arguably the most important
example is in reducing demand for gas for
space-heating in the buildings sectors via
improved insulation. This can play a very
large role but, unfortunately, as we noted
above, the current government has a poor
record in this area. For example, recent
figures from the Dept of Energy and
Climate Change indicate installations of
home insulation have fallen 77-93%
following the introduction of the latest
government schemes
7
.

Another key measure to reduce
dependence on natural gas for space-
heating is a large-scale switch to efficient
electric sources. Heat pumps (especially air-

7
Carrington D (2013). Number of households getting help with insulation plummets.
http://www.theguardian.com/environment/2013/dec/30/number-households-insulation-lofts-plummets-
green-deal
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

other) gas. SGR/CIEH make no attempt
to answer this, leaving a second gaping
hole in their analysis.
Fortunately, the National Grid have
provided a number of future energy
scenarios, while Friends of the Earth have
also made an admirable attempt to
outlining their ideal future energy scenario.
Whether one considers the National
Grids Gone Green scenario, or Friends of
the Earths Clean British Energy
scenario, it is clear that even under the
most optimal assumptions there is a
substantial need for natural gas in the UKs
energy sector, and that this need will
exist for some time to come, regardless of
whether we choose to develop shale
gas. SGR/CIEH claim a lack of space to go
into detail comparing renewables and
shale gas. However, when this work has
already been done, in great detail, by the
National Grid, it seems very strange indeed
that SGR/CIEH would want to completely
neglect their findings.
Finally, SGR/CIEH note that in nations
where extensive hydropower is available,
certain nations are able to become
sufficient in renewable energy. This is all
well and good, but has no bearing on the
situation in the UK, where we do not have
capacity for substantial hydropower, and is
therefore irrelevant with respect to the
issue of whether or not we need shale gas
in the UK.

To conclude:
I will couch my conclusions in the spirit in
which this letter has been written, namely
that of providing peer review. Given the
extent of factual errors, cherrypicking,
failure to consider relevant literature, logical
fallacies and statements unsupported by
evidence; were this report subjected to the
kind of robust peer review on which
modern science is based, then I do not
source) have a particular potential here
8
.
Indeed, a large increase in the fraction of
UK energy supplied through electricity use
especially for heating and transport is at
the heart of numerous low carbon transition
studies. This is why we made the main
focus of this section the issue of replacing
gas in the electricity supply sector. There is
widespread agreement for such a shift
across government, industry and
environmental NGOs. Again, on reflection,
we could have made this point more
explicitly.

And, as we noted above, concerted efforts
to increase the use of biogas are a key part
of efforts in this area.

Furthermore, we also note that there are a
number of low carbon transition studies
that have modelled UK scenarios which do
not include use of gas with CCS. For
example, WWF modelled two such
scenarios in their 2011 study
9
and the
Centre for Alternative Technology modelled
one in detail in their 2013 study
10
.









Conclusion
As with any briefing paper, particularly one
that seeks to provide an overview of a
number of complex aspects associated with
what is currently a highly emotive and
contentious subject, there will always be
scope for further improvement. However,
we would reiterate, that this briefing did
not set out to provide an in-depth critique
of every aspect referred to within the

8
MacKay, D. (2009) Sustainable Energy without the hot air.
9
WWF (2011). Positive Energy: how renewable electricity can transform the UK by 2030.
http://www.org.uk/renewables
10
CAT (2013). Zero Carbon Britain: Rethinking the Future. http://zerocarbonbritain.org/
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

believe it would make it through to
publication. To put things more bluntly, the
report represents a shocking lack of
scholarship, and falls well short of the
standards one would expect from a
professional society.
My concerns have their principal basis in
the accurate portrayal of a delicate and
sensitive topic. However, I feel I should
also point out the impact of the CIEHs
endorsement of this report, both on the
institution as a whole and on the rank and-
file membership.
The CIEH Professional Code of Conduct
places great importance upon maintaining
the standing and credibility of the
organisation (paragraphs 2.2 and
2.3). More specifically, paragraph 4.5 states
that members should take all reasonable
steps to ensure that information provided
by them in a professional capacity on a
matter within their knowledge or
competence is accurate and complete. It is
clear that this report achieves neither
accuracy nor completeness.
Presumably, the CIEH as an institution
wishes to add its voice to the debate over
UK shale development, and more
specifically to have an influence on
policymakers and regulators. However, by
attaching their name and making claims of
impartiality to a report that is neither
impartial nor reaches the standard of
scholarship expected of a professional
body, the CIEH risks of making itself
appear less than competent and less than
impartial in the eyes of stakeholders at the
heart of the UK shale discussion. As such,
the more likely outcome is that the views of
the CIEH are seen as both partisan and ill-
informed, and therefore to be dismissed,
with the net result that the CIEH is
marginalised from the debate, rather than
more deeply involved.
I also have concerns on the implications of
this report for the rank-and-file membership
of CIEH, on whom this report reflects
extremely badly. Note, for example, that
the lack of scholarship shown in this report
has already become the subject of ridicule
on social media. I myself do not regularly
publication. Rather it draws on relevant
peer-reviewed literature and independent
expert opinion to present an accessible yet
robust and fully-referenced overview of the
main issues, which readers may then
explore in more detail.

In summary our view is, respectfully, that
many of Dr Verdons criticisms either
misrepresent our text or are not well
grounded in the available evidence. Hence
we believe our report remains a useful
evidence-based guide of the major
environmental and socio-economic issues
related to shale gas development in the UK.

The panel of authors of this document have
now responded appropriately to the
comments made by Dr Verdon.

Comments from Graham Jukes

On the question of impartiality, I note that
Dr Verdon has omitted to state in his
correspondence whether the views and
comments that he has expressed are his
own personal views or whether they have
been endorsed by the University that he is
associated with. Given the comments he
has made about one of the authors of this
report, his additional omission to make a
statement of interest about any connection
with the Oil and Gas Industry given his
comments on social media channels casts
doubt on the credence of the views he has
expressed.

Dr Verdons final comments call into
question the professionalism not only of
those who the CIEH has charged with
providing an excellent review of the current
landscape, but the professionalism and
standing of the CIEH itself and its
members, which cannot go unchallenged.

The claims of factual errors, cherry-
picking, failure to consider relevant
literature, logical fallacies and statements
unsupported by evidence, shocking lack
of scholarship, falls well short of the
standards one should expect from a
Appendix 1
CIEH response to the comments received by Dr James Verdon on the joint CIEH/SGR report
Shale Gas and fracking: examining the evidence July 2014

interact with CIEH members (at least, not
to my knowledge). However, it would not
be surprising if some of your membership
were working in sectors that are, or are
likely to, interact with the nascent UK shale
gas industry. For example, in many cases
operators are looking to develop
relationships with independent
environmental consultants in order to
ensure their footprint is minimised.
However, for those whose first interaction
with the CIEH is this report, it might
be a natural assumption (erroneously, I
hope) that the lack of professionalism
shown in this particular report is
representative of CIEH members more
generally. One wonders whether this might
become a source of embarrassment,
or indeed the cause of lost opportunities
and marginalisation, for CIEH members
who might otherwise have a role to play in
advisory and/or regulatory roles.
Given the above failings, I would appreciate
a response from the CIEH that outlines and
justifies the decision-making process that
lead to the CIEH attaching their name to
this report. In particular, if the stated aim
was to produce an impartial, evidence-
based report, why the CIEH felt it
appropriate to appoint as lead author an
election candidate for a political party that
has stated is opposition to the industry in
the starkest terms, and who has
documented publicly her involvement in
protests outside of drilling sites?
I would also be interested to know whether
the document was subject to any kind of
review process by the CIEH (external or
internal) prior to publication? Of course,
once published there is no going back, but I
would also appreciate your response and
comments on the issues to which I have
drawn attention above.
Yours sincerely,
Dr. James Verdon, Ph.D., M.Sci,
MA(Cantab),
NERC Research Fellow,
School of Earth Sciences,
University or Bristol.
professional society rebuffed in this
response have not been substantiated, are
incorrect and misleading.

The report that has been produced by the
CIEH is robust and factually referenced.
The CIEH membership together with the
regulatory authorities responsible for
ensuring the health of people and their
communities are well served by its
publication.

There is no evidence that has been
presented to suggest that the CIEH code of
conduct has been breached and concerns
expressed by Dr Verdon are misguided, and
unfounded.

I dismiss entirely the remainder of the
comments by Dr Verdon as not evidenced
and completely without foundation.

On the final point about peer review. The
report prior to publication was circulated
internally for comment and those
comments were taken on board by the
authors. Final copy was submitted to me
and published under my authority as a
document worthy of carrying the quality
mark of the CIEH.












Response by the authors and peer
reviewers of the report compiled and edited
by
Graham Jukes OBE CFCIEH
Chief Executive
Chartered Institute of Environmental Health